The topic is short and compact
The vertical integration is decisive: whether a provider develops formulations in its own laboratory, manufactures them itself, or passes orders on to third parties.
A contract manufacturer is only sufficient if the formulation is documented, tested in the target packaging, and transferable to the facility's equipment.
Under Regulation (EC) No 1223/2009, the brand is generally considered the manufacturer in contract manufacturing; it remains the responsible person unless it designates a mandate.
The time until the first batch is usually determined by the initial formulation, sampling rounds, choice of packaging materials, and preservative challenge test, rather than the kettle capacity.
There is no manufacturing authorization for cosmetics under Section 13 of the German Medicinal Products Act (AMG); pharmaceutical contract manufacturing only becomes relevant for medicinal products or borderline cases.
So läuft die Entwicklung bei Labtree
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Konzeptionierung
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Bemusterung – Standardmuster in 24 h
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Individualisierung
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Prototyping
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Produktion
White Label 2–3 Monate · Private Label 3–6 Monate · Produktion ab 1.000 Stück
What types of cosmetics manufacturers are there in Germany?
The term cosmetics manufacturer is used for very different business models. For the selection, company size is less decisive than the depth of value creation: whether a provider develops formulations, produces samples in its own laboratory, handles filling in-house, or merely passes on orders.
Provider type | Formulation created | Manufacturing | Suitable if |
|---|---|---|---|
Intermediary platform | at the affiliated facility | at the affiliated facility | You are looking for a market overview of standard products |
Formulation laboratory | in the service provider's laboratory | at a separate manufacturer | You want your own formulation and already have a manufacturer |
Toll processor | at the brand | at the toll processor | the formulation is complete, tested, and transferable |
Format specialist | predominantly from their own range | in industrial series | a single format is required in large quantities |
Manufacturer with in-house laboratory | in their own laboratory | in their own production | development, sampling, and production should run together |
Many companies are hybrid models. A contract manufacturer can offer a catalog of ready-made formulations in addition to toll processing, and a laboratory can fill small batches itself. Therefore, do not ask for their self-description, but rather which steps take place in-house and which go to third parties.
What is the difference between an intermediary platform and a manufacturer with its own laboratory?
An intermediary platform bundles inquiries and forwards them to affiliated companies. It shortens the search, but does not change who develops the formulation, produces the sample, and releases the batch. These steps remain with the company behind it, which you often only get to know directly late in the process or not at all.
For a development project, what matters most is what happens when something does not work. If a sample fails during stability testing, an emulsion separates in the final container, or a foundation shade misses the target tone, someone with laboratory access must modify the formulation and re-sample. With a manufacturer who has their own laboratory, this happens without handovers between companies. In a brokered project, the same correction involves additional coordination.
Clarify before commissioning:
With whom are you entering into the manufacturing contract, and who is liable for the quality of the batch?
Where is the laboratory sample produced, and is it the same formulation that will later go into the production vessel?
Who modifies the formulation if test results or filling performance require it?
Who receives the formulation documentation, and under what conditions?
When is a contract manufacturer sufficient, and when does it require in-house formulation development?
A contract manufacturer is sufficient if your formulation is fully documented, tested in the primary packaging, and transferable to the facility's equipment. This includes the formulation with INCI designations and raw material specifications, manufacturing instructions with temperatures, mixing times, and phase sequence, as well as the test results on which the safety report is based. If any of these elements is missing, development work shifts to production, where it becomes more expensive.
In-house formulation development at the manufacturer makes sense if any of the following initial situations apply:
Benchmark product: A market product is to be recreated or improved in texture, coverage, or sensory profile.
Color range in make-up: Skin tints, concealers, or blushes in several shades require pigment dispersion, shade matching, and batch consistency across the entire range.
Hot-poured formats: For sticks, pouring temperature and cooling profile determine whether the mass breaks in the casing, sweats, or shows air bubbles.
formulation from a laboratory without production relevance: An emulsion that is stable in a beaker does not automatically behave the same way under different shear forces and different heating and cooling times in a vessel.
How an existing formulation can be transferred and what documentation the manufacturer needs for this is described in the article Cosmetics based on your own formulation.
Who is considered a manufacturer under the Cosmetics Regulation?
Not necessarily the company that mixes and fills. According to Article 2(1)(d) of Regulation (EC) No 1223/2009, a manufacturer is any natural or legal person who manufactures a cosmetic product or has such a product designed or manufactured, and markets that cosmetic product under his name or trademark. In contract manufacturing, this is usually the brand. For a product manufactured in the EU, this manufacturer is the responsible person pursuant to Article 4(3). They can delegate the role by written mandate to a person established within the EU who accepts the mandate in writing.
Regardless of the type of provider, the same obligations remain with the responsible person:
Good manufacturing practice: According to Article 8(1), manufacturing must comply with good manufacturing practice. If it complies with the harmonized standard ISO 22716, compliance is presumed under Article 8(2); the standard is neither mandatory nor sole proof.
Product information file: According to Article 11(1), it is kept for ten years from the placing on the market of the last batch.
Notification: Prior to placing on the market, the responsible person notifies the product according to Article 13(1) via the free CPNP notification portal of the European Commission.
In Germany, there is no official authorization for cosmetic products prior to market access. According to information from the Federal Office of Consumer Protection and Food Safety, the surveillance authorities of the federal states monitor manufacturers and importers, take samples, and test products on the market. How these obligations are handled in practice is shown in the article on the EU Cosmetics Regulation with CPNP notification and product information file.
Does a cosmetics manufacturer need a pharmaceutical manufacturing authorization?
No, as long as the product is a cosmetic product. The licensing requirement pursuant to Section 13 (1) of the German Medicines Act applies to the commercial manufacture of medicinal products, certain active ingredients, and substances of human origin for the manufacture of medicinal products. For cosmetics, Regulation (EC) No 1223/2009 requires good manufacturing practice, but no official manufacturing authorization.
Pharmaceutical contract manufacturing only becomes relevant if your product crosses the line into being a medicinal product, for example because it is advertised for the treatment or prevention of a disease. The European Commission provides guidance on such borderline cases between cosmetics and other product categories and emphasizes that classification is carried out on a case-by-case basis. For your choice of manufacturer, this means:
Define the intended purpose and planned advertising claims before comparing providers.
A manufacturing authorization for medicinal products proves compliance with a different legal framework; for a purely cosmetic product, it is not a requirement and, on its own, not proof of quality.
For cosmetics, what counts is applied good manufacturing practice, for example in accordance with ISO 22716, documented testing, and experience with the product category.
What determines the lead time for the first production batch?
A cosmetics manufacturer's time-to-market generally depends less on its capacity than on the formulation's starting point and the sequence of testing. For the safety report, Annex I Part A of Regulation (EC) No 1223/2009 requires, among other things, information on stability under reasonably foreseeable storage conditions, the results of the preservation challenge test, and the relevant characteristics of the packaging material. These data only emerge once the formulation and packaging materials have been finalized.
The Key Time Drivers
Starting point: Adapting an already tested formulation is usually faster than developing a new one from scratch, as stability and skin compatibility data are often partially available.
Sampling rounds: Each cycle of sample, feedback, and adjustment extends the project, often by several weeks. Physical samples early in the project shorten these loops because texture and shade can be evaluated directly on the product rather than on a data sheet.
Packaging materials: Stability and compatibility are tested in the final container. Changing packaging materials after testing has started generally requires these tests to be repeated.
Preservation: The challenge test, usually conducted in accordance with ISO 11930, takes several weeks; if it fails, formulation changes and a retest will be required.
Handovers: If the laboratory and manufacturing are handled by different companies, scaling up to production scale is added as a separate step.
Realistic timelines by product type and the factors behind them are described in the article Cosmetics Development: Realistic Timelines.
Compare providers based on evidence, not self-descriptions. In practice, these points separate viable offers from risky ones:
In-house laboratory work: Are samples produced in an in-house laboratory and adjusted by the same people who hand over the formulation to production?
Samples before budget release: Do you receive a physical sample before you commit to development costs or packaging materials?
Test data in final packaging: Are stability and preservative challenge test results available for the planned packaging, or only for a laboratory bottle?
Formulation rights: Are you adapting an off-the-shelf manufacturer formulation that remains with the manufacturer (white label), or are you developing from scratch (private label), and what rights or exclusivity are transferred to you contractually?
Minimum quantities: Is the minimum order quantity specified per product, shade, and fill size, including the minimum quantities of packaging material suppliers?
Repeat production: How does the manufacturer ensure batch-to-batch consistency for reorders, especially for color ranges?
The questions for the initial meeting are compiled in detail in the article Ten questions to ask a cosmetic contract manufacturer; what proof GMP and ISO certificates actually provide is explained in the article on Certifications for cosmetic manufacturers.
Labtree is a B2B cosmetics developer and cosmetics manufacturer from Hamburg with its own laboratory and production capacities in Germany. Formulation development, in-house laboratory work, sampling, manufacturability testing, and cosmetics production are all under one responsibility: concepts become laboratory samples, manufacturable formulations, and finished cosmetic products. The focus is on makeup with complexion products, concealer, blush, mascara, and stick formats, followed by skincare such as creams, serums, and cleansers.
White Label: Tested Labtree formulations are adapted for the brand; usually ready for delivery in 2 to 3 months with standard packaging. The formulation remains the property of Labtree.
Private Label: New development according to your requirements, typically 3 to 6 months to market readiness. Formulation rights or exclusivity can be contractually transferred.
Samples: Samples of pre-qualified formulations usually leave the sample warehouse within 24 hours.
Minimum Order Quantity: Usually 1,500 units per product, depending on product type, filling size, and packaging.
The page Have cosmetics developed describes the process from conceptualization to sampling, customization, and prototyping through to production.
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FAQ
Do cosmetics manufacturers in Germany require official approval?
No. Cosmetic products in Germany are neither officially approved nor examined by authorities prior to market access. Responsibility for safety and legal compliance lies with the designated responsible person; the supervisory authorities of the federal states inspect companies and products on a spot-check basis.
Who owns the formulation if the manufacturer develops it?
This is governed by the contract. With white label, the formulation generally remains with the manufacturer, while with private label, formulation rights or exclusivity can be transferred to the brand. How you can safeguard this is covered in the Labtree article Confidentiality with the contract manufacturer: NDA and formulation ownership.
Is ISO 22716 certification mandatory for cosmetics manufacturers?
No. Regulation (EC) No 1223/2009 requires good manufacturing practice; compliance is presumed for those who manufacture in accordance with ISO 22716. A certificate indicates that processes are actively implemented, but it is no substitute for reviewing test data and documentation.
Can the manufacturer take on the role of the responsible person?
Yes, if the brand designates them through a written mandate and they accept the mandate in writing. They then maintain the product information file and handle the notification. The division of tasks should be set out in a contract before the first batch is placed on the market.
What are the minimum order quantities required by cosmetics manufacturers in Germany?
The minimum order quantity is determined by the smallest practical vessel batch size, the cleaning cycles between batches, and the minimum purchase quantities of packaging material suppliers. At Labtree, this is typically 1,500 units per product, depending on the product type, filling volume, and packaging. The individual drivers are explained in detail in the article MOQ in Cosmetics.
Is one CPNP notification enough to sell in all EU countries?
CPNP notification is carried out once per product with the European Commission and applies to the entire EU market. However, the language required for mandatory packaging information depends on the laws of the member state where the product is sold. Therefore, always check the language requirements of each target market before printing the artwork.
How quickly can a manufacturer deliver initial samples?
That depends on whether an existing formulation is being sampled or newly developed. Samples of pre-qualified Labtree formulations usually leave the sample warehouse within 24 hours, while samples of a new development follow after the initial laboratory rounds. Ask every supplier under what conditions their sample lead time applies.
