Having cosmetics made by a contract manufacturer: process, duties and the brief

The EU Cosmetics Regulation defines the manufacturer as whoever manufactures a cosmetic product, or has it designed or manufactured, and markets it under their own name or trademark. For a product manufactured in the EU, this manufacturer is the responsible person. It may hand that role to another person established in the EU by written mandate, which that person accepts in writing.

For the brand this means: it must ensure that, before the product is placed on the market, a safety assessment has been carried out and a safety report set up, that a Product Information File is kept, that the product is notified in the CPNP and that the label carries the mandatory particulars. The contract manufacturer supplies many of the documents, but responsibility stays with the brand.

First, work out the idea and the brief. Second, choose a contract manufacturer with experience in the product category. Third, development and samples, usually over several rounds, until texture, fragrance and performance fit. Fourth, stability, preservation and, where relevant, tolerance and packaging tests on the selected version.

Fifth, safety assessment and building the Product Information File. Sixth, create the label and notify the product in the CPNP. Seventh, approve the formula and manufacturing instruction and produce the first batch. Eighth, after launch, document reorders, changes and complaints properly.

A brief describes the product so that the contract manufacturer can develop without coming back with questions: product idea and category, target group and skin type, texture, application and fragrance, desired actives and claims, no-go ingredients, intended certifications, target markets, packaging and fill size, price positioning, quantities and timeline.

The more precise these details, the fewer sample rounds are needed and the easier it is to compare quotes from different contract manufacturers. Record later changes to the brief so every decision remains traceable.

Check whether the contract manufacturer develops itself or only fills to someone else’s formula, whether it has experience with your product category, and what minimum quantities and capacity it offers. Ask which documents it supplies: method of manufacturing, GMP statement, test reports, raw-material data.

The law requires good manufacturing practice, not a third-party certificate. An audit or self-assessment can still be worthwhile. Also settle before development starts who owns the formula and what happens to the documents if you later change manufacturer.

There are no fixed prices. Cost depends mainly on development effort and the number of sample rounds, raw materials and packaging, minimum quantities, the tests required, the safety assessment, and artwork and printing.

Comparable quotes require a complete brief. Ask for development, tests, safety assessment and unit price separately, so you can see which items are one-off and which recur with every batch.

For the Product Information File, the brand needs a description of the product, the safety report, the description of the method of manufacturing with a statement on good manufacturing practice, evidence for claims and information on animal testing. For the label it needs the ingredient list in the right order and the warnings.

Agree by contract that the contract manufacturer supplies these documents per version and announces changes to raw materials or manufacturing in advance. Otherwise the file soon no longer matches the product on the shelf.

Claims appear on the packaging before there is evidence for them. The label is approved before the formula is final. The contract manufacturer swaps a raw material without telling the brand. Samples are approved by email without it being clear which version was meant.

The same remedy helps in every case: each approval refers to a named formula version, and every change after that is visible to both sides.

If the contract manufacturer uses VYVA, the brand sees its projects in the customer portal: status, brief and the formula sent for approval with its INCI list and percentages. It approves the formula there or rejects it with a comment, and the decision is documented with its date. That replaces sending individual files and ties every approval to a version.