How to verify cosmetics factory GMP evidence
Match the factory's GMP evidence to the actual manufacturing site and the processes used for your cosmetic product. Verify certificate scope, examine completed batch records and check whether production controls support the statement. Cambridge China Bridge can gather factory evidence through its own staff in China.
Define what the evidence must support
For cosmetics supplied in Great Britain, manufacture must comply with good manufacturing practice. As the Responsible Person, you remain responsible for ensuring the regulatory requirements are fulfilled. ISO 22716 is commonly used to demonstrate GMP, but it is not the only route. Ask the factory which approach it follows and what evidence supports it.
Build a product-specific evidence request: manufacturing-site details, process description, relevant procedures, completed production records, audit findings and corrective actions. Use our factory audit checklist for general supplier checks; the additional task here is connecting cosmetic manufacturing controls to your product.
Match documents to the actual manufacturing site
Identify where bulk manufacture, filling, packing and storage will happen. Match those addresses and activities against the GMP statement, any certificate and the audit report. Ask whether another plant or subcontractor performs any stage. A certificate for the supplier's head office gives you no useful assurance about an unnamed filling site.
Where a certificate is offered, confirm its authenticity and current status directly with the issuer. Check the holder, site address, scope and exclusions. Ask for the underlying audit findings and evidence that corrective actions were checked. Record any mismatch before approving the site, rather than accepting a sales explanation without supporting records.
Observe controls while production is running
Commission a visit during relevant production and ask the quality lead to show how contamination and mix-ups are controlled. Examine staff hygiene and training records, cleaning logs, equipment maintenance, material identification and segregation. For water used in manufacture, ask for treatment arrangements, test results and the response to an unacceptable result.
Compare written procedures with what operators actually do. Look at line clearance before filling, identification of bulk awaiting use, segregation of rejected materials and storage conditions. Record the location, activity, document reference and observed gap. These are practical evidence checks, not a claim that this checklist reproduces every requirement of ISO 22716.
Follow a batch through its records
Ask the factory to retrieve a completed batch record for a comparable product, then repeat the exercise for your production. Trace the approved formula and instructions through ingredient lots, weighing, mixing, process checks, filling, packaging and release. Cross-check entries against material labels and laboratory records instead of reading the batch sheet in isolation.
Ask who can release a batch, how failed results and deviations are investigated, and how rework is authorised and recorded. Check that formula or process changes reach the production instructions. Agree access to your own batch records before ordering. Our filled cosmetics inspection guide covers the separate check on finished goods.
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Build support for the GMP statement
The Responsible Person must keep the Product Information File in English, including how GMP has been followed. Ask for a dated GMP statement identifying the manufacturer, manufacturing sites, covered products or processes, approach used and responsible signatory. Treat these as useful evidence fields. Link the statement to the manufacturing description, reviewed records and audit findings.
Keep an evidence index showing what was reviewed, unresolved gaps, corrective-action owners and closure evidence. Pause acceptance where site identity, contamination controls or batch traceability remain unexplained. Agree notification of changes to sites, subcontractors and processes so you can reassess the evidence. Use our cosmetics file and safety assessment guide for the wider file.
Frequently asked questions
Is an ISO 22716 certificate enough?
Do not accept it on its own. Verify the issuer, site and scope, then check production records and actual controls. ISO 22716 is a recognised way to demonstrate GMP, but it is not the only way.
What if the factory has no GMP certificate?
Ask which GMP approach it follows and request procedures, completed batch records and audit evidence. Assess whether those records support the statement; the absence of a certificate does not answer that question.
Can I use evidence from another factory in the group?
Only use it where it actually covers your manufacturing site and relevant activities. Ask for site-specific records and an explanation of shared controls. Group ownership alone does not establish what happens on your line.
What should I do if the GMP evidence has gaps?
Record the missing evidence and agree corrective actions with named owners. Obtain closure records and recheck the affected controls before acceptance. Ask for specialist review where you cannot assess the manufacturing risk.