Can You Verify a USA Skincare Manufacturer Is FDA Registered?
If you are vetting a skincare manufacturer in the USA and you have asked for a copy of its FDA registration certificate, you are not going to get one — and not because the factory is hiding something. On September 9, 2026 the FDA stated plainly that it does not provide certificates or other documents verifying compliance for cosmetic product facility registration, and there is no public database to look a facility up in. The agency said it issued the clarification because it had received an increased number of inquiries asking for exactly that paperwork.
So the question every founder asks at the shortlist stage — prove you are registered — has no documentary answer. Here is what you can verify instead, and which half of the obligation lands on you rather than on the factory.
What the FDA actually said
The FDA will not issue a certificate as proof of facility registration or product listing, will not issue a verification letter or email stating that a facility is registered, and will not issue a document confirming that a facility or responsible person is not required to register. All three are routinely requested by brands and retailers running supplier checks.
The agency also restated something that matters more than the paperwork: registration and product listing are “neither a cosmetic approval program nor a promotional tool,” and a registration number “does not indicate FDA approval of the facility or its cosmetic products.” There is no FDA approval program for cosmetics at all. So if a supplier’s site upgrades “registered” into any claim of agency approval, that is not a stronger credential — it is a claim about a program that does not exist.
The duty is split, and your half has your name on it
Section 607 of the FD&C Act, as amended by the Modernization of Cosmetics Regulation Act of 2022, divides the obligation in two. The facility registers itself and renews every two years. Separately, the responsible person — the manufacturer, packer or distributor whose name appears on the label — must list each marketed product with the FDA, ingredients included, and update it annually.
In a white label or custom formulation deal, your name is on the label. The product listing is yours to file, not the factory’s, and you cannot file it without the factory’s registration number: the FDA uses the FDA Establishment Identifier (FEI) as that number, and the listing submission requires it. The FEI is the one concrete thing a manufacturer can actually hand you.
The exposure is asymmetric too. The FDA can suspend a facility’s registration, and while a suspension is in force it is a prohibited act to distribute or sell cosmetic products from that facility in the United States. The suspension belongs to the factory. The finished inventory in your warehouse belongs to you.
The first renewal wave is live right now
Registrations renew biennially, and renewal dates run from the date of initial registration rather than a common annual deadline. The FDA’s own worked example: an initial registration received on February 20, 2024 carries a renewal date of February 20, 2026. Facilities that registered in the first compliance window are hitting their first renewals across 2026, through either a biennial or an abbreviated renewal in Cosmetics Direct. So a registration that was current when you signed is not evidence of one that is current today — and you cannot check.
Two details catch brands out. Registration applies to contract manufacturers wherever they sit, so an overseas factory making product for US distribution must register too. And per FDA guidance, there is no exemption from registration for following ISO 22716 — a supplier answering “we’re ISO certified” has answered a different question.
What to ask instead of asking for a certificate
- Ask for the facility’s FEI number in writing. You need it for your own product listing, and a supplier who cannot produce it quickly has a problem.
- Ask for the initial registration date, the most recent renewal submission date, and which renewal route was used.
- Confirm in writing who each side treats as the responsible person. If your brand is on the label, it is you — agree that before launch, not after.
- Contractually oblige the manufacturer to keep its registration current and to notify you immediately of any suspension, since your inventory becomes unsellable the moment one bites.
- Treat GMP and quality documentation as a separate line of questioning. Useful, but not a substitute for registration.
- Check that any small-business exemption a supplier claims actually applies. It does not cover products that contact the mucous membrane of the eye, injected products, products for internal use, or products intended to alter appearance for more than 24 hours where consumer removal is not part of normal use.
The honest version of the answer
You cannot verify FDA registration through the FDA. You can verify that a manufacturer knows which obligations are theirs and which are yours, can produce its FEI number without a week of searching, and will commit in writing to keeping it current. A factory that volunteers the split before you ask is telling you more than any certificate would have.
Moe’s Group is an FDA registered contract manufacturer in Chatsworth, California, formulating, filling and labeling skincare, hair care and body care in one facility — white label from 200 units, custom formulation from 1,000. Certificates are downloadable at moesgroup.com/certifications, and if you want the registration and responsible-person questions answered for your project, send us the details.
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