Department of Rasashastra & Bhaishajya Kalpana, Faculty of Ayurveda, Institute of Medical Sciences, Banaras Hindu University, Varanasi.
Ayurveda, one of the most effective systems of traditional medicine, is experiencing a resurgence in India’s consumer market, particularly through personal care products such as hair oils. With the rise of both legacy and digital-first (D2C) brands, questions regarding compliance with the Drugs and Cosmetics Act, 1940, the Drug Rules, 1945, licensing by the Ministry of AYUSH, and implementation of Good Manufacturing Practices (GMP) in the true spirit have become increasingly important. This article examines five prominent brands manufacturing Bhringraj-based hair oils: Indulekha, Khadi Natural, Mamaearth, Nat Habit, and Nidhi’s Grandmaa Recipe. The analysis compares compliance with labelling and packaging rules as per the Drug Rules, 1945, and the Cosmetics Rules, 2020, AYUSH or cosmetic licensing, GMP certification, and advertising claims. The findings reveal inconsistencies between claims and certifications, highlighting the dilution of Ayurveda into cosmetic branding. This regulatory gap threatens the authenticity of Ayurveda and undermines global standardisation efforts. The study concludes with recommendations to strengthen compliance, enhance consumer education, and foster a more scientific, globally credible, and authentic form of Ayurveda that is better positioned for the marketplace.
In the evolving global healthcare paradigm, traditional medicine systems are gaining recognition for their holistic, preventive, and patient-centric approaches. Among these, Ayurveda, with a history spanning over 3,000 years, continues to occupy a prominent position. It emphasizes balance among bodily humors (Tridoshas), the use of natural substances, and the optimization of physiological processes through tailored therapeutics. Within this traditional realm, Sneha Kalpana (lipid-based formulations), comprising medicated oils and ghritas, constitute a cornerstone of therapeutic interventions for both systemic and local disorders. The renewed interest in Ayurveda is largely driven by a shift in public health behaviour favoring natural, chemical-free, less toxic, and time-honored treatment regimens, especially in the management of chronic, degenerative, and lifestyle-related diseases. Notably, Ayurvedic medicated oils have gained traction not only in classical therapeutic contexts such as Abhyanga (oleation therapy), Basti (medicated enemas), Nasya (nasal administration), and Shirodhara, but also in cosmetic, dermatological, and wellness sectors. The Ayurvedic products market in India reflects this upward trend. As of 2024, it reached a valuation of ?875.9 billion and is projected to grow at a compound annual growth rate (CAGR) of 16.17%, reaching ?3,605 billion by 2033 (IMARC Group, 2024)[1]. Similarly, the Forum on Indian Traditional Medicine (FITM), under the Research and Information System for Developing Countries, reported that India’s AYUSH industry was valued at USD 18.1 billion in 2020-21, underscoring its expanding economic footprint (FITM, 2021)[2]. A major trend driving this market growth is the increasing adoption of Ayurveda in mainstream wellness and personal care practices, including skincare, haircare, beauty, and overall wellness. Standardization and regulatory compliance are fundamental to the credibility of any system of medicine. In India, Ayurveda is regulated under the Drugs and Cosmetics Act, 1940 (D&C Act), the Drug Rules 1945 and its subsequent amendments, empowering the Ministry of AYUSH to oversee the manufacturing, licensing, and marketing of Ayurvedic, Siddha, and Unani (ASU) drugs[3]. According to the Drug Rules 1945, a set of quality criteria-based information is required to be displayed on the labels of Ayurvedic product containers marketed in India. Rules 161 and 161B of the Drug Rules 1945 outline mandatory labelling and packaging requirements, including disclosure of ingredients, batch numbers, manufacturer details, license numbers, and shelf life for ASU drugs, both classical and proprietary[4,5]. Additionally, Schedule T of the Drug Rules 1945 specifies Good Manufacturing Practices (GMP) for ASU drugs[6], ensuring product quality, reproducibility, and safety essential for standardization, while all so-called herbal and natural cosmetic products are governed by the Cosmetic Rules, 2020[7]. Despite this framework, the market exhibits a blurred line between Ayurvedic proprietary medicines and herbal cosmetic products. While authentic Ayurvedic formulations, classical or proprietary, require AYUSH licensing[8], numerous brands classify their products as cosmetics under the Central Drugs Standard Control Organisation (CDSCO) governed by the Cosmetic Rules, 2020, while using Ayurvedic herbs, imagery, and subtle claims, excluding the use of words like prevent, cure, and treat. This regulatory duality and loophole raise concerns about the commercial and scientific dilution of Ayurveda, as products adopt its identity without complying with established standards. The Indian market has witnessed a surge in Ayurvedic personal care products, which is driven by heritage companies and digital-first startups. Hair oils containing Bhringraj (Eclipta alba) are widely marketed for preventing hair fall, improving scalp health, and restoring natural shine and strength. Classical texts describe Bhringraj taila as a preparation crafted through Sneha Kalpana, with defined methods, ingredients, and therapeutic claims. However, many modern products exploit the Ayurvedic identity under the ‘herbal’ tag, thereby evading strict regulatory compliance and raising concerns about authenticity, safety, standardization, and, most importantly, the scientific validation of Ayurveda.
This study investigates the compliance landscape through the example of popular Bhringraj-based hair oils, which contain Bhringraj, known in Ayurveda as Keshraj (king of hair).
METHODOLOGY
This study examines five companies: Indulekha (owned by Hindustan Unilever, positioned as an Ayurvedic proprietary medicine), Khadi Natural (by Khadi Natural Healthcare, recognized for luxury wellness products), Mamaearth (Honasa Consumer Ltd., a D2C unicorn marketed as a toxin-free natural cosmetic), Nat Habit (a D2C clean beauty startup emphasizing an Ayurvedic ‘kitchen-fresh’ positioning), and Nidhi’s Grandmaa Recipe (featured on Shark Tank India, inspired by traditional DIY oils). Data were collected from product packaging and labelling (as presented on company websites and e-commerce platforms), in addition to claims communicated through packaging and digital media.
The selected products were systematically compared across the following parameters:
These parameters were selected to assess the degree of regulatory compliance, the authenticity of Ayurvedic positioning, and the potential dilution of Ayurveda in the marketplace due to cosmetic-oriented branding.
RESULTS
The comparative analysis of five Bhringraj hair oils is summarized in Table 1 and 2. Table 1 presents the compliance status of each product with respect to licensing, GMP certification, and claim alignment, while Table 2 evaluates adherence to mandatory labelling and packaging requirements under Rule 161/161B of the Drugs Rules, 1945, and the Cosmetic Rules, 2020.
Table 1. Comparative Compliance Analysis of Bhringraj Hair Oils
|
S. No. |
Brand |
Name of Hair Oil |
D&C Act, 1940 Classification |
GMP Certification |
AYUSH / Cosmetic License |
Regulatory Framework |
Claims vs Certification Alignment |
|
1. |
Indulekha[9,10] |
Bringha Ayurvedic Hair Oil
|
Ayurvedic Proprietary Medicine |
GMP certified |
AYUSH license |
Rule 161/161B of the Drug Rules, 1945 |
Aligns |
|
2. |
Khadi Natural[11,12] |
Ayurvedic Bhringraj Hair Oil
|
Cosmetic product |
GMP certified |
Likely cosmetic license |
The Cosmetic Rules, 2020 |
Claims Ayurvedic benefits, uses ‘Ayurveda’ in the product name incorrectly. |
|
3. |
Mamaearth[13,14] |
BhringAmla Hair Oil
|
Cosmetic product |
GMP certified |
Cosmetic license |
The Cosmetic Rules, 2020 |
Claims 100% natural but uses words like ‘ayurveda recipes’ and ‘kshirapaka method’ |
|
4. |
Nat Habit[15,16] |
Neem Bhringraj Hair Oil |
Ayurvedic Proprietary Medicine |
GMP certified |
AYUSH license |
Rule 161/161B of the Drug Rules, 1945 |
Authentic Ayurveda claims match the license |
|
5. |
Nidhi’s Grandmaa Secret[17,18] |
13 Herbs Hair Oil |
Cosmetic |
Likely GMP certified |
Cosmetic license |
The Cosmetic Rules, 2020 |
Positions as ‘Ayurvedic medicated hair oil, 100% Ayurveda’ but no AYUSH license |
Table 2. Comparative Compliance Analysis of Rule 161/161B of the Drug Rules, 1945, and the Cosmetic Rules, 2020, of Bhringraj Hair Oils
|
S. No. |
Parameters under Rule 161/161B of the Drug Rules, 1945/ the Cosmetic Rules, 2020 |
Indulekha |
Khadi Natural |
Mamaearth |
Nat Habit |
Nidhi’s Grandmaa Secret |
|
|
Name and address of the manufacturer |
ü |
ü |
ü |
ü |
ü |
|
|
Net weight of the formulation |
ü |
ü |
ü |
ü |
ü |
|
|
Name of the drug/ingredient |
ü |
ü |
ü |
ü |
ü |
|
|
Botanical name of the drug/ingredient |
ü |
NA |
NA |
û |
NA |
|
|
Part used of the drug/ingredient |
ü |
NA |
NA |
û |
NA |
|
|
Net weight of each ingredient in the metric system |
ü |
û |
ü |
û |
û |
|
|
Batch number |
ü |
ü |
ü |
ü |
ü |
|
|
Licence number |
ü(AYUSH) |
ü |
ü |
ü(AYUSH) |
û |
|
|
Date of manufacturing |
ü |
ü |
ü |
ü |
ü |
|
|
Mentioning the word “Ayurvedic medicine” |
ü |
NA |
NA |
û |
NA |
|
|
For external use only |
ü |
ü |
ü |
ü |
ü |
|
|
Mentioning the expiry date |
ü |
ü |
ü |
ü |
ü |
|
|
Package insert |
ü |
ü |
ü |
ü |
ü |
(ü- Present, û- Absent, NA- Not Applicable)
DISCUSSION
The analysis highlights several critical regulatory issues:
A well-defined regulatory demarcation between Ayurvedic proprietary medicines and herbal cosmetics that utilize Ayurvedic herbs, plant-based ingredients, or marketing phrases such as ‘Ayurveda-inspired’ or ‘prepared using Ayurvedic methods’ is imperative in the current context. The absence of such clarity creates regulatory ambiguities that are often exploited by brands, allowing products to appropriate the identity of Ayurveda without adhering to its rigorous standards of formulation, licensing, and clinical validation. Misleading representations of this nature highlight the urgent need for stricter enforcement through the Drugs and Magic Remedies (Objectionable Advertisements) Act, 1954, or comparable legal instruments designed to prevent deceptive or exaggerated health-related claims. Strengthening compliance norms for both Ayurvedic, Siddha, and Unani (ASU) drugs and cosmetics, in tandem with well-articulated regulatory boundaries, is crucial to preserving the authenticity, credibility, and therapeutic integrity of Ayurveda. Such reforms would ensure that Ayurvedic proprietary medicines are distinguished from cosmetic products not only in terms of licensing and labelling, but also in terms of their evidence base and permissible claims. Furthermore, by closing existing regulatory loopholes, these measures can help protect consumers from misinformation while simultaneously supporting genuine Ayurvedic innovations. The establishment of a robust regulatory framework that emphasizes standardization, scientific validation, and transparency is essential for Ayurveda’s global positioning. Rather than being relegated to the informal category of home remedies or colloquially referred to as “dadi ka nuskha,” Ayurveda must be recognized as a scientifically credible, evidence-based system of traditional medicine with the potential to make substantive contributions to contemporary healthcare.
CONCLUSION
This study highlights critical gaps in the regulatory framework for Ayurvedic cosmetics, which are often exploited by D2C brands, leading to the dilution of Ayurveda in the marketplace. To preserve Ayurveda’s credibility, enforcement of AYUSH regulations must be strengthened, along with comprehensive reforms to curb the misuse of the term ‘Ayurveda’ in herbal cosmetics. Consumer awareness initiatives must be undertaken to clearly communicate the differences between Ayurvedic drugs, proprietary formulations, and herbal cosmetics. The establishment of a public digital registry of AYUSH licenses and GMP certifications, similar to the e-Aushadhi portal, with mandatory disclosure even for cosmetics, is crucial. Without such measures, Ayurveda risks being reduced to a mere marketing label, thereby weakening its global recognition as a traditional medical system.
ACKNOWLEDGEMENT
The authors acknowledge the contribution of Prof. Anand K. Chaudhary in the conceptualisation of the core idea of the study.
REFERENCES
Kanika Nainwal*, Anand Chaudhary, Branding V/S Compliance: Exploring Marketing Tactics and Regulatory Adherence in Bhringraj Hair Oils, Int. J. of Pharm. Sci., 2025, Vol 3, Issue 9, 1690-1698 https://doi.org/10.5281/zenodo.17129082
10.5281/zenodo.17129082
