Switching cosmetic factory with the same formula

Define what actually changes

This guide concerns supply in Great Britain. Our beauty and personal care guide covers the launch basics. For a factory switch, prepare a comparison of the approved and proposed processes: ingredient grades and suppliers, water source, mixing order, heating and cooling, bulk holding, transfer equipment, filling and closures.

Check the full quantitative formula against the approved version. An unchanged ingredient list does not establish identical concentrations or raw-material specifications. Give the Responsible Person and safety assessor the comparison, existing reports and proposed production records before committing to commercial production.

Review GMP at the actual production site

OPSS says cosmetic manufacture must comply with good manufacturing practice. Ask the Responsible Person to review evidence for the actual mixing and filling operations, including any subcontractor. Request cleaning records, water-quality results, equipment maintenance, staff training, contamination controls and batch-release procedures.

Treat a factory certificate as a starting point. Check its site and scope against where your product will be made, then examine records from comparable production. Ask how operators record deviations and prevent unapproved process changes. Our Responsible Person guide helps clarify who owns the compliance decision.

Update the file around the new process

Ask OPSS to confirm the product information file requirements for the manufacturing method, GMP statement and safety report. Replace outdated process descriptions and add the new site's supporting evidence. Keep the previous version identifiable so the history of existing stock remains clear.

OPSS advises reviewing the safety assessment when new data might alter its conclusion. Ask the qualified assessor to document whether the existing assessment remains applicable, what supporting information needs updating and whether the safety conclusion or warnings need revision. Keep the assessor's reasoning with the evidence rather than accepting a factory assurance that the formula is unchanged.

Choose tests against the changed risks

OPSS guidance says testing may be necessary to complete the safety information. Ask the assessor to identify gaps in existing evidence and agree a targeted test plan. The suggestions below are discussion prompts, not a prescribed testing package. Use samples made through the proposed manufacturing and filling process in the intended packaging.

Make release a recorded decision

Agree release conditions before ordering saleable stock: acceptable process evidence, completed assessor review, resolved test findings and an updated file. Record which existing reports were retained and why. If a result differs from the approved product, investigate before accepting the batch.

Keep old-site and new-site stock distinguishable through batch records, retained samples and shipment documents. Our batch traceability guide explains the wider chain. Cambridge China Bridge's staff in China can gather site records and coordinate production samples; the Responsible Person and safety assessor should make the compliance and safety decisions.