Start 2026 the right way with Best Practices for Cosmetic Products
The entry into force of Regulation (EC) No. 1223/2009, also known as the Cosmetics Regulation, introduced the requirement for compliance with good practices—i.e., guidelines that regulate certain aspects of the life cycle of a cosmetic product. These are known as Good Manufacturing Practices (GMP).
But what exactly do they involve? And how can they be effectively implemented in your organization? In this article, we provide a comprehensive overview to help you better understand Good Manufacturing Practices as they apply to the cosmetics industry.
Good manufacturing practices: what are they?
GMPs are guidelines that guarantee the quality and safety of cosmetic products.
Why are GMPs important?
While the Morhange talc scandal was the catalyst for the first regulations on cosmetic products in France—and subsequently in Europe—it primarily highlighted that the manufacturing process of a cosmetic product is a critical stage.
The Cosmetics Regulation reinforces this point, as Article 8 clearly states that “the manufacture of cosmetic products shall comply with good manufacturing practices […].”
In practical terms, this means organizations must implement strict procedures to ensure product quality at every stage of production.
Cosmetic GMPs (Good Manufacturing Practices) play a vital role in ensuring consumer safety and minimizing risks. They help to:
- Reduce the risk of contamination throughout the manufacturing process
- Reduce human and technical errors
- Provide quality assurance by controlling organizational, technical, and administrative factors
- Provide complete traceability to identify the causes of non-compliance and implement corrective actions.
By following these guidelines, manufacturers strengthen their ability to deliver safe and compliant products while ensuring consumer protection. GMPs are therefore not just a requirement: they are a guarantee of quality for the entire chain.
How can good manufacturing practices be implemented?
The implementation of good manufacturing practices relies on the adoption of a management system that ensures their proper application at every stage of the process.
The Regulation does not explicitly cite any reference text. Still, it specifies that GMPs are presumed to be complied with if manufacturing follows harmonized standards, i.e., mainly ISO 22716, which could also be called the GMP standard, since it provides guidelines for GMPs for cosmetic products.
An international standard developed by consensus with the help of experts from the cosmetics industry, ISO 22 716, is not the only ISO standard for cosmetics, but it is the best known. It covers not only the manufacture of cosmetics, but also other stages of production: control, storage, and shipping. It is a quality reference standard that ensures control of the human, technical, and administrative factors that can impact the quality of the final product. It thus makes it possible to obtain a product that meets the defined characteristics. It’s 17 chapters cover the various aspects of the supply chain, which are:
- Personnel: GMP training, individual responsibilities, organization, and hygiene.
- Equipment and premises: design of premises, cleaning, maintenance, and calibration of equipment.
- Production: management of raw materials, manufacturing and packaging operations, waste, storage, and shipping.
- Quality control (see box).
- Quality system: compliant documentation, internal audits, management of changes, deviations, complaints, and recalls.
It’s essential to train staff, document each procedure, and implement a system that ensures traceability and follow-up of actions. Compliance with best practices is not limited to technical requirements: it is part of a quality and safety-oriented corporate culture.
Focus: quality control in cosmetics
Quality control for cosmetic products begins even before manufacturing. Sample management is essential to obtain representative results. Once the specifications for the finished product have been established (pH, viscosity, physical and chemical characteristics, etc.), they will serve as a reference for control analyses during production and the product’s marketing. It is also essential to establish a process for managing products that do not meet specifications and to investigate the causes. Quality control also determines the conditions for product release: what conditions must it meet to continue its life cycle? All these steps aim to guarantee the consumer a product of consistent quality.
Remember that the person in charge must certify in each Product Information File (PIF) that GMP is being followed. They must also ensure that any subcontractors follow the same guidelines. Although the ISO 22716 GMP standard includes the concept of internal auditing, it is preferable to have GMP compliance certified by an approved and recognized service provider. This avoids unpleasant surprises during any inspections by the regulatory authorities (ANSM in France, which devotes around a third of its annual inspection campaign to GMP). It is also a guarantee of quality for commercial and export partners.
What are the risks if GMPs are not applied?
Failure to comply with GMPs exposes the company to serious consequences, both in terms of regulations and reputation.
The absence of rigorous procedures (poorly maintained premises and equipment, untrained staff) increases the risk of contamination by undesirable agents, thereby compromising product safety.
It can also cause quality issues, such as formulation errors and production variations, which can lead to regulatory non-compliance and penalties from regulatory authorities.
For consumers, these failures can cause adverse effects ranging from mild irritation to severe allergic reactions or infections. The use of non-compliant products can therefore have a direct impact on health, particularly for sensitive populations such as children, the elderly, or those with fragile skin.
Authorities may impose corrective measures such as the withdrawal of the products concerned. Mass recalls are usually accompanied by negative media coverage and potential financial penalties.
How can teams be trained in GMP?
The proper application of GMP depends heavily on people (hygiene, compliance with procedures, etc.). Writing guides on the various processes is not enough. Employees must understand what to do, why it is necessary, and how to do it effectively.
All those involved must be made aware of their roles and responsibilities in ensuring product safety and limiting the risk of non-compliance. They must understand the requirements of good manufacturing practices, internal procedures, and the consequences of potential deviations.
To facilitate this learning process, you can:
- Set up training modules tailored to different jobs and levels of responsibility.
- Integrate flexible solutions such as distance learning to reach all teams where possible.
- Offer regular sessions that include practical exercises and GMP audit simulations to reinforce what has been learned.
Beyond knowledge transfer, the success of the training project also depends on staff commitment. The goal is for everyone to feel responsible for the safety of the products sold.
Finally, using a suitable cosmetic PLM tool facilitates the implementation and monitoring of GMPs by centralizing documentation, supporting teams in their actions, generating alerts, ensuring traceability, and more. These are all assets that guarantee best practices daily.
To go further: Good Laboratory Practices (GLP)
Unlike GMP, Good Laboratory Practices (GLP) are not based on a standard, but on regulatory texts (for cosmetics in France: the Public Health Code and the decree of August 10, 2004, referring to it). However, in detail, they also involve various standards. They are applied in many areas, such as medicines, tattoo products, food, the environment, and other consumer goods. For cosmetic products, Regulation (EC) No. 1223/2009 requires that non-clinical safety studies necessary for the safety assessment of a product comply with GLP (or other recognized equivalent standards). The international harmonization of GLP ensures the recognition of GLP-compliant studies in different countries.
As with GMP, the objective of GLP is to establish a quality framework for the organization and operation of laboratories (or “test facilities” for the ANSM) conducting non-clinical safety tests. For cosmetic products, this concerns all tests required to ensure product safety for consumers, excluding human subjects: toxicology tests, tolerance tests, microbiological analy, instrumental tests, etc. The objective of GLP is to ensure the quality, authenticity, reproducibility, and integrity of data obtained for regulatory purposes.
As with GMP, GLP governs all aspects of non-clinical studies: personnel, facilities, procedures, study protocols, documentation, etc. The 5 M method summarizes these principles:
- Raw materials (identification, control, management).
- Equipment (identification, calibration, maintenance, operating procedures).
- Method (detail, validation, verification, availability).
- Personnel (training, qualifications).
- Environment (environment and infrastructure).
A laboratory wishing to implement GLP can follow two procedures:
- The GLP compliance verification procedure: in France, this verification is carried out by the ANSM for cosmetic products. If the verification is positive, the laboratory is certified.
- The accreditation procedure: this is the responsibility of the Cofrac (French Accreditation Committee). Accreditation considers technical competence for certain types of analysis.
Conclusion
Whether they concern manufacturing or laboratory studies, Good Manufacturing Practices (GMP) and Good Laboratory Practices (GLP) are pillars of cosmetic product quality in Europe. They ensure the traceability necessary to control a product’s life cycle to satisfy the fundamental principle of European cosmetic regulations: to market products that are safe for consumer health.
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