ASEAN Guidelines for Cosmetic Good Manufacturing Practice

Annex 1, Part 9

ASEAN GUIDELINES FOR COSMETIC GOOD MANUFACTURING PRACTICE

PREAMBLE

The GMP Guidelines have been produced to offer assistance to the cosmetic industry
in compliance with the provisions of the ASEAN Cosmetic Directive. As this document is
particularly intended for cosmetic products, clear delineation from drug or
pharmaceutical product GMP should be kept in mind.

The Good Manufacturing Practices presented here is only a general guideline for the
manufacturers to develop its own internal quality management system and procedures.
The important objective must be met in any case, i.e. the final products must meet the
quality standards appropriate to their intended use to assure consumer’s health and
benefit.

1. INTRODUCTION

The objective of the Cosmetic Good Manufacturing Practice (GMP) guidelines

is to ensure that products are consistently manufactured and controlled to the
specified quality. It is concerned with all aspects of production and quality
control.

1.1 General Consideration

1.1.1 In the manufacture of cosmetic products, overall control and

monitoring is essential to ensure that the consumer receives
products of specified quality.

1.1.2 The quality of a product depends on the starting materials,

production and quality control processes, building, equipment and
personnel involved.

1.2 Quality Management System

1.2.1 A quality system should be developed, established and

implemented as a means by which stated policies and objectives
will be achieved. It should define the organisational structure,
functions, responsibilities, procedures, instructions, processes
and resources for implementing the quality management.

1.2.2 The quality system should be structured and adapted to the

company’s activities and to the nature of its products and should
take into consideration appropriate elements stated in this
Guidelines.
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1.2.3 The quality system operation should ensure that if necessary,

samples of starting materials, intermediate, and finished products
are taken, tested to determine their release or rejection on the
basis of test results and other available evidence related to
quality.

2. PERSONNEL

There should be an adequate number of personnel having knowledge,

experience, skill and capabilities relevant to their assigned function. They
should be in good health and capable of handling the duties assigned to them.

2.1 Organisation, Qualification and Responsibilities

2.1.1 The organisational structure of the company shall be such that

the production and the quality control sections are headed by
different persons, neither of whom shall be responsible to the
other.

2.1.2 The head of production should be adequately trained and

experienced in cosmetic manufacturing.

He should have authority and responsibilities to manage

production of products covering operations, equipment,
production personnel, production areas and records.

2.1.3 The head of quality control should be adequately trained and

experienced in the field of quality control. He should be given full
authority and responsibility in all quality control duties such as
establishment, verification and implementation of all quality
control procedures. He should have the authority to
designate/assign when appropriate, personnel, to approve
starting materials, intermediates, bulk and finished products that
meet the specification or to reject those which do not conform to
the relevant specification or which were not manufactured in
accordance with approved procedures and under the defined
conditions.

2.1.4 The responsibilities and authority of key personnel should be

clearly defined.

2.1.5 An adequate number of trained personnel should be appointed to

execute direct supervision in each section of the production and
the quality control unit.

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2.2 Training

2.2.1 All personnel directly involved in the manufacturing activities

should be appropriately trained in manufacturing operations in
accordance to GMP principles. Special attention should be given
to training of personnel working with any hazardous materials

2.2.2 Training in GMP should be conducted on a continuous basis.

2.2.3 Records of training should be maintained and its effectiveness

assessed periodically.

3. PREMISES

The premises for manufacturing should be suitably located, designed,

constructed and maintained.

3.1 Effective measures should be taken to avoid any contamination from the
surrounding environment and from pests.

3.2 Household products containing non-hazardous materials/ingredients and

cosmetic products can share the same premises and equipment
provided that due care should be exercised to prevent cross
contamination and risk of mix-up.

3.3 Painted line, plastic curtain and flexible barrier in the form of rope or tape
may be employed to prevent mix-up.

3.4 Appropriate changing rooms and facilities should be provided. Toilets

should be separated fromthe production areas to prevent product
contamination/cross contamination.

3.5 Defined areas should be provided for, wherever possible and applicable:

3.5.1 Materials receiving.

3.5.2 Material Sampling

3.5.3 Incoming goods and quarantine.

3.5.4 Starting materials storage.

3.5.5 Weighing and dispensing.

3.5.6 Processing.

3.5.7 Storage of bulk products.

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3.5.8 Packaging.

3.5.9 Quarantine storage before final release of products.

3.5.10 Storage of finished products.

3.5.11 Loading and unloading.

3.5.12 Laboratories.

3.5.13 Equipment washing.

3.6 Wall and ceiling, where applicable should be smoothand easy to

maintain. The floor in processing areas should have a surface that is
easy to clean and sanitise.

3.7 Drains should be of adequate size and should have trapped gullies and
proper flow. Open channels should be avoided where possible, but if
required they should be able to facilitate cleaning and disinfection.

3.8 Air intakes and exhausts and associated pipework and ducting, when
applicable, should be installed in such a way as to avoid product
contamination.

3.9 Buildings should be adequately lit and properly ventilated appropriate to

the operations. .

3.10 Pipework, light fittings, ventilation points and other services in

manufacturing areas should preferably be installed in such a way as to
avoid uncleanable recesses and run outside the processing areas.

3.11 Laboratories should preferably be physically separated from the

production areas.

3.12 Storage areas should be of adequate space provided with suitable

lighting, arranged and equipped to allow dry, clean and orderly
placement of stored materials and products.

3.12.1 Such areas should be suitable for effective separation of

quarantined materials and products. Special and segregated
areas should be available for storage of flammable and
explosive substances, highly toxic substances, rejected and
recalled materials or returned goods.

3.12.2 Where special storage conditions e.g. temperature, humidity

and security are required, these should be provided.

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3.12.3 Storage arrangements should permit separation of different

labels and other printed materials to avoid mix-up.

4. EQUIPMENT

Equipment should be designed and located to suit the production of the product.

4.1 Design and Construction

4.1.1 The equipment surfaces coming into contact with any in-
process material should not react with or adsorb the materials
being processed.

4.1.2 Equipment should not adversely affect the product through

leaking valves, lubricant drips and through inappropriate
modifications or adaptations.

4.1.3 Equipment should be easily cleaned.

4.1.4 Equipment used for flammable substances should be

explosion proof.

4.2 Installation and Location

4.2.1 Equipment should be located to avoid congestion and should

be properly identified to assure that products do not become
admixed or confused with one another.

4.2.2 Water, steam and pressure or vacuum lines, where

applicable, should be installed so as to be easily accessible
during all phases of operation. They should be clearly
identified.

4.2.3 Support systems such as heating, ventilation, air conditioning,

water (such as potable, purified, distilled), steam,
compressed air and gases (example nitrogen) should function
as designed and identifiable.

4.3 Maintenance

Weighing, measuring, testing and recording equipment should be

serviced and calibrated regularly. All records should be maintained.

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5. SANITATION AND HYGIENE

Sanitation and hygiene should be practised to avoid contamination of the

manufacturing of products. It should cover personnel, premises,
equipment/apparatus and production materials and containers.

5.1 Personnel

5.1.1 Personnel should be healthy to perform their assigned duties.

Regular medical examination must be conducted for all
production personnel involved with manufacturing processes.

5.1.2 Personnel must practise good personal hygiene..

5.1.3 Any personnel shown at any time to have an apparent illness

or open lesions that may adversely affect the quality of
products should not be allowed to handle raw materials,
packaging materials, in-process materials, and finished
products.

5.1.4 Personnel should be instructed and encouraged to report to

their immediate supervisor any conditions (plant, equipment or
personnel) that they consider may adversely affect the
products.

5.1.5 Direct physical contact with the product should be avoided to

ensure protection of the product from contamination.
Personnel should wear protective and clean attire appropriate
to the duties they perform,.

5.1.6 Smoking, eating, drinking and chewing, , food, drinks and

smoking materials and other materials that might contaminate
are not permitted in production, laboratory, storage or other
areas where they might adversely affect product quality.

5.1.7 All authorised personnel entering the production areas should

practice personal hygiene including proper attire.

5.2 Premises

5.2.1 Adequate employee's washing and well ventilated toilet

facilities should be provided and separated from the
production area.

5.2.2 Suitable locker facilities should be provided at appropriate

location for the storage of employees' clothing and personal
belongings.
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5.2.3 Waste material should be regularly collected in suitable

receptacles for removal to collection points outside the
production area.

5.2.4 Rodenticides, insecticides, fumigating agents and sanitising

materials must not contaminate equipment, raw materials,
packaging materials, in-process materials or finished
products.

5.3 Equipment and Apparatus

5.3.1 Equipment and utensils should be kept clean.

5.3.2 Vacuum or wet cleaning methods are preferred.

Compressed air and brushes should be used with care and
avoided if possible, as they increase the risk of product
contamination.

5.3.3 Standard operating procedures must be followed for cleaning

and sanitising of major machines.

6. PRODUCTION

6.1 Starting Materials

6.1.1 Water

Special attention should be paid to water, since it is an important

raw material.Water production equipment and water systems
should supply quality water. Water systems should be sanitized
according to well-established procedures.

The chemical and microbiological quality of water used in

production should be monitored regularly, according to written
procedures and any anomaly should be followed by corrective
action.

The choice of method for water treatment such as deionisation,

distillation or filtration depends on product requirement. The
storage as well as delivery system should be properly maintained.

6.1.2 Verification of materials

All deliveries of raw materials and packaging materials should be

checked and verified for their conformity to specifications and be
traceable to the product.

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Samples of raw materials should be physically checked for

conformity to specifications prior to release for use. The raw
materials should be clearly labelled. All goods must be clean and
checked for appropriate protective packing to ensure no leakage,
perforation or exposure.

6.1.3 Rejected materials

Deliveries of raw materials that do not comply with specification

should be segregated and disposed according to standard
operating procedures.

6.2 Batch Numbering System

6.2.1 Every finished product should bear a production identification

number which enables the history of the product to be traced..

6.2.2 A batch numbering system should be specific for the product

and a particular batch number should not be repeated for the
same product in order to avoid confusion.

6.2.3 Whenever possible, the batch number should be printed on

the immediate and outer container of the product.

6.2.4 Records of batch number should be maintained.

6.3 Weighing and Measurement

6.3.1 Weighing should be carried out in the defined areas using

calibrated equipment.

6.3.2 All weighing and measurement carried out should be

recorded and , where applicable, counterchecked.

6.4 Procedure and Processing

6.4.1 All starting materials used should be approved according to

specifications.

6.4.2 All manufacturing procedures should be carried out according

to written procedures 6.4.3 All required in-process controls
should be carried out and recorded.

6.4.4 Bulk products should be properly labelled until approved by

Quality Control, where applicable.

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6.4.5 Particular attention should be paid to problem of cross-

contamination in all stages of processing.

6.5 Dry Products

Handling of dry materials and products should be given

special attention. Where possible, dust-containing production
system, central vacuum system or other suitable methods
should be employed.

6.6 Wet Products

6.6.1 Liquids, creams and lotions should be produced in such a way

as to protect the product from microbial and other
contamination.

6.6.2 The use of closed systems of production and transfer is

recommended.

6.6.3 Where pipe-lines are used for delivery of ingredients or bulk

products, care should be taken to ensure that the systems are
easy to clean.

6.7 Labelling and Packaging

6.7.1 Packaging line should be inspected for clearance prior to

operation. Equipment should be clean and functional. All
materials and products from previous packaging operation
should have been removed.

6.7.2 Samples should be taken and checked at random during

labelling and packaging operations.

6.7.3 Each labelling and packaging line should be clearly identified

to avoid mix-up.

6.7.4 Excess labels and packaging materials should be returned to

store and recorded. Any rejected packaging materials should
be disposed off accordingly..

6.8 Finished Product: Quarantine and Delivery to Finished Stock

6.8.1 All finished products should be approved by Quality Control

prior to release.

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7. QUALITY CONTROL

7.1 Introduction

Quality control is an essential part of GMP. It provides assurance that

cosmetic products will be of consistent quality appropriate to their
intended use.

7.1.1 A quality control system should be established to ensure that

products contain the correct materials of specified quality and
quantity and are manufactured under proper conditions
according to standard operating procedures.

7.1.2 Quality control involves sampling, inspecting and testing of

starting materials, in process, intermediate, bulk, and finished
products. It also includes where applicable, environmental
monitoring programs, review of batch documentation, sample
retention program, stability studies and maintaining correct
specifications of materials and products.

7.2 Reprocessing

7.2.1 The methods of reprocessing should be evaluated to ensure

that they do not affect the quality of the product.

7.2.2 Additional testing of any finished product which has been

reprocessed should be performed.

7.3 Returned Products

7.3.1 Returned products should be identified and stored separately

either in allocated area or by moveable barrier such as rope
or tape.

7.3.2 All returned products should be tested if necessary, in

addition to physical evaluation before being released for
distribution.

7.3.3 Returned products which do not comply with the original

specification should be rejected.

7.3.4 Rejected products should be disposed according to

appropriate procedures.

7.3.5 Records of returned products must be maintained.

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8. DOCUMENTATION

8.1 Introduction

The documentation system should include the complete history of each

batch, from starting materials to finished products. The system should
record executed activities for maintenance, storage, quality control,
primary distribution and other specific matters related to GMP.

8.1.1 There should be a system for preventing the use of any

superseded document.

8.1.2 If an error is made or detected on a document, it should be

corrected in such a manner that the original entry is not lost
and correction is made close to the original entry, initialled
and dated.

8.1.3 Where documents bear instructions they should be clearly

written step by step.

8.1.4 Documents should be dated and authorised.

8.1.5 Documents should be readily available to relevant parties.

8.2 Specifications

All specifications should be approved by authorised personnel.

8.2.1 Raw and packaging material specifications should include :

(a) Name of material

(b) Description of the material

(c) Testing parameters and acceptance limits

(d) Technical drawings, where applicable.

(e) Special precautions e.g. storage and safety conditions, if

necessary.

8.2.2 Bulk and finished product specifications should include :

(a) Name of product

(b) Description
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(c) Physical properties

(d) Chemical assay and/or microbiological assays and their

acceptance limits ; if necessary

(e) Storage conditions and safety precautions, if necessary

8.3 Documents for Production

8.3.1 Master Formula

The Master formula should be available upon request. This
document should contain the following information :

(a) Product name and product code/number.

(b) Intended packaging materials, and storage conditions

(c) List of raw materials used

(d) List of equipment used.

(e) In-process controls with their limits in processing and

packaging, where applicable.

8.3.2 Batch Manufacturing Record ( BMR )

(a) Batch Manufacturing Records should be prepared for

each batch of product.

(b) Each BMR should include the following :

i. Name of product
ii. Batch formula
iii. Brief manufacturing process
iv. Batch or code number
v. Date of the start and finish of processing and
packaging
vi. Identity of individual major equipment and lines or
location used
vii. Records of cleaning of equipment used for
processing as appropriate
viii. In-process control and laboratory results, such as
pH and temperature test records
ix. Packaging line clearance inspection records
x. Any sampling performed during various steps of
processing
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xi. Any investigation of specific failure or discrepancies

xii. Results of examinations on packed and labelled
products

8.3.3 Records for Quality Control

(a) Records for each testing, assay result and release or rejection of
starting materials, intermediates, bulk and finished product should
be maintained.

(b) These records may include :

i. Date of test
ii. Identification of the material
iii. Supplier name
iv. Date of receipt
v. Original batch number if any
vi. Batch number
vii. Quality control number
viii. Quantity received
ix. Date of sampling
x. Quality control results

9. INTERNAL AUDITS

An internal audit consists of an examination and assessment of all or part of a

quality system with the specific purpose of improving it. An internal audit may
be conducted by outside or independent specialists or a team designated by the
management for this purpose. Such internal audits may also be extended to
suppliers and contractors, if necessary. A report should be made at the
completion of each internal audit.

10. STORAGE

10.1 Storage Areas

10.1.1 Storage areas should be of sufficient capacity to allow orderly

storage of the various categories of materials and products
such as starting and packaging materials, intermediates, bulk
and finished products, products in quarantine, and released,
rejected, returned, or recalled products.

10.1.2 Storage areas should be designed or adapted to ensure good

storage conditions. They should be clean, dry and well-
maintained. Where special storage conditions are required (
temperature and humidity ) these should be provided,
checked and monitored.
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10.1.3 Receiving and dispatch bays should protect materials and

products from weather. Reception areas should be
designed and equipped to allow incoming materials to be
cleaned if necessary before storage.

10.1.4 Storage areas for quarantine products should be clearly

demarcated.

10.1.5 Wherever possible sampling area for starting materials

should be provided to prevent contamination.

10.1.6 Hazardous materials should be safely and securely stored.

10.2 Stock Handling and Control

10.2.1 Receiving Products

10.2.1.1 Upon receipt, each incoming delivery should be

checked against the relevant documentation and
physically verified by label description, type and
quantity.

10.2.1.2 The consignment should be carefully inspected for

defects and damage. Records should be retained
for each delivery.

10.2.2 Control

10.2.2.1 Records should be maintained showing all receipts

and issues of products.

10.2.2.2 Issues should observe the principle of stock

rotation (first in - first out).

10.2.2.3 All labels and containers of products should not be

altered, tampered or changed.

11. CONTRACT MANUFACTURING AND ANALYSIS

The conditions of contract manufacturing and analysis should be clearly defined,

agreed, and controlled so as to avoid misunderstandings, which could result in a
product or work of unsatisfactory quality. All aspects of contracted work should be
specified to obtain a quality product conforming to the agreed standards.

There should be a written contract between the principal and the contract
manufacturer to clearly establish the duties and responsibilities of each party.
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12. COMPLAINTS

12.1 A person responsible for handling complaints and deciding the

measures to be taken should be designated. If this person is different
from the authorised person, the latter should be made aware of any
complaint, investigation or recall.

12.2 There should be written procedures describing the action to be taken,

including the need to consider a recall, in the case of a complaint
involving a possible product defect.

12.3 Complaints involving product defects should be recorded with all the
original details and investigated.

12.4 If a product defect is discovered or suspected in a batch,

consideration should be given to whether other batches should be
checked in order to determine whether they are also affected. In
particular, other batches that may contain reprocessed product from
the defective batch should be investigated.

12.5 Where necessary, appropriate follow-up action, possibly including

product recall, should be taken after investigation and evaluation of
the complaint.

12.6 All the decisions and measures taken as a result of a complaint

should be recorded and referenced to the corresponding batch
records.

12.7 Complaint records should be regularly reviewed for an indication of

specific or recurring problems that require attention and might justify
the recall of marketed products.

12.8 The competent authority should be informed if a manufacturer is

considering action following possibly faulty manufacture and product
deterioration,which may lead to serious safety issues.

13. PRODUCT RECALLS

There should be a system of recall from the market of products known or

suspected to be defective.

13.1 A person responsible for the execution and co-ordination of recalls

should be designated, as well as sufficient personnel, to handle all
aspects of recalls with the appropriate degree of urgency.

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13.2 Written procedures for recall should be established and regularly

reviewed. Recall operations should be capable of being initiated
promptly.

13.3 The primary distribution records should be readily available to the

person(s) responsible for recalls, and they should contain sufficient
information of distributors.

13.4 The progress of the recall process should be recorded and a final
report issued, including a reconciliation between the delivered and
recovered quantities of the products.

13.5 The effectiveness of the arrangements for recalls should be

evaluated from time to time.

13.6 A written instruction should be established to ensure recalled

products are stored securely in a segregated area while awaiting
decision..

14. GLOSSARY

14.1 Batch

A quantity of any cosmetic product produced in a given cycle of

manufacture that is uniform in character and quality.

14.2 Batch Number

A designation in numbers and/or letters or combination of both that

identifies the complete history of the batch, quality control and
distribution.

14.3 Bulk Product

Any processed product which will have to undergo the packaging

operation in order to become a finished product.

14.4 Calibration

Combination of checking an instrument and adjusting it to bring it within

its limits for accuracy according to recognized standards.

14.5 Date of Manufacture

Date of manufacturing of a batch of product.

14.6 Documentation

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All written procedures, instructions and records involved in the

manufacture and quality control of products.

14.7 Product

Any substance or preparation intended to be used, or capable or

purported or claimed to be capable of being used, in or for cleansing,
improving, altering or beautifying the complexion, skin, hair or teeth.

14.8 Finished Product

A product which has undergone all stages of manufacturing operations.

14.9 In-Process Control

Checks and tests instituted and carried out in the course of the
manufacture of a product including checks and tests done on
environment and equipment in order to ensure that the end product will
comply with its specification.

14.10 Intermediate Product

Any processed substance or mixture of substances which has to

undergo one or more stages of processing to become a bulk product.

14.11 Manufacture or Manufacturing

The complete set of activities to produce a product, comprising of

production and quality control, from acquisition of all raw materials
through processing and subsequent packaging and release for
distribution of the finished product.

14.12 Packaging

The part of production cycle applied to a bulk product to obtain the

finished product.

14.13 Packaging Material

Any material used in the packaging of a bulk product to obtain the

finished product.

14.14 Processing

The part of production cycle starting from weighing of raw materials to

obtaining a bulk product.

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14.15 Production

All operations starting from processing to packaging to obtain a finished

product.

14.16 Quality Control

All measures taken during manufacturing which are designed to ensure

the uniform output of product that will conform to established
specifications.

14.17 Quarantine

The status of materials or products set apart physically or by system,

while awaiting a decision for their rejection or release for processing,
packaging or distribution.

14.18 Raw Materials

Any ingredient to be used in the formulation of a cosmetic product.

14.19 Rejected

The status of materials or products which are not permitted to be used

for processing, packaging or distribution.

14.20 Released

The status of materials or products which are allowed to be used for

processing, packaging or distribution.

14.21 Returned Product

Finished products sent back to the manufacturer.

14.22 Sanitation

Hygienic control on manufacturing premises, personnel, equipment and

material handling.

14.23 Specification of Materials

A description of a starting material or finished product in terms of its

chemical, physical and biological characteristics, if applicable. A
specification normally includes descriptive and numerical clauses stating
standards and tolerated deviations.

14.24 Starting Materials

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Raw materials and packaging materials used in the production of

products.

15. REFERENCES

15.1 Good Manufacturing Practices for Pharmaceutical Products, World

Health Organisation ( WHO ) Technical Report Series No : 823, 1992

st
15.2 Good Storage Practice, 1 Edition, January 1995, ISBN 983-9870-14-9,
National Pharmaceutical Control Bureau, Malaysia

15.3 Cosmetic Good Manufacturing Practices, COLIPA – The European

Cosmetic Toiletry and Perfumery Association, July 1994

15.4 Australian Code of Good Manufacturing Practice for Therapeutic Goods

– Sunscreen Products, Therapeutic Goods Administration ( TGA ),
Australia, February 1994

15.5 Guidelines on Good Manufacturing Practice ( GMP ) for Traditional

st
Medicines, National Pharmaceutical Control Bureau, Malaysia, 1
Edition, 1999

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