India’s revised IS 4707 sets the numbers plainly: 20 ppm for lead, 2 ppm for arsenic, 100 ppm for total heavy metals in cosmetic raw materials. Parts 2 and 3 of the standard were reworked to carry those limits alongside a certification and audit framework, and to bring ingredient naming into line with the INCI system used internationally.
India is not alone in tightening here — Macao has banned mercury-added cosmetics outright from 2026. For anyone supplying into or manufacturing for the Indian market, the limits are the headline but the labelling change is the one that will consume more of your time.
What each part covers
Part 2 is the substance list. It sets out what may be used, at what levels, and where the contaminant ceilings sit — including the requirement to declare the composition of colours, dyes and pigments rather than listing them generically. Part 3 is procedural: certification pathways for raw materials, quality control expectations, and the audit mechanisms regulators use to verify them.
Splitting it that way is deliberate. A company can be compliant on paper against Part 2 and fail Part 3, because holding a certificate of analysis is not the same as running a system that generates one reliably for every incoming lot.
Where the heavy metals actually come from
The limits look strict until you know where the contamination originates, at which point they look targeted.
Heavy metal traces in cosmetics are overwhelmingly a colourant problem. Mineral-derived pigments — iron oxides, ultramarines, mica, titanium dioxide — carry whatever the geology of the source deposit contained, and the refining step determines how much of it survives into the finished material. Botanical extracts are the second contributor, since plants take up metals from the soil they grew in. Neither is an adulteration issue. It’s a sourcing and purification issue, and the fix is upstream of the formulator.
That’s why the ppm figures land hardest on colour cosmetics and on brands leaning heavily on botanicals. A clear serum built on synthetic actives is rarely near these ceilings. A lipstick with a deep pigment load, or a herbal-positioned cream with several plant extracts at meaningful concentration, is where testing gets tight.
The practical consequence: supplier qualification stops being a procurement formality. A pigment house that can supply a full heavy-metals profile per lot, and holds it consistently, is worth a price premium over one that cannot — because the alternative is testing every incoming lot yourself, which costs more and takes longer.
The INCI change is the bigger operational shift
Adopting INCI nomenclature sounds like a paperwork exercise. It isn’t, because it forces every ingredient in a formula to resolve to a single internationally recognised name — and legacy formulations, particularly ones built around traditional or regionally sourced materials, frequently don’t have one.
A supplier who has been shipping a botanical extract under a local trade name for twenty years now has to establish the correct INCI designation, which means establishing the species, the plant part, and the extraction solvent. Those details often weren’t documented. Reconstructing them takes months and sometimes requires re-qualifying the material entirely.
The upside is real once it’s done. A formula documented to INCI can be filed in most markets with modest adaptation, which is the whole point of harmonisation. It’s the same logic driving ingredient regulation updates across Southeast Asia — regulators converging on a shared vocabulary so that a dossier assembled once can travel.
Enforcement is not theoretical
Import permits have been revoked for products failing to meet the revised requirements. That’s the detail that separates this from standards updates which sit on a shelf. A brand planning an India launch on a timeline that assumes documentation can be tidied up after first shipment is planning to have inventory sitting in a port.
The Ayurvedic question
India’s regulators are trying to do two things simultaneously: align with international safety and naming frameworks, and preserve space for traditional ingredients that carry genuine domestic and export value. Those aims pull in opposite directions more often than the policy language admits.
A traditional preparation with centuries of use has cultural authority but frequently lacks the dossier a modern safety assessment expects — characterised composition, defined actives, toxicological data. Long use is not a substitute for that data under the framework being adopted, and pretending otherwise creates exposure rather than protection.
Korea worked through a version of this problem in a different category. Government certification for natural and organic cosmetics was replaced with a private, science-based system built on ISO 16128 guidelines, which define natural and organic content by calculable indices rather than by a regulator’s list. The transition was uncomfortable — brands lost a state endorsement consumers recognised — but it produced a claim that meant something arithmetically and that international buyers could verify.
The route available to Indian manufacturers is comparable: keep the traditional ingredient, build the modern dossier around it, and let the two credentials reinforce each other. A botanical with both a documented traditional lineage and a full safety file is a stronger export proposition than either credential alone.
Practical steps
Audit your colourant supply chain first, since that’s where the ppm limits bite. Ask for lot-level heavy metals data, not a one-off certificate, and check whether the supplier tests or relies on their own upstream vendor’s claim.
Start the INCI mapping now if any part of your formulation history predates it. This is the work with the longest lead time and the least visibility, and it does not compress under deadline pressure.
Treat your compliance documentation as a commercial asset rather than a filing obligation. Buyers ask for it directly now, and a brand that can produce a complete file quickly closes deals that a brand promising to send it next week does not.
Traceability tooling is worth evaluating at this point, though with realistic expectations. QR-coded labels linking to ingredient origin data, and digital lot tracking through the supply chain, both work and both are being deployed — the same infrastructure shift that’s reaching packaging sourcing and specification. Blockchain-based systems get more attention than their adoption justifies; the underlying benefit is disciplined record-keeping, which most companies could achieve with a well-run database.
And build the assessment step earlier into development. Discovering that a pigment can’t meet the ceiling after the shade range is locked means reformulating the whole range, not one shade.
“Ingredient standard overhauls like this tend to get treated as a purely regulatory story, but from where we sit, they’re also a branding opportunity that a lot of companies leave on the table. In client conversations with brands entering the Indian market, we’ve noticed that pairing compliance with the country’s revised heavy-metal and labeling limits with messaging that respects local traditions — Ayurvedic ingredients alongside internationally validated safety data — tends to land better than a purely Western-science pitch or a purely traditional one. The practical takeaway we share with clients is to treat compliance documentation as content, not just paperwork, since increasingly informed consumers are starting to ask for it directly.” — Hyejin Cho, Digital Marketing Specialist, Marketing and Communication Team at SPSCOS