Manufacturing Spray Cosmetics in Compliance with ISO 22716/2017
Manufacturing a line of spray cosmetics in compliance with ISO 22716/2017 is feasible without investing in your own plant: simply entrust production to a manufacturer already operating under these Good Manufacturing Practices (GMP). The process covers custom formulation, filling in aluminum or tinplate containers, quality control at every stage, and traceable documentation from start to finish.
What Does ISO 22716/2017 Require from a Cosmetics Manufacturer?
ISO 22716 is the international standard for Good Manufacturing Practices for cosmetic products. It regulates four fundamental areas: personnel, facilities, equipment, and production, as well as documentation and internal audit systems.
Regarding personnel, the standard requires that all operators involved in manufacturing have specific GMP training and that their responsibilities are set out in writing. In facilities, production, quality control, and storage areas must be physically separated and have documented cleaning and disinfection systems to prevent cross-contamination.
The production section is the most demanding for a cosmetic aerosol: each batch must be manufactured according to written instructions, with weight controls, leak verification, and records for every parameter. Managing deviations, complaints, and product recalls is also part of the scope of the standard.
💡 Technical criterion: before starting a cosmetic contract manufacturing project, request the manufacturer's current ISO 22716 certificate and check that its scope explicitly includes aerosols and not just liquid or cream formats. The scope of the certificate is as relevant as having it.
The European Legal Framework for Marketing Spray Cosmetics
ISO 22716/2017 is the reference technical standard, but the legal obligation in Europe comes from Regulation (EC) 1223/2009 on cosmetic products. This regulation requires designating a responsible person established in the European Union, notifying each product on the Cosmetic Products Notification Portal (CPNP), and preparing a Product Information File (PIF) that includes a safety assessment signed by a qualified toxicologist.
The relationship between both instruments is direct: a manufacturer with an active ISO 22716 certification considerably facilitates the preparation of the PIF, because the batch traceability, analytical controls, and process documentation required by the standard are exactly the records the responsible person needs to support the safety assessment before the authorities.
The Stages of the Cosmetic Aerosol Manufacturing Process
A cosmetic aerosol in spray format goes through a sequence of operations that ISO 22716/2017 regulates in its entirety:
| Stage | Operation | Key GMP Control |
|---|---|---|
| Formulation | Mixing of active ingredients, preservatives, and excipients according to approved technical data sheet | Review of raw materials, supplier certificates of analysis |
| Filling | Loading the product into the empty container (aluminum or tinplate) | Gravimetric dosing, net weight record per batch |
| Sealing | Crimping the valve to create a hermetic seal | Verification of torque and seal integrity |
| Propellant | Injection of the propellant through the valve at controlled pressure | Internal pressure and final weight control |
| Verification | Hot water bath at 50 °C for leak detection | 100% of units tested, incident log |
| Labeling | Application of labeling in accordance with Regulation 1223/2009 | Verification of mandatory mentions (INCI, expiration date, responsible person) |
Each operation generates a batch record that remains in the manufacturer's documentation system and forms part of the file that the responsible person must keep for at least ten years after the last marketing date.
What Are the Advantages of Contract Manufacturing Over Setting Up Your Own Plant?
Contract manufacturing with a certified manufacturer provides the client with three specific advantages that a self-owned plant cannot replicate in the short term.
The first is immediate certification: the client relies on the manufacturer's already audited ISO 22716/2017, without needing to subject their own infrastructure to external audits. The second is scalable production capacity: unlike having your own filling line, contract manufacturing allows starting with small volumes and increasing them without additional investment in machinery. The third is access to technical formulation: a manufacturer with experience in cosmetic aerosols has proven formula bases and can adapt the viscosity, propellant, and spray particle size to the client's specifications.
- Available containers
- aluminum and tinplate
- Propellants
- adapted according to formulation and intended use
- Cosmetic sectors served
- deodorants, hairsprays, hair care products, intimate hygiene, body cosmetics
- Production capacity
- more than 12 million units per year
- Active certifications
- ISO 9001/2015 · ISO 22716/2017
- Logistics location
- less than 2 hours from the port of Barcelona
The Documentation the Responsible Person Needs
The PIF (Product Information File) required by Regulation 1223/2009 is largely built with documents generated by the manufacturer during production. The responsible person will need, at a minimum, the formula description with its actual concentrations, the certificates of analysis for each raw material, the batch records of the manufacturing process, the results of the quality controls of the finished product and, in the case of deodorants or antiperspirants, the corresponding efficacy studies.
A manufacturer operating under ISO 22716/2017 generates and maintains all this documentation systematically. This means that the responsible person does not start from scratch: they receive a structured documentation package that their toxicologist can review directly to issue the safety report.
The consistency between what the manufacturer declares and what their management system certifies is the strongest argument before any inspection by the competent authority.
The Ilerspray quality policy details how the commitments documented under ISO 9001/2015 and ISO 22716/2017 translate into the actual manufacturing process and the traceability a brand needs to bring its spray cosmetics to the European market with full guarantees.
