Cosmetic Co-Packer: MoCRA, Testing and Quotes Compared

A cosmetic co-packer, more often called a contract manufacturer, makes and fills your lotion, butter, balm, scrub or soap to your formula, or to one of its own under your label. Since the Modernization of Cosmetics Regulation Act of 2022, MoCRA, a facility that manufactures cosmetics registers with FDA, and a contract manufacturer registers once for all its clients; the brand lists its products. Small businesses are exempt from some of that, with exceptions. What decides whether a skincare brand needs a co-packer, though, is the product: a water-free body butter is quick to make, an emulsion needs preservative testing and a filling line. In the example below, a skincare maker selling 1,000 jars of body butter a month pays $4.74 a jar making it itself, $5.36 with a small contract manufacturer, and $4.14 with a larger one. Below is what MoCRA asks, testing, what the manufacturer needs, three quotes, and a free calculator.

The short version

• Under MoCRA, a facility that manufactures or processes cosmetics registers with FDA and renews every two years.
• A contract manufacturer needs one registration for all the brands it makes for.
• The brand, the responsible person on the label, lists its products.
• Businesses under $1,000,000 a year in US cosmetic sales are exempt from the registration and GMP rules, unless they make certain products, such as eye-area or injected ones.
• Emulsions with water need preservative and stability testing before they sell; water-free products often need less.
• Compare quotes on the cost of a good unit, not the fee; for simple products, your own kitchen may win.
• TaroStack keeps track of your ingredients and jars at the manufacturer, by lot, as a site of its own. More below.

What MoCRA asks

A facility that first engages in manufacturing or processing cosmetics for distribution in the US registers with FDA within 60 days and renews every two years; a facility that makes cosmetics for other brands needs only one registration, which it or any of its brands can submit (21 U.S.C. 364c). The same section has each brand, the responsible person, list its products. Small businesses, with average US cosmetic sales under $1,000,000 a year over the past three years, adjusted for inflation, are exempt from the registration and good manufacturing practice sections, except for those making products that regularly touch the eye's mucous membrane, are injected, are meant for internal use, or alter appearance for more than 24 hours (21 U.S.C. 364h). A small brand using a larger contract manufacturer may be exempt itself while its manufacturer is not. This is general information, not legal advice. What MoCRA asks of small brands in more detail is in MoCRA small business.

Testing

Anything with water in it, lotions, creams, many scrubs, can grow mold and bacteria, so it needs a preservative system and a test showing it works, and a stability test showing it holds up over its shelf life. A contract manufacturer will ask whether your formula has been tested, and may run the tests itself at your cost. Water-free products like whipped body butter and balms often need less, though they still need a shelf life you can stand behind. How a skincare line is planned around that is in lotion business plan.

What a cosmetic contract manufacturer will ask you for

• The formula by weight, each ingredient's INCI name and supplier, or a request to use one of theirs.
• Test results: preservative efficacy and stability, or a budget for them.
• Specs: fill weight, viscosity or texture, scent, color, and the container.
• Labels with the ingredient list in order, your name and address, and a contact for reactions.
• A forecast, a deposit and a first run you sign off on.

What goes on a cosmetic label is in cosmetic labeling requirements.

Three quotes compared

Hoʻola Botanicals, a made-up skincare maker in Kailua, Oʻahu, I use in these examples, sells about 1,000 four-ounce jars of whipped body butter a month:

Whipped body butter takes Hoʻola about three minutes a jar to make, so its own labor is a dollar, and the small contract manufacturer costs 61 cents a jar more. For this product, the kitchen wins until the volume is big enough for the larger manufacturer, which saves 60 cents a jar but asks for five months of sales up front, $20,100. The picture changes for Hoʻola's lotion: an emulsion that needs testing, homogenizing and a pump filler is where a contract manufacturer earns its fee. How a cosmetic batch is recorded either way is in cosmetic batch record template.

Get the calculator

Download the cosmetic co-packer quote calculator. One column for each quote and one for making it yourself: type the run you'd order, the minimum, the loss, the setup, the fee or your labor, ingredients, packaging, freight and storage, and the run's cost, the months it takes to sell at your sales a month, the storage while it sells, the cost of each good unit and the cash out before it sells fill in. It's an ordinary Excel file with no macros, and it works in Google Sheets, LibreOffice and Numbers.

Where this stops working

Body butter made in your own kitchen, lotion at a contract manufacturer, soap curing on your racks, and jars, pumps and labels in two places. A spreadsheet can't say how many lotion bottles are at the manufacturer, which batch of shea went into a jar a customer reacted to, or when to order the next pumps.

How TaroStack does it

TaroStack keeps track of your ingredients and jars at the manufacturer, by lot, as a site of its own.

The manufacturer as a site. The contract manufacturer's premises can be a site, so the butters, oils and containers you send are a transfer, shown in transit until they arrive, and the finished units there are counted as yours. More than one site is on Standard at $99 a month.

Batches and lots. Each run is a batch with a lot that records the ingredient lots it used, so a customer's reaction leads back to the shea and the scent oil in that jar, and a recall report shows which customers got the lot.

Containers on time. Jars, pumps and labels come up on the reorder list in days of cover, with each supplier's lead time and minimum. How stock across places works is in multi-location inventory.

Sites, transfers, batches and lots are on Standard at $99 a month for more than one site. The first 30 days are free, with no credit card. If you'd like a hand setting up, ask, and we'll do it with you.

Questions people also ask

Does a cosmetic co-packer need to register with the FDA?

Under MoCRA, a facility that manufactures cosmetics registers with FDA and renews every two years, unless it's a small business that qualifies for the exemption. A contract manufacturer needs one registration for all its clients.

Do I need to list my products if a co-packer makes them?

The brand, as the responsible person, lists its products, unless it's a small business that qualifies for the exemption.

What is the minimum order for a cosmetic contract manufacturer?

In the example, 1,000 jars at a small manufacturer and 5,000 at a larger one.

Is it cheaper to make skincare yourself?

For quick, water-free products like body butter, often yes until the volume is large. In the example, $4.74 a jar in-house against $5.36 at a small contract manufacturer.