Contract cosmetics manufacturers and ISO 22716 – why is GMP an absolute must when choosing a manufacturing partner today?

You’re building a cosmetics brand. You have a vision for the product, you know your customer, and you know how you want to position the brand. You do not plan to handle production yourself – you are looking for a proven contract manufacturer to whom you can entrust production. This is an increasingly popular model in the industry and has many advantages. It also carries one key risk: if you choose the wrong manufacturer, you will bear the consequences – not them.

ISO 22716 certification does not solve all the problems involved in choosing a manufacturing partner. But the lack of it should be a clear warning sign for any brand.

Why does the responsibility for quality lie with the brand, not the manufacturer?

This is one of the most important facts that many young cosmetics brands are unaware of when they start out. Under the EU Cosmetics Regulation, the brand is the responsible party for a product placed on the market – not the facility that manufactured it. This means that if a product turns out to be defective, contaminated or dangerous, the brand is liable to the consumer, regulatory bodies and the media.

In practice, this boils down to one thing: the quality of the production process at your contract manufacturer is your problem. You cannot pass it on to a subcontractor and think that the matter does not concern you. You can only choose a manufacturer that minimises this risk – and ISO 22716 certification is one of the strongest indicators available that this is indeed the case. This is particularly important if the brand plans to enter foreign markets in the future, where the requirements for manufacturers may be more stringent.

What does GMP certification say about a contract manufacturer?

A production facility holding ISO 22716 certification has undergone an independent audit which confirmed several key points. Its manufacturing processes are documented and reproducible – each batch of product is manufactured according to the same, documented procedures. Hygiene conditions are monitored systematically, rather than on an ad hoc basis. Raw materials are verified before use, and their suppliers are qualified. The non-conformity and complaints handling system is operational and documented.

For a brand outsourcing production, this information has a direct bearing on business security. An ISO 22716-certified manufacturer knows what to do when something goes wrong – and has procedures in place to respond quickly and effectively. A manufacturer without certification may have equally good intentions, but lacks a documented system to enforce them.

What questions should you ask a contract manufacturer before signing a contract?

Vetting a contract manufacturer is a process that should be carried out before signing any contract – not after the first customer complaint. As well as asking about ISO 22716 certification and checking that it is up to date and verifying the certification body that issued it, it is worth asking about a few specific matters.

What is the process for qualifying raw materials and suppliers – does the manufacturer verify each supplier, or do they use pre-approved lists of suppliers? How is quality control carried out during production, and what happens to a batch that does not meet specifications? How does the manufacturer handle a situation where, after a batch has been released, it turns out that the product is defective – do they have a recall procedure and how quickly can they implement it? Is production documentation available to the brand on request and in what form?

A manufacturer who answers these questions efficiently and in detail is likely to have a functioning system. A manufacturer who gives vague answers or asks for time to check – provides valuable information even before the contract is signed.

GMP certification as part of a contract with a manufacturer

Many cosmetics brands do not include certification requirements in their contracts with contract manufacturers. This is a mistake that can prove costly. It is worth ensuring that the manufacturing contract includes not only the product specification and pricing terms, but also a commitment from the manufacturer to maintain a valid ISO 22716 certificate throughout the duration of the partnership, as well as an obligation to immediately inform the brand of the results of certification audits and any significant non-conformities detected during the manufacturing process.

Such a clause is not a sign of mistrust – it is part of a professional business relationship in which both parties know what they expect from each other. And it protects the brand should anything go wrong.

If you would like to find out what requirements a cosmetics manufacturer must meet and what the certification process involves, you can find more information on the page dedicated to ISO 22716.