The FDA confirmed in September that it issues no certificate, letter or email proving a cosmetic factory is registered. For brands shortlisting a US manufacturer, that changes what due diligence has to look like.

From January 1, 2027, California bars manufacturing, selling, delivering, holding or offering 30 listed intentionally added ingredients in cosmetics. Because “manufacture” and “hold” are both prohibited, a California facility is caught even for out-of-state orders.

The FDA says it issues no proof-of-registration certificate. Here is how the filing duties actually split between a private label brand and its manufacturer.

There is no zero-cost route to a cosmetic brand in the United States, but the floor is knowable. Here is what federal law makes unavoidable, what it exempts, and which costs are genuinely optional.

The FDA does not recognize the word “cosmeceutical”. Your product is a cosmetic, a drug, or both — and your claims, not your category, decide which.