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How to vet a cosmetic contract manufacturer

Ask for eight documents, understand what each one proves and what it does not, and you will catch most of what goes wrong in a cosmetics manufacturing deal before any money moves.

The one-line answer: in cosmetics, holding a certificate and being compliant are two different things. Most buyers treat them as the same thing, and that is where the money is lost.

What a contract manufacturer actually is

A contract manufacturer makes a product to a specification — yours or one you buy — and puts your brand on it. It may also hold the formula, run the fill line, and handle the primary packaging. What it does not do, in most jurisdictions, is take over your legal obligations as the brand owner. Keep that split in mind: it is the reason the documents below are split the way they are.

If what you actually want is a ready-made formula with your label on it, start with private label vs contract manufacturing instead — the two are not interchangeable and the vetting questions differ.

The eight documents worth asking for

Every row below answers the same three questions: who signs it, what it proves, and — the part usually left out — what it does not prove.

What each document proves, and its limit
DocumentWho issues itWhat it provesWhat it does not prove
Business licenceThe company registry in the factory's jurisdictionThat the legal entity exists, and who its registered owner isNothing about capability or product safety
GMP certificate for cosmeticsAn accredited certification body (the cosmetics GMP standard is ISO 22716)That the site passed an audit against cosmetics GMP at a point in timeWhich products the scope covers, or that the certificate is still valid — verify the number on the issuer's own register
Quality management certificateAn accredited body (commonly ISO 9001)That a quality system existed at the audit dateThat your specific product is safe. Check the revision year: a current site showing a 2000- or 2008-revision certificate is running on an unread template
Facility registration confirmationThe manufacturer, filed through the FDA cosmetics portalThat the facility has been registered with the FDAThat the FDA has approved the product or the factory
Product listing confirmationThe "responsible person" named on the labelThat the product has been listed with the FDAThat the product is compliant, or reviewed
Safety assessment (the EU "CPSR")A qualified safety assessorThat a safety assessment exists for the formula or productThat the brand's own obligations are discharged — in the EU the responsible person must still hold the file
Batch record and certificate of analysisThe factory, one per production lotWhat was tested on that specific batchThat the tests cover what matters to you — read the parameters, not the header
Stability and compatibility reportThe factory's own labThat a formula was held over time in a given packThat it holds in a different pack, a different climate, or after a formula change

Three checks you can run yourself

  1. Verify every certificate number on the issuer's own site. Take the registration number off the PDF and look it up at the body that issued it. A number that cannot be found, or a scope that does not name the site you are buying from, is the single most common finding.
  2. Read the revision year. Superseded standards on a live page usually mean the page has not been read in years. That tells you about attention, which is exactly what you are trying to judge.
  3. Match names across three documents. The website, the licence and the proforma invoice should point to the same legal entity. Three different names is a signal, not a formality.

What "FDA registered" does and does not mean

Facility registration and product listing are filing obligations. They are not approvals. The FDA has stated plainly that it does not issue any certificate, letter or other document to verify that a cosmetic facility or product complies with the law — a point worth knowing, because marketplaces and buyers routinely ask sellers for exactly such a document. See the FDA statement on certificates and compliance documents. For the wider picture of what the FDA does and does not do with cosmetics, see how cosmetics are regulated but not "approved".

There is no such thing as "FDA approved" for a cosmetic. The one exception is colour additives, which do require pre-market approval and, for some, batch certification — see colour cosmetics requirements. If a supplier leads with "FDA approved", that is a claim to slow down on, not a reason to trust faster.

The questions that expose a weak supplier fastest

Related reading

Frequently asked questions

Is a GMP certificate enough to trust a cosmetic contract manufacturer?

No. A GMP certificate shows a site was audited against cosmetics GMP at some point. It does not name your product, and it does not prove the certificate is still valid — always verify the number on the issuing body's own register and check the scope names the site you are buying from.

Does FDA facility registration mean a product is approved?

No. Registration and product listing are filing obligations, not approvals. The FDA has stated it does not provide certificates or other documents verifying that a cosmetic facility or product complies with the law.

Can a manufacturer claim 'FDA approved' for a cosmetic?

No. Cosmetics are regulated but not approved by the FDA. The one exception is colour additives, which require pre-market approval and, for some, batch certification.

What is the difference between facility registration and product listing?

Facility registration is filed by the manufacturing facility; product listing is filed by the responsible person named on the label. In a private label project these are usually two different companies, which is why the paperwork should name both.

Should I ask for a certificate of analysis for every batch?

Yes, and read the parameters rather than the header. A batch record tells you what was tested on that lot; only you can judge whether those tests cover the characteristics that matter for your product.

How do I check a Chinese manufacturer's business licence?

Cross-check the legal entity name on the licence against the name on the website and the proforma invoice, and against the public enterprise credit registry. Three documents pointing to three different names is a warning sign.

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