Your Supplement Contract Manufacturer Has a December 31 Deadline
Any facility that manufactures, processes, packs or holds dietary supplements for sale in the United States has to renew its FDA food facility registration between October 1 and December 31 of every even-numbered year. 2026 is one of those years, which puts the deadline 63 days out. If you are a beauty brand adding your first supplement SKU, that date belongs to your supplement contract manufacturer rather than to you — and it is still your inventory sitting behind it.
The deadline is fixed, free and easy to miss
Dietary supplements and their components are “food” under the Federal Food, Drug, and Cosmetic Act, so a plant making capsules, tablets, powders or gummies registers as a food facility, not as a cosmetic one. FDA spells that out in question C.2.3 of its food facility registration questions and answers, and extends it in C.2.9 to facilities making supplement raw materials.
The renewal window itself comes from 21 CFR 1.230(b). There is no fee. Submissions go through FDA Industry Systems electronically unless the agency has granted a waiver, and the registration needs a unique facility identifier — currently a DUNS number. Facilities with nothing to change since their last submission can use the abbreviated renewal under 1.230(c). FDA restated all of it in a constituent update on September 29, 2026, in one blunt sentence: the agency will consider the registration expired for any facility that fails to renew by December 31, 2026.
Expired is not a grace period. Under 21 CFR 1.241, a facility with an expired registration is treated as having failed to register at all, and failing to register is a prohibited act under section 301(dd) of the Act. The one piece of good news is in question D.2.6: a renewal submitted complete on or before the deadline is not treated as expired just because FDA has not finished processing it. Submitted on time counts. Submitted in January does not.
Your cosmetic manufacturer runs on a completely different clock
This is where brands running skincare and supplements side by side get caught. Cosmetic facilities also renew every two years, under section 607(a)(2) of the Act as amended by the Modernization of Cosmetics Regulation Act. But the cosmetic clock is a rolling anniversary, not a shared national window. FDA’s own worked example on its registration and listing page: an initial registration received on February 20, 2024 is due for renewal by February 20, 2026. Cosmetics Direct now shows a registration status and a renewal date field so facilities can see their own.
So a plant that fills both a serum and a capsule carries two unrelated renewal dates under two different sections of the same statute. Add the separate cosmetic product listing, which the responsible person updates annually, and “we are registered with FDA” stops being a single fact with a single expiry.
FDA will not send either of them a certificate
If you are planning to ask a factory for proof, read FDA’s September 9, 2026 clarification first. The agency says it does not issue a certificate proving facility registration, does not issue a verification letter or email confirming a facility is registered, and does not issue a letter confirming that someone is exempt from registering. It notes the question is being driven by ecommerce platforms, TikTok Shop among them, asking sellers to produce exactly those documents.
The food side works the same way. Registration numbers are not published — the list of registered food facilities sits outside the Freedom of Information Act — and FDA’s answer at M.4 is that suppliers and their customers are expected to settle verification in their own buy and sell agreement. Question L.2 is the sentence worth quoting at anyone who oversells this: assignment of a registration number does not in any way convey FDA’s approval or endorsement of a facility or its products. Registered is a filing status, not an endorsement.
What to ask before you place the order
Put these in an email, not a phone call, and keep the reply:
- Has this facility submitted its food facility registration renewal for the window closing December 31, 2026, and on what date was it submitted?
- Is the supplement work done at the same registered address as the skincare work, or at a second site with its own registration?
- For the cosmetic side, what is this facility’s MoCRA renewal date, and when was the product listing last updated?
- Will the supply agreement carry a written commitment to maintain registration and to notify us within a set number of days if it lapses?
- Who is named as the responsible person on each finished product — because on cosmetics that is almost certainly your company, not the factory’s.
A manufacturer that answers all five in writing, with dates, is telling you something useful about how it runs its paperwork generally. One that offers you a certificate instead is telling you something too.
Moe’s Group manufactures dietary supplements and skincare in-house in Chatsworth, California, with supplement capacity up to 1,000,000 units a month and a 1,000-unit minimum on supplement runs. We would rather you asked us the five questions above than took our word for it: our certifications page has the documents we can actually hand over, and the product inquiry form reaches the people who can answer the rest with dates attached.
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