Contract manufacturing: what the brand and the factory each prepare

In contract manufacturing, the brand that acts as filer or registrant still submits the filing or registration in its own name and remains responsible for quality, safety and claims. The factory provides truthful licence, site and process information and produces according to the technical requirements on file. Handing the entire project to the factory is not the same as completing a compliant dossier.

Published 11 November 2026 · Updated 11 November 2026

How to divide the work

The Measures for the Administration of Cosmetics Registration and Filing require a domestic contract-manufacturing relationship to be confirmed through the information service platform. Imported products made by an overseas contractor need manufacturing-relationship documents or, where the parties belong to the same group, group-relationship and quality-assurance documents. The agreement should identify the product, the commissioning party, the manufacturer’s name and address, and the date of the engagement, along with other items required by the dossier rules.

What each side usually prepares

The brand typically supplies the intended name and claims, formula ownership or authorization to use the formula, label concepts, safety-assessment organization and efficacy evidence. The factory typically supplies the production licence, site address, process description, and support for sample making and factory-side quality records. Both sides must freeze the same formula before samples go to a laboratory.

Cautions

The filer or registrant must itself have a suitable quality-management system and adverse-reaction monitoring capacity. Those duties cannot be described as belonging only to the factory. If one side changes the fragrance, colour or process after testing has started, the reports may no longer match the file.

Questions we are often asked

Can the factory file in its own name for our brand?

Only if the factory is truly the filer or registrant and the label and legal responsibilities match that choice. Using the factory’s filing for a different brand name usually means a separate product identity.

Who talks to the laboratory?

Either party may ship samples, but the reports must describe the product that will be filed or registered. Jinshang coordinates partner laboratories so that the test plan matches the frozen formula and claims.