Published Jun 16, 2026 | 7:00 AM ⚊ Updated Jun 16, 2026 | 7:00 AM
The Central Drugs Standard Control Organisation has clarified that products administered through injections do not qualify as cosmetics.
Synopsis: A CDSCO clarification that injectables are not cosmetics highlights a growing gap in public understanding of aesthetic medicine. Through conversations with young consumers and expert insights, the story explores how Botox, fillers and skin boosters occupy a grey zone between beauty and healthcare, blurring perceptions of risk, regulation and medical oversight.
“A doctor,” Sneha, a student, said when asked who should administer an injectable beauty treatment. “Because it’s an injectable treatment. But I think it’s done by salons as well.”
Sneha’s uncertainty is the focus of a growing conversation around aesthetic medicine in India. On 18 May 2026, the Central Drugs Standard Control Organisation(CDSCO) issued a public notice clarifying that products administered through injections do not qualify as cosmetics under the Drugs and Cosmetics Act, 1940.
Only substances that can be rubbed, poured, sprinkled, sprayed on, or applied to the human body, for cleansing, beautifying, promoting attractiveness, or altering appearance, meet the legal definition.
The notice did not announce a new rule. It restated one that already existed. The clarification arrives at a time when injectable aesthetic treatments such as Botox, fillers and skin boosters have become increasingly visible in mainstream beauty culture.
“I think anything that alters the natural features of your face or body,” Mallack, another student, told South First. “Even using a homemade face mask to brighten your skin tone counts as a cosmetic.”
Arya, 20, provided a more visual explanation. “I would like to think of cosmetics being used as painting done on a canvas. The canvas is one’s face.”
Both definitions focused on appearance rather than medical classification. Neither interviewee initially mentioned injectables when defining cosmetics.
Their examples centred on products applied to the surface of the body, makeup, face masks and appearance-enhancing products. Procedures involving needles appeared to occupy a separate category, even if consumers were not always certain where that category belonged.
Also Read: No cosmetic can be injected, India’s drug regulator tells beauty clinics
Mallack drew her own boundary between procedures. “There is a huge difference between plucking your eyelashes and having surgery to change your eye shape,” she said.
Botox, fillers, skin boosters, platelet-rich plasma therapy, mesotherapy, does not appear clearly on either side. Unlike foundation or lipstick, these treatments occupy a category that consumers often encounter only after entering the world of aesthetic clinics.
Yet unlike surgery, they are frequently discussed alongside skincare routines, anti-ageing regimens and beauty maintenance. That combination makes them difficult to place within traditional understandings of beauty and medicine.
Consumers encounter these treatments through social media, influencers, beauty clinics and word-of-mouth, in spaces that use the language of beauty rather than medicine. Arya’s canvas analogy holds here too. If cosmetics paint the surface, injectables do something the analogy does not account for, they enter the body entirely.
Also Read: Snapchat dysmorphia and Korean glass skin
“Botox and fillers could be performed by cosmetologists, I think,” Neeha, 19, told South First. “They aren’t as drastic and permanent as changing the shapes of your face.”
“Injectables should only be performed by qualified medical practitioners with training in facial anatomy, product selection, vascular safety and complication management,” Dr Debraj Shome, co-founder and director of The Esthetic Clinics, said.
Neeha added that fillers have become so common that she assumed non-medical professionals could perform them. Mallack believes dermatologists might recommend injectable treatments but that cosmetologists carry out the procedure itself.
Notably, none of the interviewees expressed uncertainty about plastic surgery. Surgery belonged firmly within medicine. The uncertainty emerged only when the conversation shifted to injectables. The procedure appeared less medical because it was perceived as less invasive.
Together, the responses suggest that while consumers associate surgery with medicine, they are less certain about who should administer a needle. Surgery requires a doctor. The injectable sits in a less certain space.
“The objective should not be to create fear around injectables, but to strengthen standards,” Dr Shome said. “Treatments involving toxins, fillers, devices and regenerative therapies require medical assessment, informed consent, documentation, product sourcing, and the ability to manage complications if they occur.”
Vascular injury, infection, allergic reactions and unintended outcomes can follow procedures performed without adequate training or clinical oversight. Some require urgent intervention.
A filler administered without vascular training in an unregulated space carries risks that a foundation applied to skin does not. The route of entry changes both the medical risk and the legal classification of the product.
These treatments are often encountered through beauty and wellness channels before consumers engage with the medical framework that surrounds them.
Dr Shome identified four questions consumers should ask any provider before undergoing treatment: what product is being used, who is administering it, why it is being recommended, and what follow-up care is available.
“The CDSCO discussion should be viewed as part of the natural maturation of India’s aesthetics and wellness ecosystem,” he said. “As the sector expands, clearer distinctions are needed between cosmetics, drugs, medical devices, biologically active formulations and medical procedures.”
Consumers are increasingly familiar with the language of fillers, Botox, skin boosters and aesthetic enhancements. What remains less clear is where beauty treatment ends and medical intervention begins.
The CDSCO notice may have restated the legal boundary. The public conversation is still catching up.
