ISO 22716 or BRCGS Consumer Products: Which Certification Does a Cosmetics Manufacturer Need?

By Robert Low, Director, Lead Auditor & BRCGS Approved Trainer

If you manufacture cosmetics, sooner or later you face this question, usually prompted by a customer: we hold ISO 22716, do we also need BRCGS Consumer Products? Or the reverse. Having built systems for both, audited against both and trained both, here is how I answer it.

They Answer Different Questions

ISO 22716 is the cosmetics GMP standard. It defines good manufacturing practice for cosmetic products, premises, equipment, personnel, production, quality control, and it is the standard regulators lean on: cosmetics regulation in the EU, UK and much of the world requires manufacture in accordance with GMP, with 22716 as the recognised benchmark. It is certificated on a pass or fail basis: you hold it or you do not.

BRCGS Consumer Products is a retailer-facing certification standard. It goes beyond GMP into the full product safety and quality management system, risk assessment methodology, supplier approval, traceability testing, incident management, and wraps it in an audit protocol with grades, audit options and a public directory. It exists because retailers and brand owners wanted one recognised, benchmarked answer to the question: can we trust this site? With Issue 5 arriving, that system expectation is deepening, as my full Issue 5 breakdown sets out.

So Which Do You Need?

Follow your customers and your markets. Selling to retailers, especially UK and European private label, and BRCGS is increasingly the ticket to the game. Manufacturing for brand owners who audit you themselves, and 22716 may satisfy them while keeping regulators content. But for a growing cosmetics manufacturer the honest answer is usually both, and the good news is they nest neatly: 22716 gives you the GMP core, BRCGS builds the management system and audit protocol around it. I have mapped the overlap in detail in my piece on how 22716 maps to BRCGS enhanced hygiene expectations, and my ISO 22716 section by section series covers the GMP side clause by clause.

The Efficient Route

Build once, certify twice. A properly structured system covers both standards with one set of documents, one internal audit programme and one improvement cycle, rather than two parallel worlds. That is exactly how I build them: my ISO 22716 GMP-MS document packs give sites the GMP core off the shelf, and my remote consultancy extends the same system to BRCGS readiness, gap analysis included. See my solutions page or use the buttons below, and with Issue 5 audits starting April 2027, cosmetics sites holding only 22716 have a decision to make this year.