Changing cosmetics manufacturers: How a structured transition works
Changing cosmetics manufacturers: How a structured transition works
12 min read
CEO & Founder at Labtree GmbH
Switching manufacturers sounds risky, and it is if the process is unstructured. A structured, five-step transition keeps the supply chain stable and reduces transition risks.
The topic is short and compact
Switching in 5 steps: takeover, regulatory compliance, parallel production, validation, controlled handover.
Parallel production avoids supply disruptions and enables iteration without delivery pressure.
Important factors with the new manufacturer: in-house laboratory expertise, integrated regulatory affairs, and scalability.
The first step is the complete transfer of all relevant data:
Ingredient lists and concentrations
Processes (mixing times, temperatures, sequences)
Stability data and skin compatibility studies
Existing regulatory documentation (PIF, CPNP, SDS)
Specifications for raw materials and packaging
In the case of incomplete documentation, the new manufacturer must analytically reverse-engineer the formulation, ingredient analysis, stability reassessment, process derivation. This extends the transfer phase, but is feasible given sufficient laboratory competence.
Step 1: Assumption of the formulation and documentation
The first step is the complete transfer of all relevant data:
Ingredient lists and concentrations
Processes (mixing times, temperatures, sequences)
Stability data and skin compatibility studies
Existing regulatory documentation (PIF, CPNP, SDS)
Specifications for raw materials and packaging
In the case of incomplete documentation, the new manufacturer must analytically reverse-engineer the formulation, ingredient analysis, stability reassessment, process derivation. This extends the transfer phase, but is feasible given sufficient laboratory competence.
Step 2: Regulatory Handover
PIF and CPNP notification must be updated to the new production site and, if applicable, new processes. Safety assessments are reviewed and renewed if necessary.
Ideally, these steps run in parallel with production preparation. With integrated development partners, regulatory preparation is part of the standard process, not purchased externally.
Step 3: Start of production in parallel with the existing delivery
The crucial point for risk minimization: test batches at the new manufacturer while the old one is still delivering. Three advantages:
No supply disruption in the market
Validation of the new production before the hard cut
Opportunity to iterate in case of anomalies without delivery pressure
The test batches are tested against the existing specification; sensory profile, stability, and performance must be comparable.
Step 4: Validation of the first batches
Before full delivery handover takes place, the first production batches from the new manufacturer must be validated:
Sensory comparability: Texture, smell, application identical to the existing production
Stability assessment: First data points from stressed stability
Quality control: Reproducibility over several batches
Packaging: Compatibility with the new production environment
Only after validation will the step-by-step scaling to full volume take place.
Step 5: Controlled delivery handover
The transition occurs gradually, not as a hard cut. Typical pattern:
First weeks: Stocks from the old manufacturer, new batches are produced as fallback
Middle phase: Parallel delivery, shares shift towards the new manufacturer
Complete takeover: Old manufacturer is phased out
Even after the handover, the first 6–12 months are closely monitored, regarding complaint rates, delivery reliability, and quality consistency.
In-depth sources: The legal basis for all cosmetic products marketed in the EU is the EU Cosmetics Regulation (EC) No. 1223/2009. In Germany, the health assessment of ingredients is the responsibility of the Federal Institute for Risk Assessment (BfR). Industry information and market data are published by the German Cosmetic, Toiletry, Perfumery and Detergent Association (IKW).
What to look for in a new manufacturer
Experience with takeovers: Structured methodology available?
In-house laboratory expertise: Reverse engineering of formulations possible in case of incomplete documentation?
Formulation basis as fallback: If 1:1 takeover is not possible, existing alternatives?
Integrated regulatory affairs: Part of the standard process, not purchased separately?
Scalability: From test batch to industrial production without interface disruption?
Related articles: Manufacturer change too late · Checking cosmetics manufacturers · Cosmetics manufacturers in Germany
A structured transition in five steps significantly reduces the risk compared to a hard-cut. The total duration of 3 to 6 months sounds long, but it is an investment in stability, much cheaper than a failed transition with delivery stops and regulatory gaps.
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FAQ
Does Labtree have its own laboratory?
Yes. Labtree has its own development expertise, including a laboratory. This means that formulations can not only be selected, but specifically developed, tested, and adjusted. Additionally, smaller test batches can be produced in-house in order to validate products early on in real conditions and safely transfer them to production.
How long does a change of manufacturer take?
Typically 3 to 6 months. In the case of incomplete documentation from the previous manufacturer, the transition phase may be extended because formulations must be analytically recreated.
What happens if the old manufacturer does not provide any data?
The new manufacturer must analytically reverse-engineer the formulation, ingredient analysis, stability reassessment, process derivation. Feasible with sufficient laboratory competence, but typically extends the phase by 4–8 weeks.
Can I continue to deliver during the transition?
Ideally yes, through parallel production. The old manufacturer continues to supply while the new one produces test batches. This avoids supply disruptions and allows for calm validation.
How much does a manufacturer change cost?
Project-dependent. Main items: buyout effort, regulatory updates, test batches, potentially reverse engineering. Usually manageable compared to the consequential costs of a poorly managed transition (supply stops, commercial damages).
How do I minimize the risk of a supply disruption?
Schedule parallel production, so the new manufacturer starts while the old one is still delivering. Define safety stocks. Communicate transparently with retailers about potential transition phases.
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