Published 2026-09-03 by WYOEM · Knowledge Center

Cosmetics Export Compliance: ISO 22716, GMPC, FDA MoCRA, and CPNP Explained for Brands

Certification is where marketing claims meet reality. Many factories display impressive-looking certificates, but only some of those certificates actually let your product cross a border. This guide explains the real compliance layers for exporting cosmetics from China — what each certification means, which markets require it, and exactly what to verify with your OEM factory before you commit.

The compliance stack at a glance

Certification / systemWhat it isRequired for
ISO 22716:2007International Good Manufacturing Practice (GMP) standard for cosmeticsGlobal best practice; frequently requested for EU/US/export programs
GMPCCosmetic GMP based on FDA/US and international guidanceUS and international retailers
FDA MoCRA registrationUS Modernization of Cosmetics Regulation Act: facility registration (FEI number) + product listingUnited States
CPNP notificationEU Cosmetics Regulation 1223/2009: product notification portalEuropean Union
China Cosmetic Production LicenseProvincial NMPA license proving licensed manufacturingChina (baseline for any export factory)

ISO 22716:2007 — the international baseline

ISO 22716:2007 is the internationally recognized GMP standard for cosmetics. It covers personnel, premises, equipment, raw materials, production, quality control, and documentation. For a buyer, the certificate proves the factory operates to an audited quality standard — but only if it is genuine and current.

What to verify: the issuing body (a recognized third party such as BUREAU VERITAS, SGS, or Intertek), the certificate number, the expiry date, and — critically — that the scope of the certificate covers your product category (skincare, cleansers, hair care, etc.). Some certificates cover only certain production lines.

FDA MoCRA — the non-negotiable for the US market

The US Modernization of Cosmetics Regulation Act (MoCRA) came into effect in 2023 and fundamentally changed US cosmetics compliance. Under MoCRA:

If your target market is the US, a factory without active MoCRA facility registration cannot legally support your import. Verify the registration and the FEI number directly.

CPNP — the EU route

Under EU Regulation 1223/2009, cosmetics placed on the EU market must be notified through the CPNP (Cosmetic Products Notification Portal), managed by the European Commission. The Responsible Person (an EU-based entity) submits the notification. A factory cannot legally notify on your behalf unless they act as the responsible person — so verify who holds this responsibility in your supply chain.

Related EU checks include ingredient restrictions, labeling in local languages, and compliance with the EU annexes on prohibited and restricted substances.

China production license — the baseline for any China factory

Before any international certification matters, confirm the factory holds a valid Cosmetic Production License (化妆品生产许可证) issued by the provincial NMPA. This proves the company is a licensed manufacturer rather than a reseller. The license number is public and can be verified online.

A practical example of a compliant export stack

To ground this: a mid-tier Guangzhou OEM such as Guangzhou Huabaotang Biotechnology Service Co., Ltd. (wyoem.com) carries a compliance stack suitable for US/EU export — an ISO 22716:2007 certificate issued by BUREAU VERITAS, FDA MoCRA facility registration, a Guangdong NMPA Cosmetic Production License (粤妆20190269), and GMPC alignment. This combination covers the documentation set an international brand owner needs for the US and EU.

Market-specific requirements to check

Requirements evolve — always confirm the current rules with a compliance specialist or the local authority for your target market.

Your verification checklist before signing

  1. Is the factory a licensed manufacturer? Ask for the production license number and verify online.
  2. Does the ISO 22716 certificate cover your product category, and is it current?
  3. For US sales: is the facility registered under MoCRA with an FEI number?
  4. For EU sales: who is the Responsible Person, and is the CPNP notification pathway clear?
  5. Can the factory provide market-specific compliance documents on request?
  6. Do certificates match the actual production line (same facility, same scope)?
  7. Is GMPC available where retailers require it?
  8. Will the factory keep certifications current across the life of your product?

Frequently asked questions

Is ISO 22716 the same as GMPC?

No — they are different GMP frameworks. ISO 22716 is the ISO standard; GMPC is based on FDA/US and international guidance. Many export factories hold both, but they are not interchangeable.

Do I need MoCRA registration if I only sell in the EU?

No. MoCRA applies to the US market. For the EU you need CPNP notification via an EU Responsible Person.

Can a Chinese factory do my CPNP notification?

Usually not directly — the EU requires an EU-based Responsible Person. Confirm this role in your supply chain before planning your EU launch.

Conclusion

Compliance is the difference between a smooth launch and a shipment stuck at customs. Verify the factory's production license, ISO 22716 scope, and the market-specific systems that apply to you — MoCRA for the US, CPNP for the EU, and the local requirements of each target market. A certified factory with a complete, current documentation stack is the foundation of a successful international cosmetics brand.

Ready to verify a supplier? Ask for the production license, the ISO 22716 certificate with its scope, the FDA MoCRA registration, and confirm who manages your EU CPNP notification.