Most brands spend weeks agonising over shade names and packaging finishes. Far fewer devote that same energy to choosing the manufacturer who'll be responsible for what's inside the bottle or box. 

Your choice of manufacturer affects everything: from product quality, regulatory exposure, and speed to market to your ability to scale when a product takes off. 

We work with cosmetics and personal care brands on regulatory compliance and international market entry, and we see the consequences of good and bad manufacturer choices all the time. Here's our 10-minute guide to choosing an EU or UK cosmetics manufacturer:

‍Get the regulatory basics locked down first

A product that doesn't meet regulatory requirements can't be sold. And in cosmetics, the regulatory bar is high and getting higher.

‍The EU framework

The governing legislation for cosmetics sold in the EU is Regulation (EC) No 1223/2009. It's been in force since July 2013 and covers safety, labelling, ingredient restrictions and post-market surveillance.

Every product needs a Responsible Person based in an EU member state. This is a legal entity that carries personal accountability for ensuring each product is compliant before it reaches consumers. 

Among other things, the Responsible Person is required to compile and maintain a Product Information File (PIF) containing the safety assessment, manufacturing method, evidence supporting any claims, and full ingredient composition.

Products must also be registered on the Cosmetic Products Notification Portal (CPNP) before they go on sale. 

One thing to be aware of: the regulation isn't standing still. Commission Regulation (EU) 2023/1545 expanded the list of declarable fragrance allergens from 26 to over 80 ingredients, with full compliance required by July 2026. Annexes II and III have also seen updates with new CMR (carcinogenic, mutagenic, or toxic to reproduction) substance bans coming through. 

‍The UK framework

Brexit created a separate regulatory system for manufacturing beauty products sold in Britain. The UK now operates its own version of the Cosmetics Regulation and compliance with the EU framework does not equal compliance in the UK. 

Products going onto the Great Britain market (England, Scotland, Wales) need to be notified through the Submit Cosmetic Product Notification (SCPN) portal, which sits under the Office for Product Safety and Standards (OPSS). 

You also need a UK-based Responsible Person – a separate appointment from your EU RP unless the same entity is legally established in both places.

Northern Ireland follows different rules again. Under the Windsor Framework, it aligns with EU Cosmetics Regulation, meaning products sold there must meet EU requirements and go through the CPNP.

If you're selling in both markets, you need dual compliance. Your manufacturing partner should be able to talk you through the differences.

‍Manufacturing standards to look for

Regulatory compliance gets your product to market; manufacturing standards keep quality consistent once you're there. Two standards are critical in the production of cosmetics and beauty products: 

• GMP certification: GMP stands for Good Manufacturing Practice, and in the EU and UK it's mandatory. The Cosmetics Regulation requires it, and proof of GMP compliance has to sit in the Product Information File for every product.

• ISO 22716:2007: this internationally recognised standard for cosmetics is referenced by the EU Cosmetics Regulation. Published by the International Organization for Standardization, it provides guidelines covering production, control, storage and shipment.
  
  ISO 22716 touches most aspects of how a cosmetics manufacturing facility operates. It sets out requirements for staff training and defined responsibilities, facility design and contamination controls, equipment calibration and maintenance, raw material sourcing and traceability, batch-by-batch production documentation, quality control testing, and internal auditing. The goal is repeatability so that batch 50 of your moisturiser is identical to batch one.
  

Interrogate their technical capability

With the regulatory boxes ticked, you next need to know whether the manufacturing facility can produce your specific products to the standard you need.

‍Formulation

There's a split in the industry between manufacturers who develop formulations from a brief and those who only produce to a supplied formula. Where your brand sits in the product development cycle determines which type of partner you need.

If you're relying on the manufacturer for formulation, their R&D capability becomes critical. How many cosmetic chemists do they have? What's their depth in your category? A team that's brilliant at serums might struggle with a complex pressed powder range, for example. 

‍Product formats

Facilities are set up for specific product types. Liquid fills, hot-pour, aerosols, pressed powders, sticks; not every manufacturer handles all of them. Some outsource formats they can't produce in-house. Find out early what they do and don't cover, and if outsourcing is involved, ask who does it and how quality is managed.

‍Minimum order quantities (MOQs)

Minimum order quantities vary widely, from manufacturers who will run a few hundred units to those who won't look at anything under 10,000 SKUs. This is particularly important if you're exploring private-label cosmetics in the UK or the EU, where initial volumes are often modest. Forcing a mismatch – e.g. being a small brand in a big factory, or big ambitions in a micro-batch operation – can create problems on both sides.

‍Packaging

Clarify the packaging model before you go too far down the road. For example, does the manufacturer handle sourcing, compatibility testing, filling and assembly? Or are you expected to supply your own components? Each setup has knock-on effects for your timeline, cost base, and how many relationships you're managing.

‍Use the development process as your litmus test

How a manufacturer handles the sampling and development stage is one of the best indicators of what the ongoing relationship will be like.

A solid brief should cover product type, sensory targets, key actives, fragrance direction, claims you want to make, price point, and any non-negotiables around certification or ingredient exclusions.

From there, the manufacturer will produce bench samples: small-scale prototypes for your evaluation. Pay attention to how long this takes. Four to six weeks for a first bench sample is reasonable. Beyond that, ask why.

Additionally, find out how many rounds of refinement are included before you start paying for extras. Two or three iterations is fairly standard. And look at how feedback is managed. Is there a defined review process, or are you chasing updates through email threads with no structure?

‍Cosmetics stability testing and micro testing

Once you've signed off on a formulation, the next development step is testing. Cosmetic stability testing subjects the product to heat, cold, light and temperature cycling over time, generating the data that supports your shelf-life claim (either an expiry date or Period After Opening statement). This data goes into the PIF.

Microbiological testing establishes that the product can resist microbial contamination throughout its shelf life. The EU Cosmetics Regulation requires this as part of the Cosmetic Product Safety Report (CPSR) and broader safety assessment. 

Things you may want to know from the manufacturer about testing include: 

• When does testing start in the development process?
• What stability protocols do they use and over what timeframes? 
• Do they run accelerated studies alongside real-time studies? 
• Is micro testing done in their own lab or sent out? 

‍Make sure your claims will stand up to scrutiny

Making claims on cosmetic packaging requires evidence to back them up. Your manufacturer should be able to help by sourcing certified raw materials, keeping chain-of-custody documentation, or working with test houses for independent substantiation.

Commission Regulation (EU) No 655/2013 sets out common criteria for cosmetic claims, including that they must be truthful, supported by evidence, fair, and enable consumers to make informed choices. 

If your brand relies on certifications (e.g. COSMOS, Ecocert or Vegan Society approval), check whether the manufacturer already holds those certifications or whether they'd need to work towards them.

Read more > UK beauty and cosmetics claims: what you can (and can't) say.

‍Think ahead: scale, lead times and supply chain

A manufacturer that's right for producing 500 units might not be right for 50,000. Think about where you're going, and how that could impact partner choice.

For example, if demand spikes, can the manufacturer keep up? How much spare capacity do they have? How quickly can they scale a run? And conversely, if demand disappoints, are you locked into volumes you can't shift?

First runs take longer than reorders. Make sure you understand the realistic timeline for an initial production run, so your launch plans aren't built on overambitious assumptions. For reorders, determine the lead time they need and whether they hold buffer stock of your key ingredients. 

It's also worth asking about their supply chain more broadly. Where do they source key raw materials? Do they have pre-approved alternative suppliers if their primary source has issues? Ingredient shortages or shipping delays can catch brands off guard.

Communication is another important consideration. How easy is it to reach people? Can you talk to a formulator directly, or does everything pass through an account manager? How are production updates conveyed? What happens when there's a problem?

Bear in mind the responsiveness you experience during the sales process. If it's slow and disorganised from the start, it probably won't improve once they have your business.

Finally, when something goes wrong with a product, your ability to find out what happened depends on the quality control records behind it. Ideally, full batch traceability should run from raw material receipt right through to finished product release. This is your safety net if a complaint or recall happens. 

Ask potential manufacturing partners if you can see a sample batch record. The level of detail will tell you whether documentation is taken seriously or treated as a box-ticking exercise.

‍Your checklist for choosing a UK/EU cosmetics manufacturer 

Before you commit to a manufacturing partner, here are some questions to run through:

Regulation:

• Do they comply with EU Regulation (EC) No 1223/2009 and/or the UK Cosmetics Regulation? 
• Can they support PIF compilation and CPNP/SCPN notification? 
• Are they on top of ingredient restrictions and regulatory updates?

GMP and quality:

• Are they ISO 22716 certified or able to demonstrate documented GMP compliance? 
• Do they have full batch traceability? 
• Do they offer stability, micro and challenge testing as standard?

‍Capability:

• Do they manufacture your product types and formats? 
• Are there in-house formulation services if you need them? 
• Do their MOQs work for your volumes now, with room to grow?

‍Process: 

• Do they have defined development timelines and iteration rounds? 
• Do they offer packaging support? 
• Are their lead times clearly laid out for first runs and reorders?

‍Partnership:

• Is their communication responsive and transparent? 
• Are they experienced with brands at your stage? 
• Can they support the certifications you need?

If you can, go and see the facility. Walk the production floor, see how the team interacts and how organised the warehouse is. Compare what you see to what you were told. 

The right manufacturer will protect your brand through compliance, deliver consistency through their quality systems, and give you the technical foundation to build products people love. It’s worth putting the time and effort in to find the ideal match. 

‍Hooley Brown helps cosmetics brands with regulatory compliance, labelling and international market entry, including finding the right manufacturing partners through our global resource network. We can also act as your Responsible Person in the UK and EU.

Book an exploratory call to tell us about your project.