This is a practical guide to how to choose a private label manufacturer, written by one. We manufacture skincare, hair care and supplements at our own facility in Chatsworth, California, so we have an interest here and you should read it knowing that. What follows is the set of questions we would ask if we were the ones buying, including the ones that are awkward to answer.
The checklist
| What to check | What good looks like |
|---|---|
| GMP certificate number and standard | ISO 22716 for cosmetics. Verify the number, and check the scope names your product category. |
| Accreditation of the certificate | Accredited certificates are checkable at iafcertsearch.org. Unaccredited ones are not. |
| FDA establishment identifier (FEI) | Real and checkable. Registration is a filing obligation, never an approval. |
| Where production physically happens | Own facility, contracted out, or offshore and relabelled. Ask to visit. |
| Batch verification on actives | Purity grade, who verifies it, what is tested per batch, certificate of analysis. |
| Formulation competence | Ask what breaks with your ingredient and why. Specificity is the tell. |
| Written MOQ and lead time | In writing, not verbal. |
| Formulation ownership on exit | Who owns the formula if you move. |
| Claims support | What you can legally print. Cosmetic versus drug claim line. |
How do you verify a manufacturer is really GMP certified?
Ask for the certificate number and the standard, then check it yourself. For cosmetics the standard is ISO 22716. Two details matter more than the logo. First, the certified scope: a certificate that names skin care but not hair care does not cover your shampoo. Second, accreditation: a certificate issued by an accredited body can be verified through the IAF register at iafcertsearch.org, and an unaccredited one cannot. Ask which applies. A manufacturer who cannot produce a number is telling you something.
Does FDA registration mean a product is FDA approved?
No, and any manufacturer who implies otherwise is misstating the position. Cosmetic manufacturing facilities are required to register with the FDA and receive an establishment identifier, known as an FEI number. That is a filing obligation, not an endorsement. The FDA does not approve cosmetic products or the facilities that make them. Ask for the FEI number, because it is real and checkable, and be wary of anyone selling you the phrase FDA approved.
Should I ask to visit the factory?
Yes, and pay attention to the answer more than the tour. A manufacturer producing in their own facility can usually say yes. One who contracts production out, or relabels finished goods sourced offshore, often cannot, and the reason they give is informative. You are not inspecting equipment; you are testing whether the story you were told is true.
What should I ask about ingredient sourcing and batch testing?
For any active you are paying for, ask three questions. What purity grade is it, who verifies that, and what is tested on each incoming batch. With copper peptides, for instance, purity alone is not enough – the copper-to-peptide ratio is what the formulation depends on, so it should be verified per batch rather than assumed from a supplier sheet. Ask for a certificate of analysis. If the answer is vague at this stage, it will not improve later.
How do I know if a manufacturer can actually formulate, or just fill?
Ask what goes wrong with the ingredient you care about, and why. Anyone who formulates for a living will have a specific answer. With copper peptides they should mention pH sensitivity, oxidation, and incompatibility with certain actives. With tallow they should mention oxidation and scent. A manufacturer who says every ingredient is straightforward has probably not formulated with it.
What claims can I legally make about my product?
Less than most brands assume, and this is where new brands get into trouble. In the United States a cosmetic may affect appearance; the moment it claims to treat, prevent or cure something it is a drug, and drugs follow a completely different regulatory path. Published research on an ingredient is not a trial of your product, and citing it as though it were is a common and serious error. A manufacturer worth working with will tell you where the line sits rather than let you walk over it.
What are the red flags?
A few, in rough order of seriousness. Claims of FDA approval for a cosmetic. GMP claimed without a certificate number or standard. Unwillingness to discuss where production physically happens. Ingredient percentages quoted without any batch verification behind them. Comparison articles and best manufacturer roundups that turn out to be published by one of the manufacturers being compared, which is common enough that it is worth checking who owns any list you are relying on. And pressure to commit before you have seen a sample.
What should I have in hand before signing anything?
A sample you have actually used. A certificate of analysis for the batch it came from. The GMP certificate number and standard, verified. The FEI number if you are manufacturing in the US. Written minimum order quantity and lead time, not a verbal figure. And clarity on who owns the formulation if you leave.
A note on how to choose a private label manufacturer using online roundups
Search for the best private label manufacturer in almost any category and you will find ranked lists. Many are published by manufacturers, which does not make them worthless, but it does mean the ranking is marketing rather than assessment. Check the footer and the about page of any list you are relying on. We publish this guide under our own name for the same reason: you should know who is talking.
How Moe’s Group answers its own checklist
- GMP: ISO 22716:2007, certificate 25-I-0062, scope covers skin care, hair care and oils
- Also held: ISO 9001:2015 (accredited by UAF) and ISO 45001:2018 (accredited by KAB)
- FDA: registered facility, FEI 3041507202
- Production: our own facility in Chatsworth, California. Formulation, filling and labelling in house. Visits welcome
- Batch verification: purity, and for copper peptides the copper-to-peptide ratio and bioactivity, per batch
- Verify us: download every certificate, or check the accredited ones at iafcertsearch.org
Frequently asked questions
How do you verify a manufacturer is really GMP certified?
Ask for the certificate number and the standard, then check it yourself. For cosmetics the standard is ISO 22716. Two details matter more than the logo. First, the certified scope: a certificate that names skin care but not hair care does not cover your shampoo. Second, accreditation: a certificate issued by an accredited body can be verified through the IAF register at iafcertsearch.org, and an unaccredited one cannot. Ask which applies. A manufacturer who cannot produce a number is telling you something.
Does FDA registration mean a product is FDA approved?
No, and any manufacturer who implies otherwise is misstating the position. Cosmetic manufacturing facilities are required to register with the FDA and receive an establishment identifier, known as an FEI number. That is a filing obligation, not an endorsement. The FDA does not approve cosmetic products or the facilities that make them. Ask for the FEI number, because it is real and checkable, and be wary of anyone selling you the phrase FDA approved.
Should I ask to visit the factory?
Yes, and pay attention to the answer more than the tour. A manufacturer producing in their own facility can usually say yes. One who contracts production out, or relabels finished goods sourced offshore, often cannot, and the reason they give is informative. You are not inspecting equipment; you are testing whether the story you were told is true.
What should I ask about ingredient sourcing and batch testing?
For any active you are paying for, ask three questions. What purity grade is it, who verifies that, and what is tested on each incoming batch. With copper peptides, for instance, purity alone is not enough – the copper-to-peptide ratio is what the formulation depends on, so it should be verified per batch rather than assumed from a supplier sheet. Ask for a certificate of analysis. If the answer is vague at this stage, it will not improve later.
How do I know if a manufacturer can actually formulate, or just fill?
Ask what goes wrong with the ingredient you care about, and why. Anyone who formulates for a living will have a specific answer. With copper peptides they should mention pH sensitivity, oxidation, and incompatibility with certain actives. With tallow they should mention oxidation and scent. A manufacturer who says every ingredient is straightforward has probably not formulated with it.
What claims can I legally make about my product?
Less than most brands assume, and this is where new brands get into trouble. In the United States a cosmetic may affect appearance; the moment it claims to treat, prevent or cure something it is a drug, and drugs follow a completely different regulatory path. Published research on an ingredient is not a trial of your product, and citing it as though it were is a common and serious error. A manufacturer worth working with will tell you where the line sits rather than let you walk over it.
What are the red flags?
A few, in rough order of seriousness. Claims of FDA approval for a cosmetic. GMP claimed without a certificate number or standard. Unwillingness to discuss where production physically happens. Ingredient percentages quoted without any batch verification behind them. Comparison articles and best manufacturer roundups that turn out to be published by one of the manufacturers being compared, which is common enough that it is worth checking who owns any list you are relying on. And pressure to commit before you have seen a sample.
What should I have in hand before signing anything?
A sample you have actually used. A certificate of analysis for the batch it came from. The GMP certificate number and standard, verified. The FEI number if you are manufacturing in the US. Written minimum order quantity and lead time, not a verbal figure. And clarity on who owns the formulation if you leave.
Talk to us, or don’t
If this guide helps you evaluate someone else, it did its job. If you want to run your product past us, the inquiry form is below and you are welcome to visit the facility first.