How to Choose a Skincare Manufacturer in Australia: 12 Questions to Ask
The right skincare manufacturer can show you its quality systems, test results and documents, make the quantity you can actually sell, and tell you in writing what its price includes. Ask these 12 questions before you order. We're an Australian skincare manufacturer; our own answers are at the end, but the questions work for any manufacturer.
Key facts
- Three types: white label (their formula, your label), private label (a formula developed for you) and contract or OEM (your formula, their production).
- Minimums can start as low as 10 units per product for white label (ours), and are often 1,000+ for a custom formula.
- Ask for evidence of GMP (ISO 22716), stability, preservative efficacy and micro testing, and an SDS, CoA and PIF per product.
- Cosmetics are regulated through AICIS, the ACCC and the Poisons Standard, and the TGA doesn't approve them, so "TGA approved" on a cosmetic is a red flag.
- Your brand is responsible for its final label and claims.
The three types of skincare manufacturer
| Type | Whose formula | Typical MOQ | Best for |
|---|---|---|---|
| White label | The manufacturer's tested formula | Can be as low as 10 units | Testing demand, a fast launch |
| Private label (ODM) | Developed for your brand | Around 1,000 units and up | Signature products |
| Contract (OEM) | Yours | Usually set by batch size | A proven formula that needs capacity |
Many brands start with white label, then move to a custom formula. See white label vs private label.
12 questions to ask a skincare manufacturer
1. What's your MOQ, per product and per size?
Why it matters: it sets how much cash you tie up in stock. A low headline MOQ can be per order, or exclude labelling.
Good answer: a number per product and packaging size, with what the price includes. See skincare MOQs explained.
2. Can I order samples first?
Why it matters: you can't judge texture or scent from a spec sheet.
Good answer: yes, full size and from the production formula. For custom work, lab samples you approve before production.
3. Do you operate to GMP, and what does that involve?
Why it matters: good manufacturing practice makes your tenth batch match your first and lets a problem be traced. ISO 22716 is the international GMP guideline for cosmetics.
Good answer: whether they're certified or operate to ISO 22716 principles, plus the systems behind it: written procedures, batch records, trained staff, raw material checks and retained samples. Read our introduction to GMP.
4. What testing has the formula had?
Why it matters: unstable formulas separate, and weak preservation lets microbes grow after opening.
Good answer: stability testing, preservative efficacy (challenge) testing and microbiological testing of each batch before release, with results they'll show you. See cosmetic preservatives.
5. Which documents do I get?
Why it matters: stockists and overseas markets ask for them.
Good answer: a Safety Data Sheet (SDS), a Certificate of Analysis (CoA) with batch results, and a Product Information File (PIF) for markets that need one. Ask for an example first.
6. Who owns the formula?
Why it matters: it decides whether you can move production, or sell your brand with its formulas.
Good answer: it's in writing. White label formulas usually stay with the manufacturer; custom work needs ownership set out in the agreement.
7. What's the lead time at my quantity?
Why it matters: launch dates and restocks depend on it.
Good answer: production time by order size, what can stretch it (packaging, artwork approval), and shipping quoted separately.
8. What does the price include, and when do I pay?
Why it matters: you can't compare unit prices when labels, packaging or testing are charged separately.
Good answer: a written breakdown (formula, packaging, labels, documents, GST, shipping), volume price breaks, and deposit and balance terms up front. See the cost to start a skincare line.
9. Do you help with labels, and do you check them?
Why it matters: reprints are expensive. The Consumer Goods (Cosmetics) Information Standard 2020 requires the ingredient list on the container, in descending order of volume or mass (or the 1% alternative), with colour additives last.
Good answer: the exact ingredient list, label templates, an artwork check before printing, and clarity that final compliance is yours. See our cosmetic labelling requirements checklist.
10. What packaging can you fill?
Why it matters: packaging affects price, minimums and label size.
Good answer: a range they already fill, label sizes for each, whether your own packaging can be filled, and minimums for printed boxes. See types of cosmetic packaging.
11. How long will stock last, and how do reorders work?
Why it matters: stock that expires before it sells is lost money.
Good answer: a stated shelf life, a period after opening (PAO), a batch code on every unit, and small reorders to the same approved specification.
12. Do you know the rules in the markets I'll sell in?
Why it matters: the wrong claim or ingredient can make a cosmetic a therapeutic good, which must be on the Australian Register of Therapeutic Goods (ARTG) before it's supplied or advertised, unless an exemption applies.
Good answer: they know cosmetics are regulated by the ACCC (safety, ingredient labelling, claims), AICIS (ingredients) and the Poisons Standard, flag risky claims early, and know extra steps for the EU, UK or US. Using an overseas maker? You must register with AICIS before importing cosmetics to sell, however few. See AICIS registration, cosmetic or therapeutic? and our regulatory guide by market.
Red flags
- "TGA approved", "TGA listed" or "TGA compliant" cosmetics. The ARTG is for therapeutic goods, not cosmetics, so these phrases mislead.
- No documents, or "you'll get them after you pay".
- No samples, or samples that aren't the production formula.
- Vague pricing that adds labels, packaging or testing later.
- Offers of therapeutic claims such as "treats acne" on a cosmetic.
- "Made in Australia" that isn't. The ACCC says this generally means the last substantial step happened here.
What to ask, good answers and red flags
| What to ask | Good answer | Red flag |
|---|---|---|
| MOQ | Per product and size | No clear number |
| Samples | Full size, production formula | No samples |
| GMP | ISO 22716, systems explained | No batch records |
| Testing | Stability, challenge, micro | "Not needed" |
| Documents | SDS, CoA, PIF | None |
| Formula ownership | In writing | Not mentioned |
| Lead time | By order size | No estimate |
| Price and payment | Written breakdown and terms | Extras added later |
| Labels | Templates and artwork check | No ingredient list supplied |
| Packaging | Range with label sizes | Untested with your formula |
| Shelf life and reorders | Shelf life, PAO, batch codes | No batch codes |
| Regulations | Knows ACCC, AICIS, Poisons Standard | "TGA approved cosmetics" |
How Cellular Cosmetics answers these
We make skincare in Molendinar on the Gold Coast. Our answers:
- MOQ: white label from 10 units per product and packaging size; custom formulas typically from 1,000; bulk 1 to 20 L with no MOQ.
- Samples: full size, no minimum.
- GMP and testing: we operate to ISO 22716 GMP principles. Formulas are stability and preservative efficacy tested, and every product has microbiological release testing. See certifications and testing.
- Documents: SDS, CoA and PIF for each product. SDS, CoA and Certificate of Conformity downloads are in our document library; PIFs on request.
- Formula ownership: we keep white label formulas; custom formula ownership is set out in your quote and manufacturing agreement.
- Lead times: 1 to 50 units, 1 to 4 business days; 50 to 200, 4 to 8; 200 to 500, 6 to 10; 500+, 12 or more.
- Price and payment: white label prices include formula, packaging, label printing and application, and GST. Volume pricing starts at 50 units. Orders over 5,000 units are typically 50% deposit, 50% before shipment.
- Labels and packaging: Canva templates, a label guide we check artwork against, and the batch code printed on the base of every bottle. Printed boxes come through our partner The Packaging People; we pack from $2 a unit.
- Shelf life: sell within 12 months of your order date; customers use within 12 months of opening (12M PAO).
- Regulations: everything we make is a cosmetic, so for a therapeutic good such as a primary sunscreen, we're not the right fit.
See real projects in our case studies.
Frequently asked questions
What's the difference between a white label and a private label manufacturer?
White label puts your label on the manufacturer's ready-made formula. Private label develops a formula for your brand, which takes longer and needs a larger first order.
What does GMP mean for a cosmetic manufacturer?
Good manufacturing practice is the set of systems that keeps every batch consistent and traceable. ISO 22716 is the international GMP guideline for cosmetics.
Can a manufacturer make my skincare "TGA approved"?
No. The TGA doesn't approve cosmetics. A product presented for a therapeutic use is a therapeutic good and must be on the ARTG before it's supplied, unless an exemption applies.
How many units do I need to start a skincare brand?
White label can start from about 10 units per product. A custom formula usually starts at around 1,000 units.
Who is responsible for my label being compliant?
Your brand, as the supplier. A good manufacturer helps, but the final label and claims are yours.
This article is general information, not legal advice.
Sources: Therapeutic Goods Administration, Determining if your product is a cosmetic or therapeutic good (updated 3 July 2026); ACCC Product Safety, Cosmetics ingredients labelling mandatory standard; AICIS, Personal care, skincare, make-up and other cosmetic products (updated 7 February 2025); ACCC, Country of origin claims.
Order samples | Custom formulation | Read the full launch guide
