Pigments affected
Two reds (CI 15850, CI 15880) and one yellow oxide (specific particle-size grade) commonly used in lipstick and powder formulations move to the restricted list.
Restricted status doesn't ban use entirely — it requires brand-specific exemption application with safety data, or alternative pigment qualification.
Action timeline
Audit lipstick and powder ranges immediately for the affected pigments. Most indie beauty SKUs use one or more of the three.
Submit exemption applications by August — late applications won't process before the January effective date.
Pre-print labels only after final amendment notification (expected July 2026).
Reformulation cost
Replacement pigments add ₹1.40 – ₹3.20 per stick depending on the affected shade. Cumulative across an 18-shade range, ₹25 – ₹60 lakh annual COGS impact for a mid-size brand.
Some shades are not replicable with alternative pigments — the brand must drop or significantly shift the shade tone.
Industry response
Three industry associations are jointly petitioning for exemption extension to January 2028. Outcome unclear; plan as if January 2027 holds.
Major MNCs are well-prepared; indie brands materially exposed. Smart move: collaborate with peers on shared exemption data.
§ KEY TAKEAWAYS
- 01Audit lipstick and powder ranges immediately
- 02Submit exemption applications by August
- 03Pre-print labels only after final amendment notification
- 04Budget ₹25 – ₹60 L annual COGS impact for mid-size brand
- 05Some shades will need to be discontinued — accept early
- 06Collaborate with indie peers on shared exemption data
§ GLOSSARY
Technical jargon, acronyms and scientific terms used in this file — decoded.
- BIS
- Bureau of Indian Standards — issues IS-codes and the ISI mark for product quality compliance.
- IS 4707
- Indian Standard governing permissible cosmetic ingredients, including pigment and colourant lists.
- CI number
- Colour Index number — international identifier for every pigment and dye approved for cosmetic use.
- Lake pigment
- An insoluble pigment made by precipitating a water-soluble dye onto an inert metallic salt; common in lipsticks and powders.

