Ask a cosmetic contract manufacturer about three
credentials, and understand that they are not the same kind of thing. ISO 22716
is an auditable good-manufacturing-practice standard — a third party
issues a certificate with a number and a defined scope, and it is the one you
can actually verify. cGMP is a regulatory expectation, not a certificate:
nobody issues a “cGMP certificate” for cosmetics, so
“cGMP certified” on its own means little without an audited
standard behind it. FDA registration is an administrative filing under MoCRA,
never an approval. Ask for all three — but treat the ISO 22716
certificate, its scope and its accreditation as the part you check
yourself.
If you have read that a cosmetic manufacturer must register with the FDA and
wondered what else you should be checking, this is the next question. Facility
registration is the manufacturer’s legal obligation; certifications are your
due diligence. The three credentials founders hear most often — ISO 22716,
cGMP and FDA registration — are constantly bundled together in sales decks
as if they were interchangeable badges. They are three different kinds of thing,
and knowing which is which is the difference between verifying a claim and
taking it on faith.
which of these he can actually check.
What is the difference between ISO 22716, cGMP and FDA registration?
They get confused because they are three different kinds of thing.
ISO 22716 is a certifiable international standard for cosmetics
good manufacturing practice: a third-party body audits the facility against it
and issues a certificate carrying a number and a defined scope. cGMP
— current Good Manufacturing Practice — is a regulatory expectation
rather than a certificate, so for cosmetics there is no single issuing
body and no certificate to hand you. When a manufacturer says it “operates
to cGMP,” the credible version of that claim is usually an ISO 22716
certification sitting behind it. FDA registration is an administrative
filing that puts the facility on record with the agency and produces an
establishment identifier (an FEI number). One is audited, one is expected, one
is filed.
- ISO 22716
- An auditable cosmetics GMP standard. Third-party audit, certificate with
number and scope. Verifiable — especially when the issuing body is
accredited. This is the credential to ask for by name. - cGMP
- A regulatory expectation of good manufacturing practice. No cosmetics
certificate exists, so “cGMP certified” is only meaningful if an
audit standard such as ISO 22716 sits behind it. - FDA registration
- A facility filing under MoCRA producing an FEI number. Checkable, but a
filing, never an approval. The FDA does not approve cosmetics or the
facilities that make them.
That last line matters more than any other in this article.
The FDA does not approve cosmetic products or the facilities that make
them, and describing a cosmetic as approved by the FDA is a
misstatement. Under the
Modernization of Cosmetics Regulation
Act (MoCRA), manufacturers must register their facility and list their
products — and that registration must be renewed every two years from the
initial registration date, so it is an ongoing obligation, not a one-time box to
tick. A supplier who tells you they are approved by the FDA is either
mistaken about the law or hoping you are; the phrase describes something that
does not exist for cosmetics.
the accreditation are the proof. Chuffy brought a magnifying glass.
How do I actually verify an ISO 22716 certificate?
Getting the word “ISO 22716” on a sales deck is trivial;
verifying it is four questions. Ask them in order and stop at the first one that
has no answer.
- Which standard, in full? You want “ISO
22716:2007,” not “GMP certified” or “GMP
compliant.” The vaguer the phrasing, the less there is behind it. - What is the certificate number? If none is offered, you
have your answer already. A real certificate has a number. - What is the certified scope? This is the one founders
skip. A certificate whose scope names skin care does not cover your shampoo,
and one covering skin and hair care does not cover your lipstick. The scope
line has to name your product category. - Is it accredited, and by whom? A certification body can
itself be accredited by a national accreditation body, and those bodies sign
the IAF Multilateral Recognition Arrangement. When that chain exists, the
certificate can be looked up in a public register rather than taken on trust.
When it does not, the certificate may still reflect a real audit — but
you have no independent way to confirm it, and you verify it through the
issuing body directly instead.
Where does the checking actually happen? Accredited certificates can be
confirmed through the IAF register at
iafcertsearch.org. Where the issuing body is not part of the
IAF chain, you verify the certificate number directly with that body’s own
registry — so ask which applies and treat the answer as information, not as
a pass or fail. Moe’s Group, an FDA-registered contract manufacturer in
Chatsworth, California, has published a plain-language breakdown of exactly these
four questions: for a fuller walk-through of
how ISO 22716, cGMP and FDA registration
compare, it is a useful second opinion precisely because it is written by a
manufacturer telling you what to ask a manufacturer — including the sentence
that describing a cosmetic as approved by the FDA is a misstatement.
it is true. Chuffy has learned to check the second before trusting the
first.
Why does certified scope matter more for contract manufacturing?
How hard you need to press on scope depends on which manufacturing route you
are buying — and the three routes are not interchangeable. On cost, on lead
time and on how much control you hold, the order never changes: white
label sits below private label, which sits below contract
manufacturing. The further up that ladder you go, the more a
certificate’s scope has to be pinned down in writing.
- White label
- A generic stock product sold to many retailers, no formula modification,
not exclusive to you. Cheapest and fastest. The manufacturer’s existing
certifications already cover the stock formula — the scope check is
simply confirming your product category is named. - Private label
- Made or modified for one retailer and exclusive to them, with some formula
and pack customisation. Costs more and takes longer than white label. The
existing certified process usually covers the modification, but the scope
still has to name the category. - Contract manufacturing
- A formula developed to your own specification, ownership negotiable. Most
expensive and slowest — and the route where scope verification matters
most, because a novel format or an unusual active may fall outside a
certificate written for a standard category. Confirm coverage in writing.
The practical failure mode is this: a manufacturer holds a genuine ISO 22716
certificate for skin care, you commission a novel balm-to-oil format or a
category the certificate never named, and the paperwork you were shown no longer
describes the work being done. That is not fraud — the certificate is
real — but it is a gap you own if you did not check. For white label it
almost never bites; for full contract manufacturing it is the first thing to
confirm.
Chuffy has spotted the gap before signing, for once.
Where is a certified manufacturer still the wrong fit?
Being straight about fit is the entire point of this site, so here is the
part that matters: a full set of certifications does not make a manufacturer
right for you, and Moe’s Group in particular is the wrong call in several real
situations. Its public certifications are ISO 22716 for cosmetics GMP, plus ISO
9001 and ISO 45001, and FDA facility registration — you can
view and download every certificate and check the accredited
ones yourself. What that list does not include tells you where to look
elsewhere. Verify every alternative’s current credentials, scope and MOQ on the
day you shortlist; these change, and we do not reprint figures that could be
stale (competitor details below checked 2026-09-08).
| If you need… | Why a certified US skincare CM like Moe’s Group can be wrong |
Look at instead (verify direct) |
|---|---|---|
| Organic certification from the manufacturer | Moe’s Group’s public certs are ISO 22716, ISO 9001, ISO 45001 and FDA registration — no USDA Organic, COSMOS or ECOCERT listed. If your channel or positioning needs the factory to hold an organic mark, this is a gap, not a quality issue. |
RainShadow Labs (St. Helens, OR) and Nutrix (Salt Lake City, UT) publicly list USDA Organic alongside ISO 22716 |
| Color cosmetics — foundation, lipstick, pressed powder | The certified ISO 22716 scope names skin care, hair care and oils. Color cosmetics fall outside it and need a manufacturer whose scope explicitly covers color. |
Lady Burd (New York, NY) and Cosmetic Solutions (Boca Raton, FL) list color-cosmetics capability |
| An EU-first launch | EU Regulation 1223/2009 requires a Responsible Person established in the EU. A California facility with no EU entity cannot be your RP — a structural gap, not a certification gap. |
An EU-based manufacturer, or a separate EU Responsible Person arrangement — confirm current status directly |
| A very small test run (under ~500 units) | Moe’s Group is not a sample-run or dropship operation. And note: “certified” means different things by scale — some low-MOQ shops hold ISO 22716, others are FDA-registered and GMP-compliant without a current third-party ISO certificate. |
Trilogy Laboratories (Fort Myers, FL) and other boutique labs built for ultra-low MOQs |
| Leaping Bunny (cruelty-free) tracing to the factory | Leaping Bunny is a supply-chain certification, not just a factory badge, and it is not listed on Moe’s Group’s public certifications page. If your cruelty-free claim must trace to the manufacturer, confirm the program status before signing. |
A manufacturer enrolled in the Leaping Bunny supply-chain program — verify against the program’s own directory |
Two honest caveats on the alternatives above: every competitor certification
claim comes from the manufacturer’s own marketing or third-party aggregators
checked in September 2026, not from an issuing body’s register — so treat
them as a starting point and verify the certificate number and scope yourself.
And do not print or repeat a competitor’s certificate number you have not
confirmed at source; a wrong number in either direction is a real
false-advertising exposure. For a fuller side-by-side of US options, see our
roundup of the
best
private label skincare manufacturers in 2026, and for the manufacturer’s
legal filing obligation as opposed to your due diligence, read
whether
cosmetic manufacturers need to register with the FDA.
Frequently asked questions
Which single credential should I ask for by name? ISO
22716, in full — “ISO 22716:2007” — with the certificate
number, the certified scope and whether it is accredited. It is the only one of
the three that is an audited, verifiable certificate for cosmetics.
Is “cGMP certified” a meaningful claim? On its
own, not really. cGMP is a regulatory expectation, and no one issues a cGMP
certificate for cosmetics. The credible version of the claim is an ISO 22716
certificate sitting behind it — ask for that. Many honest manufacturers use
the phrase loosely, so treat it as a prompt to ask for the underlying standard,
not as a red flag by itself.
Does FDA registration mean the products are approved by the
FDA? No. The FDA does not approve cosmetic products or the facilities
that make them. Registration under MoCRA is a filing that puts the facility on
record and produces an FEI number, renewed every two years. Any claim that a
cosmetic is approved by the FDA is a misstatement.
How do I check an accredited certificate myself? Confirm the
issuing body is part of the IAF chain, then look the certificate up at
iafcertsearch.org. Where the issuing body is not accredited through IAF, verify
the certificate number directly with that body’s own registry instead.
Does the manufacturer’s certificate certify my product? No.
ISO 22716 certifies that the facility follows consistent manufacturing
processes — it does not certify that any specific product is safe,
effective or compliant. Factory certification and product responsibility are
different things.
Sorting real credentials from decorative ones is most of the work of choosing
a factory well. If you have shortlisted a manufacturer and want to talk through
scope for your specific category, Moe’s Group takes enquiries through its
product inquiry form — and if the honest answer is that
your project fits one of the alternatives above better, a straight manufacturer
will tell you so.
looked up. The rest went in the bin. Chuffy has never felt so certified. He is
not certified — the factory is — but let him have this.