Changing cosmetics manufacturers requires confirmation that the new partner can make a product that meets the agreed specification. The formula, process and components need to be checked, and tasks divided between the brand and the manufacturer. Separately, the parties must establish who acts as the Responsible Person under the applicable regulations.
Outdated documents or samples may mean that a transfer requires the product to be redeveloped. A discussion about contract cosmetic manufacturing should therefore begin by establishing what must remain unchanged, what needs to be adapted and which decisions must be approved before the first batch.
Does changing manufacturer mean developing the product from scratch?
Not always. A transfer can be based on an existing formula and documentation, but the new manufacturer must independently confirm that it can make the product using its own process and meet the agreed specification. An INCI ingredient list alone or even a formula without process instructions does not describe the sequence of operations, process parameters, quality criteria or the behaviour of the bulk product during filling and packing.
The first step is to establish who has the right to use the formula and share it with the new manufacturer, and which data may be transferred. The new partner then assesses whether the information is complete, whether raw materials are available, whether the packaging is compatible with the line and whether trials are needed. If a raw material needs to be substituted, the process changed or a component adapted, the effect on the product and its documentation should be assessed before commercial production.
What should a product transfer package include?
A sample taken from the market cannot be the sole point of reference. The package should enable the approved product to be reproduced and the new batch to be compared with the correct reference. In practice, it includes:
- the approved formula version and process instructions, including critical parameters;
- raw material and finished product specifications, including permitted tolerances;
- quality control methods, acceptance criteria and relevant test results;
- the packaging system specification and available data on its compatibility with the product;
- a reference sample, change history, and the version and status of each document.
Each item should specify its date or version, approval status, the party authorised to share it and the extent to which the new manufacturer may use it.
The change history helps distinguish critical parameters from earlier trials and explains why a particular viscosity, fragrance, dispensing performance or permitted tolerance for a quality parameter was accepted. The guide to cosmetic product readiness before production explains the broader testing context. During a transfer, continuity between the documented version, the reference sample and the product made by the new manufacturer is essential.
What needs to be checked again with the new manufacturer?
A complete set of documents supports the assessment, but it does not replace the work needed to establish production. Before production begins, the brand and the new manufacturer should verify five areas:
- the feasibility of the formula with the available raw materials and equipment;
- whether the prepared sample matches the agreed reference and specification;
- whether the process can be transferred to production scale;
- the compatibility of the product with its packaging and the feasibility of efficient filling and packing on the intended line;
- the readiness of the documentation and the agreed division of responsibilities.
The scope depends on the product, the changes and the market. A previous assessment cannot automatically be carried over to a changed raw material, process or packaging.
Regulation (EC) No 1223/2009 requires manufacturing in accordance with good manufacturing practice (GMP). The Responsible Person retains and updates the Product Information File (PIF), which includes, among other things, the safety report, a description of the manufacturing method and a statement of compliance with GMP. During a transfer, the parties need to check whether the changes affect the PIF, safety report, labelling or information submitted through the CPNP, the EU Cosmetic Products Notification Portal. A change of manufacturer alone does not automatically require a new notification; information that has actually changed must be updated. The brand and manufacturer should clearly establish who prepares the data, who approves it and who fulfils the duties of the Responsible Person.
How can you move between manufacturers while maintaining continuity of supply?
The schedule should coordinate product stock, raw material and packaging deliveries, the time needed for trials and the decision on the first production run. It should also identify the points at which a decision is made to continue or pause the transfer. These include sample approval, confirmation of the process at production scale, packaging approval, confirmation that the documentation is ready and release of the first batch. The decision to end production with the existing manufacturer should take into account confirmation of the new manufacturers readiness, sufficient stock for the transition period and the terms of the agreement with the current partner. A stock buffer only helps if it allows for the actual time needed to establish production and make adjustments.
A related Canexpol Group case study describes the operational transfer of 10 stock keeping units (SKUs), which also involved work on formulas and samples. It demonstrates the importance of a shared plan, but it is not a model for a straightforward transfer of an unchanged formula. Each project requires a separate assessment of feasibility, responsibilities and timelines.
A well-prepared change of manufacturer starts with a reliable product version and is only complete when the new batch meets the agreed specification and the documentation and supply chain are ready to support continued production. Such a transfer involves more than moving files: it is the controlled reproduction of a repeatable process under new conditions.
