Cosmetic Ingredients: Effci GMP Audit Checklist FOR

EFfCI GMP AUDIT CHECKLIST
FOR
COSMETIC
INGREDIENTS
REVISION 2017
According to
EFfCI GMP GUIDE FOR COSMETIC INGREDIENTS 2017
Including the Certification Scheme for GMP for Cosmetic Ingredients
Revision 2017
Prepared by the European Federation

for Cosmetic Ingredients
In Collaboration with
Personal Care Products Council

Committed to Safety,
Quality & Innovation
Copyright EFfCI 2012, 2017

INTRODUCTION
Purpose and Scope

The quality of cosmetic ingredients is critical to assure the safety, quality and efficacy of cosmetic
products and related personal care products. Cosmetic ingredients have a wide range of
applications and are essential components of the cosmetic product formulation. Therefore,
applying appropriate good manufacturing practice (GMP) principles to cosmetic ingredients is
essential.
With the publication of ISO 9001:2015 the EFfCI GMP checklist and Certification Standard has
been updated to be fully aligned with the updated ISO standard. Texts have been adapted and
highlighted to aid review and implementation. Following a further revision to the Guide and
Standard in 2017 it is timely that this document has been updated as an aid to implementing the
GMP Checklist and Certification Standard 2017. The audit checklist asks a series of questions
which can be used to assess an organisation’s level of compliance against the GMP and
Certification Standard 2017. This allows an assessment to be completed following an inspection
of the organisations operations either by a physical audit or paper study.
It may also be used by organisations to perform a gap analysis against the EFfCI GMP standard
for example as part of preparations for Certification to the EFfCI GMP standard. But in this case it
should be noted that the organisation will have to hold a current ISO 9001:2015 certificate in order
to achieve that Certification. The requirements for ISO 9001:2015 certification have not been
included in this checklist. Some EFfCI GMP clauses do not start at the lowest level, for example
“a” in a bullet list. This is because the EFfCI GMP list will be in addition to the bullets in ISO
9001:2015.
Additional columns have been added to the template to aid the closure of any associated actions
on each topic. These have been given generic titles but users may adapt them to suit the purpose
for which the Audit checklist is being used. For example, the OBSERVATIONS could be used to
record identified gaps in a gap analysis and actions to be taken to address them.
Notes: Each time “GMP” is referenced in the template it refers to the EFfCI GMP for
Cosmetic Ingredients 2017.
And “CI” refers to Cosmetic Ingredients.
EFfCI
EFfCI is a European trade association representing the chemical and natural ingredient
industries, the suppliers and service providers for the cosmetic industries. EFfCI was set up in
2000 to represent the collective interests of more than 100 cosmetic ingredient companies in
Europe.
PCPC
The Personal Care Products Council is the leading United States trade association representing
the global cosmetic and personal care products industry. Founded in 1894, the Council represents
more than 600 member companies who manufacture, distribute, and supply the vast majority of
finished personal care products marketed in the U.S. The Council’s core mission is to create a
productive business and regulatory environment to enable the industry to create safe, quality and
innovative consumer products. To carry out its mission, the Council maintains three primary
goals:
Sound Science: Support the safety of products and ingredients through strong, science-based
programs.
Modernized Legislation: Advocate legislative and regulatory policy positions to support
appropriate and coordinated regulation at the federal, state, and local levels
Global Access: Ensure global market access for member companies by working towards
Copyright © 2017 - The European Federation for Cosmetic Ingredients
Page i
harmonization of regulation, reducing trade barriers, and influencing the global regulatory and
trade environment.
ACKNOWLEDGEMENTS
This checklist was prepared by the EFfCI GMP Working group, who used with permission of IPEC
Europe the IPEC-PQG Good Manufacturing Practices Audit Guide for Pharmaceutical Excipients
2008 as a reference and a basis for further development of the Audit Checklist. The IPEC-PQG
Checklist has been adapted in such a way that it is better suited for use by cosmetic ingredient
manufacturers.
We would like to thank IPEC-PQG for allowing us to use their checklist in this way.
IPEC
The International Pharmaceutical Excipients Council (IPEC) is an international industry
association, formed in 1991 by manufacturers and end users of pharmaceutical excipients. It is an
umbrella organisation comprising three regional pharmaceutical excipient industry associations in
the United States, Europe, and Japan (which are known respectively as IPEC Americas, IPEC
Europe and JPEC). IPEC’s objective is to contribute to the development and harmonization of
international pharmaceutical excipient standards and the development of good manufacturing
practices for pharmaceutical excipients.
PQG
The Pharmaceutical Quality Group (PQG) was formed in 1977 to promote development of a
consistent approach to pharmaceutical quality and good manufacturing practices. The group has
expanded since that time and in 1990 the PQG produced three codes of practice to cover
pharmaceutical raw materials, and printed and contact packaging materials. In 1995 the codes
were revised and integrated with ISO 9002:1994. The code for raw materials was revised and
reissued as PS 9100:2002 Pharmaceutical excipients, an application standard and GMP checklist
for pharmaceutical excipients.
This Version of the EFfCI GMP Audit Checklist was prepared by:
EFfCI GMP Committee
David Melchior BASF Personal Care and Nutrition GmbH
Iain Moore Croda Europe Ltd
Peter Ungeheuer EFfCI
Marco Vassallo Complife Italia S.R.L.
Ulrike Schupmann BASF Personal Care and Nutrition GmbH
Andrea Gross DSM Nutritional Products Ltd.
Vincenzo Paolo Maria Rialdi Vevy Europe S.p.A
Karl Hensen Merck KGaA
Stephanie Bossy Intertek Certification France
Jean-Francois Cazaubon SEPPIC SA
Benoit Hun Stepan Europe S.A.S.
Fabien Luciani Ashland Specialities France sarl
Peter Radley Innospec Performance Chemicals
Stefan Knoop Symrise AG
Francois Jodogne SGS Belgium NV

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GMP AUDIT CHECKLIST
FOR
COSMETIC INGREDIENTS
according to
EFfCI GMP FOR COSMETIC INGREDIENTS
Including the Certification Scheme for GMP for Cosmetic Ingredients
Revision 2017

Page 1
EFfCI GMP AUDIT CHECKLIST FOR COSMETIC INGREDIENTS
CHECKLIST OBSERVATIONS, FINDINGS, GAPS ACTION STATUS
4 CONTEXT OF THE ORGANISATION
4.1 Understanding the Organisation and its context

Are external and internal issues concerning Cosmetic
Ingredients (CI) Identified?
Are these reflected in the organization of QMS and GMP?
Are issues reviewed and in particular is relevant legislation

monitored for changes that may affect CI?
4.2 Understanding the needs and expectations of interested

parties
Are interested parties and their requirements identified?
Is there active monitoring for changes relevant to the
requirements for CI?
Are customers and regulatory authorities and their
requirements identified?
Are users of cosmetics identified as an interested party?
4.3 Determining the Scope of the Quality Management

System
Does the scope of the organizations GMP fall completely
within the scope of the certified ISO 9001 system?
Does the scope of the organisations GMP include a list of

activities, facilities and CI groups or CIs?
Is the scope of the organisations GMP and QMS defined

and controlled as documented information?
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Does the organisation only distribute CIs?, If yes then check
with Appendix F to ensure the exempted clauses are
correctly applied.
4.4 Quality Management System and its Processes

4.4.1 i
Are methods, including criteria, specified to ensure the
organisation can fulfil the requirements of GMP
requirements and effective implementation?
4.4.1j
Are all manufacturing processes, all testing and all other
operations required to control and that effect CI quality
included within the QMS?
4.4.1k
Are any operations outsourced?
Are they included in the organisations QMS?
Is there evidence that GMP principles are followed in
outsourced operations?
See section 8.4
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5 LEADERSHIP
5.1 Leadership and Commitment

5.1.1k and 5.2.1e
Is there a well-publicised Quality Policy. Is it signed/authorised
by top management? Does it include statements on the
importance and relevance of GMP?
5.1.1l
Are Quality Objectives set? Do these include GMP related
objectives and adherence to GMP as an objective?
Are the performance against objectives measured, reviewed
and objectives revised at an appropriate frequency?
5.1.1.m
Have resources been explicitly identified for GMP quality
system and for achievement of each quality objective? (see
5.1.2
How is meeting customer requirements and meeting GMP
requirements promoted and monitored by top management?
5.2 Policy
5.2.1e
see 5.1.1k above
5.2.1.f
Does the quality policy refer to Quality Objectives which
express the principles of GMP?
5.2.1g
Are the areas of the organisation where GMP is applied
clearly defined?
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5.2.2
Is the Quality Policy communicated in such a way that it is
available to all and familiar?
Is the requirement for GMP communicated in such a way
that is available to all?
5.3 Organisational Roles, Responsibilities and Authorities

Are there identified people/job roles with responsibility for
communicating GMP, for ensuring their understanding, for
reporting against them and integrating them within the QMS?
(Note: roles can be combined)
Is there an identified Quality Unit?
Are reporting lines for members of the Quality Unit

independent of operations? (in particular manufacturing,
supply chain, product management and sales)
Does the Quality Unit exist on an organisational chart, does

this show independence?
Is there a written description of the responsibilities of the

Quality Unit?
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Are there identified job roles with responsibilities for the
following?
• Performing risk assessments required by GMP
for CI
• Approving suppliers of quality critical materials
and services
• Approving or rejecting raw materials, packaging
components, intermediates and finished CIs
• Reviewing records to ensure no critical errors
have occurred
• Investigating critical errors in records
• Participating in authorizing changes to
processes, specifications, procedures, test
methods
• Investigating failures and complaints
• Accepting or rejecting CI if it is made, processed,
packaged or held by another company
• Training personnel in GMPs
Does the internal audit programme verify that these

responsibilities have been undertaken? – see 9.2
Are there written, current job descriptions for personnel

critical to ensuring CI quality – this includes Quality Unit, and
also others? (e.g. production, product management)
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6 PLANNING
6.1 Actions to address risks and opportunities

Are there minimum risk assessments as required by the
standard? (required 7.1.3, 7.1.4, guidance 6.3, 8.5.1.2,
8.4.1, 8.5.4.2, 8.7.1)
Has the risk assessment process been defined?
Are there other risk assessments?
Who has prepared these risk assessments, one person or a

group?
Are risk assessments maintained and is there evidence of

their revision as plant and processes change and as a result
of non-conformity?
If the risk assessment recommends additional measures

are these implemented?
Is there evidence of evaluation of effectiveness of controls

and additional measures?
Are the acceptance criteria for risks made clear?
6.2 Quality Objectives and planning to achieve them
Are there quality objectives which have been set by top

management?
Do these include adherence to GMP?
Are objectives deployed within the organisation?
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Are objectives periodically reviewed?
6.3 Planning of changes
Is there a documented procedure for the control of

changes? Are responsibilities defined?
Is the scope of the procedure appropriate – e.g. process,

equipment, specification, materials?
Does the Quality Unit participate in reviewing changes?
How are changes managed?

Are changes only made after identified actions have been
completed and reviewed?
What is the organisations definition of “significant change”?
Is there a procedure for assessing the impact of significant

changes, in terms of both CI quality and performance?
Does the change control system require customers to be

notified of significant changes?
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7 SUPPORT
7.1 Resources
7.1.1 General
Are there sufficient resources (people, equipment, facilities,
buildings) to meet requirements of the GMPs?
Is there any evidence of planning resources to meet needs

of GMPs? (see 5.3)
7.1.2 People
Are there enough people to effectively implement and
maintain QMS?
Are there enough people to manufacture, test, pack and

distribute CI in conformance with the GMP?
7.1.3 Infrastructure
Is there a written risk assessment to evaluate the threats to
CI contamination that considers:
• location of the operations,
• state of repair,
• suitable size, construction and location of the
building and facility,
• ability to maintain a suitably clean building and
facility environment,
• operations that can affect the CI quality,
• presence of airborne contaminants, especially
highly sensitizing or toxic substances?
Did the risk assessment identify that any additional control

measures were required? Have these been implemented?
What are the controls on access to computer systems which

are critical to the assurance of CI quality? Is there a list of
authorized users?
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7.1.3.1 Buildings and Facilities
Are buildings and facilities in a good state of repair?
Is their size, construction and location suitable for cleaning
and maintenance?
Where the CI is exposed, are there adequate measures to

prevent contamination?
Is there adequate space to ensure CI integrity and to

preclude mix-ups or cross-contamination including
packaging and warehousing operations?
Are there adequate laboratory facilities to perform required

testing?
Is there adequate space around finished CI locations in the

warehouse to facilitate cleaning?
7.1.3.2 Equipment
Is equipment maintained in a good state of repair?
If processing occurs outdoors what controls are in place to
minimize risk to CI quality?
7.1.3.2.1 Equipment Construction

Is equipment constructed so that CI contact surfaces are not
reactive, additive, or absorptive and will not adversely affect
the CI?
Is equipment designed and used in a manner that minimizes

the potential for contamination of CI with lubricants, coolants,
metal or seal fragments, or other extraneous materials?
If CI exposure to, or contamination with, lubricants or coolants

is possible, are these materials suitable for use in cosmetic
applications?
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How is the equipment designed? Has it been designed to
minimize the possibility of contamination from operator
contact in operations such as unloading of centrifuge bags,
use of transfer hoses, and operation of drying equipment and
pumps?
7.1.3.2.2 Equipment Maintenance

Are there Procedures and appropriate documentation for
inspection (monitoring the condition) and maintenance of
critical equipment and for measuring and test instruments?
Are records kept of maintenance, and repairs?
7.1.3.2.3 Computer Systems

What process is used to control changes to systems and
programs that can have an effect on the quality of the CI (see
4.3)?
Are changes verified and documented? Can only
designated personnel make such changes?
What is the procedure for reviewing and updating security

access when a person leaves the department or company? Is
their access to the system or their access codes to the system
revoked in a timely fashion?
If passwords are used as a security measure, are there

provisions for periodic changing of passwords?
What backup systems are in place?

Have these been verified as effective?
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7.1.3.3 Utilities
What utilities are used in the manufacture of CIs? How have
these utilities been assessed and appropriate action taken to
assure they do not contaminate the CIs?
7.1.3.4 Water
Is water used in the manufacture of the CIs? If so, is it
suitable for its intended use?
If water is used where it could contaminate the CIs, does it at

a minimum meet W HO guidelines for drinking (potable) water
quality?
Where water is treated by the manufacturer:

• Is there a specification for defining the quality of the
water?
• Is there a defined process for treating the water?
• Is the water periodically monitored for against the
specification?
• If specification action limits for process or purified
water are exceeded, how is the cause investigated,
the problem corrected, the impact of the
contamination of CIs manufactured with the water
assessed, and the results of the investigation
documented?
7.1.4 Environment for the operation of processes

Is there a written risk assessment to evaluate the threats to
CI contamination? Have the following been considered in
the risk assessment?
• air handling systems,
• special environments,
• cleanliness and sanitary conditions,
• waste segregation and disposal,
• pest control,
• other risk assessments.
Are there documented controls in place to address the
identified risks of contamination?
Are suitable records retained?
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The following questions in 7.1.4.1 to 7.1.4.6 should be
audited if the risk assessment has identified that controls
are needed for these aspects of work environment control.
7.1.4.1Cleaning
Are facilities maintained in an appropriately clean, sanitary
and orderly manner?
Where critical to CIs quality, are there adequately detailed

documented Procedures for cleaning? Do the Procedures
assign responsibilities; include schedules; describe
methods, equipment, and materials to be used; and require
maintenance of records?
How is waste segregated and storage containers identified? Is

waste disposed of in a timely manner?
7.1.4.2 Pest Control
Where necessary, is there a program to protect quality

critical materials and CIs from contamination due to insects,
rodents, birds, and other vermin (including domestic
animals)? W hat evidence is there to show that it is
adequate?
Where critical to CIs quality, how are windows, doors, or
other openings to the outside adequately protected from
entry by pests? If raw materials or intermediates are stored
in silos, tanks, or other large containers, how are the vents
adequately protected to prevent entry of birds and insects?
If allowed to be used, are rodenticides and pesticides

appropriately evaluated?
If an outside party performs pest control, how is that party’s
performance and compliance monitored?
Are pest control records kept? W hat corrective and
preventive measures have been taken?
If the nature of raw material (such as botanicals) contains
unavoidable contamination, what are the controls to prevent
the increase or spread in contamination or infestation?
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7.1.4.3 Lighting
Is there adequate lighting?
Is the lighting protected from shattering in areas where the

CI may be exposed?
7.1.4.4 Drainage
Where the CI is open to the environment, are drains of
adequate size? Are drains equipped with an air break or
other mechanism to prevent back flow?
7.1.4.5 Personal Hygiene

Where CI is exposed to the environment how are personnel
hygiene requirements and protective equipment specified
and communicated to employees?
Are personnel observed to comply with those requirements
for cleanliness, special clothing, protection, and hair
coverings as required in the various manufacturing,
packaging and testing areas?
Is there policy prohibiting loose and/or unsecured jewellery

or other items in operations where they can fall into the CI?
Are personnel observed to be in compliance?
Where can lab and operating personnel store and consume

food, beverage, or tobacco products? Are these non-
production/lab areas designated?
7.1.4.6 Washing and Toilet Facilities

Are there adequate hand washing, drying and sanitizing
facilities at appropriate locations in the plant? Do they provide
hot and cold water, soap or detergent, and have air dryers or
single service towels?
Are there clean, readily accessible toilet facilities that are

maintained in good repair?
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Are there adequate facilities for showering and/or changing
clothes?
7.1.5 Maintenance and Measuring Resources

7.1.5.1 General
Do monitoring and measuring activities include the quality
management systems as well as parameters that define CI
quality? Do these monitoring and measuring activities lead
to the consideration of opportunities for improvement?
Is there sufficient equipment, instruments, people for
evaluation of the CI?
7.1.5.2 Measurement Traceability

Is measuring and test equipment, including computer
equipment individually identified?
Are there procedures for calibration of quality-critical

equipment and for measuring and test instruments? Do the
procedures;
• include schedules;
• describe methods, equipment, and materials to be
used,
• include standards traceable to national standards;
• define re-calibration frequency
• define limits for accuracy and precision and
• require maintenance of records?
Is there a procedure specifying how to deal with equipment
and instruments if they are beyond the calibration due date?
How is the current calibration status of quality-critical

instruments and equipment known to users?
Are the actions to be taken with equipment if there is a

failure of calibration known and adequate?
Page 15
Are there records or logs maintained for calibration
operations?
Is there an investigations procedure to deal with test

records and instrument readings that may have been
made while instruments and equipment did not meet
established specifications?
7.1.6 Organizational Knowledge
How does the organization maintain current knowledge of
cosmetic industry, its regulatory requirements and GMP for
CI?
How does the organization maintain current knowledge of

customer and consumer expectations in the cosmetic
industry?
How is this knowledge made available to personnel to

perform their duties and ensure quality, safety and integrity
of the CI?
7.2 Competence
Is there a procedure for identifying training needs and
providing the necessary training on a regular basis?
What is the frequency of continuing GMP training and is it

sufficient to ensure that employees remain familiar with
applicable GMP requirements? How broadly is the training
conducted within the site?
Are job-specific training requirements clearly defined?
Is there hygiene training for personnel handling CI so they

understand the precautions necessary to prevent the
contamination of the CI? How is it documented?
Page 16
What records are kept to demonstrate that GMP training is
conducted in a timely manner for new and temporary
employees / contractors?
How are training effectiveness and employee competency

assessed?
How is training and qualifications documented for each

employee?
Is there adequate and recurring training in personal hygiene

for people handling the CI, raw materials, packaging and
intermediates?
7.3 Awareness
How is good awareness of GMP ensured through the
organization?
7.4 Communication
How are GMP and regulatory requirements, quality policies,

quality objectives and procedures communicated throughout
the organization?
Is there a documented procedure that requires top

management to be informed of quality critical situations?
7.5 Documented Information

7.5.1 General
Is there a documented system to describe how documented
information is controlled?
Does this ensure the integrity of procedures, records and
data?
7.5.2 Creating and updating
Are documents that impact CI quality reviewed and approved

by the quality unit?
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Is retention period defined for all documented information,
including external documents?
Is at least one secure copy of obsolete documents retained

by the Quality Unit? If so for how long?
Is there a procedure for writing, handling and updating

controlled documents?
Does this include indexing, reviewing and authorising?
If document control is electronic does this provide adequate

safeguards from loss and for authorisation?
Are records clear, indelible and made directly after

performing the activity? Are they traceable to the time the
activity happened and the person making the record?
Are corrections made in such a manner that the original entry

is still readable and the person performing the correction
identified?
7.5.3 Control of Documented Information
Are there procedures in place that ensure only current,

authorised methods and procedures are being used?
Are any obsolete documents in evidence?
Is there a procedure to remove previous versions from use?
What is the defined period for retention of quality records?

Is it justified on basis of expiry date and likely use of the
materials?
Are facilities to store records suitable and protect against

decay and damage? This also applies to records stored in
computerized systems.
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Are batch records retained for at least one year past expiry
date of CI?
Are records clear, indelible and made directly after
performing the activity? Are they traceable to the time the
activity happened and the person making the record?
Are corrections made in such a manner that the original entry

is still readable and the person performing the correction
identified?
Is the record retention period justified and what is the
rationale? Is this described in a written records retention
policy or procedure? Is the retention period for batch records
at least one year more than the retest or expiry interval of the
CI?
Is there a procedure for the identification, collection,

organisation, storage and maintenance of records?
How are production deviations documented in the batch

production record?
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8 OPERATION
8.1 Operational planning and control
Is a process flow diagram or other suitable description of the

process steps available for the audited CIs?
Is the unit operation batch or continuous or some combination

of the two?
Is the CI produced in equipment dedicated to its manufacture or

is the equipment also used for other CIs?
Is there a system for identifying major equipment, instruments,

and production lines? Is this information included in batch
production and control records where appropriate?
Have the requirements to control the manufacturing process

been fully described? For example:
• reactions
• purifications
• critical steps
• operating parameters
• process limitations
• tests needed for process control
• CI specifications
• sampling plans
• test and release procedures
• environmental, hygiene and contamination control
programmes
• records of these activities
Are records kept and maintained that show written testing
programmes have been carried out?
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Do the requirements include defined testing and other controls
on quality critical raw materials?
Are there defined environmental, contamination and hygiene

control programs?
Are contract manufacturers and external laboratories required

to conform to relevant sections of this standard?
How are contract manufacturers and external laboratories
monitored?
Are there sufficient resources to realise the requirements and

plans?
Are provisions in place such that in process samples are not

returned to production without appropriate authorisation from
the Quality Unit?
Are risks identified in 7.1.3 and 7.1.4 of the standard addressed

in operational planning and control?
8.2 Requirements for products and services

8.2.1 Customer Communication
How does the manufacturer communicate the agreed
customer requirements, and changes to the customer?
Is there a system to reply to customer inquiries, contracts,

and complaints? Are complaints documented?
Is there an adequate system in place to assure that

significant process changes, including the use of
subcontractors and their effect on the CI are communicated
to the customer?
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8.2.2 Determination of the requirements for products and
services
Is there a procedure to determine customer requirements
related to the CI?
Does this include regulatory requirements applicable to

intended use as CI?
Does this include other requirements not stated but
generally known to be requirements for CI?
Is there planning and procedure for monitoring relevant

legislation for potential changes covering the manufacture
and use of cosmetics ingredients?
8.2.3 Review of the requirements for products and services

Is there a procedure in place to assure that the manufacturer
and the customer have mutually agreed upon the
specifications and other requirements? If not, what is the
alternative process?
Can the manufacturer consistently meet the customer

requirements?
Is this review of customer requirements repeated when

changes are made?
8.3 Design and Development

How have GMP requirements been applied such that they
are incorporated by the time the CI is in production?
If appropriate, how are design and development activities

translated into plans for manufacturing?
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8.4 Control of Externally provided processes, products and
services
8.4.1 General
What is the program to qualify or disqualify suppliers of raw
materials, packaging components and services that might
affect quality, and to verify that they have capability to
consistently meet agreed- upon requirements?
How are outsourced manufacturing or processing controlled

such that the organization ensures that processes used
comply with GMPs?
What is the program for the evaluation and approval of

subcontractors?
Are materials purchased against an agreed specification?

How is it ensured that materials are only purchased from
approved suppliers?
8.4.2 Type and extent of control

Are there adequate written and approved instructions and
specifications for quality critical material sampling and
testing, including investigation of nonconforming results?
Are procedures in place to prevent to use of quality critical

materials on receipt until they have been approved?
Where deliveries are sampled, is at least an identification

test performed?
Are methods of sampling designed to prevent contamination

and cross-contamination?
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Do bulk deliveries have additional controls to assure
material purity and freedom from contamination (e.g.
dedicated tankers, tamper-evident seals, certificate of
cleaning, testing, and/or audit of the supplier?
8.4.3 Information for external providers
Have the specifications for the raw material or packaging
components been provided to the supplier for their
acceptance? W hat system is in place to assure that
revisions to the specifications are provided on a timely basis
to the supplier?
What system is in place to assure that suppliers and

subcontractors notify the company of significant changes?
How are relevant contract manufacturers and laboratories
notified of the requirement to adhere to appropriate sections
of the Checklist?
8.5 Production and service provision
8.5.1 Control of production and service provision .
8.5.1.1 Production Instructions and Records .
How is the execution of significant processing steps
verified?
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Are records available and readily retrievable for each batch
of CI produced? Do these records include complete
information relating to the production and control of each
batch? Such as:
• date/time each step was completed,
• identification of persons performing and checking
each significant operation,
• identification of major equipment and lines,
• material inputs to enable traceability,
• in-process and laboratory control results,
• statement of yield, unless not quantifiable
(e.g. as in some continuous processes),
• inspection of the packaging and labelling area
before and after use,
• labelling control records,
• description of sampling performed,
• failures, deviations, investigations and
• results of final CI inspection?
8.5.1.2 Equipment Cleaning
Has the organisation identified the need for and justified

equipment cleaning and or sanitization procedures?
Note a risk assessment could be used for this purpose.
Where equipment cleaning and or sanitization procedures
are implemented, is there evidence of their effectiveness?
If the organisation has identified the need for equipment

cleaning and sanitization procedures then the following
questions should be evaluated.
Are there written cleaning procedures and do they contain

sufficient detail to allow operators to clean each type of
equipment in a reproducible and effective manner?
Is equipment and utensils cleaned at appropriate intervals?

Is the cleaning status of equipment recorded?
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If equipment is not dedicated, what other types of materials
are manufactured in the same equipment? Is there a record
of the previous product manufactured using that
equipment? W hat controls are used to prevent cross-
contamination?
If CI is campaigned, is there an established interval between
complete cleaning of the equipment?
For continuous processing: is the frequency of cleaning

specified and justified?
8.5.1.3 Recovery of Solvents, Mother Liquors and Second

Crop Crystallizations
Are recovered solvents re-used in the same step of the

process or can they be used in other processes?
If fresh and recovered solvents are commingled, are the

recovered solvents sampled and assayed and found to be
satisfactory prior to commingling? How is the quality of
commingled solvents monitored on an established schedule?
If secondary recovery procedures are performed on mother

liquors or filtrates, how are the recovered materials shown to
meet applicable specifications? Are these recovery
procedures defined? How is traceability maintained?
8.5.1.4 In process Blending/Mixing

How are blending/mixing operations controlled?
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Where finished CI is blended or mixed, to ensure batch
uniformity, how has the reproducibility of the blending or
mixing process been demonstrated?
8.5.1.5 In Process Control

How is process control assured? For example, are there
• documented sampling methods
• documented instructions, including set- points and
limits,
• in-process control testing
• specifications
• actions to be taken when the results are outside
specified limits
Are in-process samples taken and test results recorded? How
are in-process samples disposed of (not returned to production
for incorporation into the final batch)?
Have personnel performing in process testing been trained

and is the training documented?
8.5.1.6 Packaging and Labelling

How are labels controlled?
Is there a procedure to verify the accuracy of the labels and

that they contain the correct information?
Do procedures require excess labels to either be immediately

returned to controlled storage or destroyed? Are excess labels
with batch numbers destroyed?
Is there a procedure for clearing the packaging area after

each packaging operation, and cleaning before the next
operation, especially if the area is used for packaging
different materials?
Page 27
8.5.1.7 Records of Equipment Use
How is the sequence of activities for each piece of
equipment demonstrated i.e. production, maintenance and
cleaning?
8.5.1.8 Validation of Processes for Production and Service

Provision
Are there any studies to show that the manufacturing
process is capable?
8.5.2 Identification and Traceability

8.5.2.1Traceability
Is there a system in place to trace quality- critical materials
back to their original manufacturers? W ill the system allow
traceability of batches delivered to customers?
Is an identification code associated with each lot of incoming

quality-critical material to enable traceability in the
manufacturing operation?
Are batch / lot numbers assigned such that they are not
duplicated and enable tracing of all processes and batch
records for each batch?
If processing is on a continuous basis or uses bulk storage

tanks, how is a batch defined? Is the timeframe during
which a particular batch of quality-critical material was
processed through the plant documented?
If a new lot number is assigned to a reprocessed lot, can it

be traced to the original batch?
If multiple sites produce this material, how can the

manufacturing site be determined?
Page 28
8.5.2.2 Inspection and Test Status
What system is used to identify the inspection status of
quality-critical items including raw materials, packaging,
intermediates and finished CIs?
How are containers and equipment labelled to clearly

identify the contents, their inspection status?
Are quality-critical materials approved before being used in

production? Have requirements been defined for
continuously fed quality- critical materials?
What controls are exercised to assure that quality-critical

materials are not used in a batch prior to release?
8.5.2.3 Labelling
Does the final CI label contain adequate information to

identify the:
• name of the CI
• grade of CI
• quantity
• batch number
• name of the manufacturer or distributor?
If special storage conditions are necessary, are they

specified on the label or otherwise communicated to the
customer with each delivery?
8.5.3 Customer Property
If a customer supplies materials for incorporation into the

customer's product, what systems and procedures are in
place for handling such materials, including verification,
storage, maintenance, and accountability for loss or
damage?
Page 29
How are materials supplied by the customer handled?
Is there a technical or commercial agreement in place to

ensure the confidentiality of any intellectual property
provided by the customer? How is this controlled by the CI
manufacturer?
8.5.4 Preservation
8.5.4.1 Handling, Storage, and Preservation
Has the manufacturer determined that specific conditions

for the storage of the CI are required? If so, then are
suitable controls in place? Are appropriate records in place
to demonstrate the implementation of these controls?
Is the warehouse clean and well organized, and materials

easily located?
If raw materials are stored outside, do the containers give

acceptable protection to the contents? Are labels indelible?
Are such containers cleaned before their contents are
subjected to further processing?
8.5.4.2 Packaging Systems
Do CI packaging systems include?

• Written specifications, testing or examination
methods
• Cleaning procedures when containers are
re-used
• Protection against deterioration or contamination
that may occur in storage and transport
• Storage and handling procedures
• Closures that minimise the risk of contamination
• Written justification that the packaging does not
introduce impurities to the CI
Page 30
Are tamper evident seals used? If not, has a risk
assessment been completed to determine the non-
application of tamper evident seals?
How are packaging and closures handled and stored in

order to protect them from contamination and deterioration,
and to prevent mix-ups?
If returnable CI containers are reused, are they cleaned

using appropriate cleaning procedures and inspected
before reuse? Are previous labels removed or defaced?
8.5.4.3 Delivery and Distribution
Are adequate records maintained for all CI shipments?
Do records allow traceability of the batch to specific

consignees?
8.5.5 Post Delivery Activities
Not applicable to CIs.
8.5.6 Control of Changes
Is there a documented procedure defining the

responsibilities and requirements for the evaluation and
approval of changes? Are records of change evaluations
and review retained?
What is the organisations definition of “significant

operational change”?
Is there a procedure for assessing the impact of significant

changes, in terms of both CI quality and performance?
Does the change control system require customers to be

notified of significant changes?
Page 31
Is the Quality Unit involved in evaluation of changes that
may affect the quality of the CI?
8.6 Release of Products and Services
8.6.1 Laboratory Controls

Is batch release of the CI based on conformance to
• the final specification and
• the intended manufacturing process?
Are there written instructions for performing testing of final

CI that specify methods, equipment, operating parameters,
acceptance specifications?
Are there retained raw data, records of calculations test

results and records of who has performed each test?
8.6.2 Cosmetic Ingredient Testing and Release
Is every CI batch tested and approved before shipment? If

not, has the use of reduced testing been justified?
What controls are applied to assure that the CI conforms to

the documented specifications when the CI is manufactured
using a continuous process?
Is release of CI based on both conformance to specification

and evaluation of the manufacturing process records?
8.6.3 Out-of-Specification Test Results
Are OOS investigations completed and matters resolved

before batch release?
Is there a procedure for investigation of Out-of-

Specification results?
Page 32
How are the results evaluated? Under what conditions may
a result be ignored?
If statistical methods are used in the evaluation of an OOS

are they documented in the relevant procedure?
Has the impact on laboratory operations, other equipment,

batches, products, etc. been considered?
8.6.4 Retained Samples
Are retained samples kept for every batch for an appropriate

interval? How is this interval defined?
Are retained samples appropriately packaged and stored?
Is the retained sample size at least twice the amount
required to perform all specification testing?
8.6.5 Certificates of Analysis
Does the CI manufacturer provide certificates of analysis for

each batch?
Is the quality unit responsible for the Certificate of Analysis?
8.6.6 Impurities
Are impurities and typical levels known? Do impurities

critical to CI quality have appropriate limits established?
Are manufacturing processes adequately controlled in order

to avoid exceeding such limits for quality critical impurities?
8.6.7 Stability
Is stability or historical / retrospective data available to

support the recommended storage conditions?
Page 33
For CIs that have no stability data has a documented
testing or evaluation programme designed to evaluate the
stability characteristics of the CI been undertaken?
8.6.8 Expiry/Retest Periods
Is a retest date and/or an expiration date assigned to the

CI? If so, what is it? Where is it listed so as to inform the
customer?
If an expiration / retest interval has been assigned how has

this interval been determined?
8.7 Control of Nonconforming Product
How are nonconforming CI identified to prevent

unintentional usage or sale?
What records are maintained of nonconforming CI, their

related investigations and corrective actions?
Is there a procedure for determining the fate of final CI that

fails to meet specifications (e.g., reprocessing, re-grading,
release with agreement of the customer, destruction)?
If CI is to be destroyed, is it tracked, controlled, and

destroyed in a timely and appropriate fashion? Are
records of such destruction maintained?
Is there a procedure that describes how a CI can be recalled

from distribution? Are records kept of such activities?
Is this tested at least annually?
Page 34
Is there a procedure for handling returned CIs, including their
identification, and the requirement to evaluate their quality
before reuse or release?
Are records of returned goods maintained?
8.7.1 Reprocessing / Reworking

Does the batch record include records to show that
unplanned blending, reprocessing or reworking has been
performed? Is traceability in these instances maintained?
If reprocessing or reworking is performed, is there a

documented review of risk to CI quality which includes:
• Formation of new impurities
• Requirement for additional testing
• Requirement for revised CI acceptance criteria
• Impact on performance?
Has the equivalence of reprocessed CI been evaluated

against the established standards, specifications and
characteristics?
Page 35
9 PERFORMANCE EVALUATION
9.1 Monitoring Measurement and Evaluation
9.1.1 General
Do monitoring and measuring activities include the quality

management systems as well as parameters that define CI
quality? Do these monitoring and measuring activities lead to
the consideration of opportunities for improvement?
9.1.2 Customer Satisfaction
How is customer satisfaction determined? Are parameters

such as customer complaints and return of CIs covered?
Does this analysis drive improvement activities?
9.1.3 Analysis and Evaluation
What monitoring occurs of the management system process

and process failures? Are these used to assess the need for
improvements?
How are out of trend and process deviations evaluated?

What actions are taken to ensure the CI meets
requirements?
9.2 Internal Audit

Is there an internal quality audit program that covers all areas
of the operation to verify that procedures and policies are
being followed?
Are audits performed at specified intervals?
Are audits scheduled on the importance and status of the
activity performed?
Are internal audits documented?
How is management personnel involved in the audit findings
and associated corrective actions?
Page 36
Who is responsible for implementing the corrective actions?
Are necessary steps taken to correct any areas of non-

compliance based on the findings and recommendations of
the internal audits?
How are corrective actions documented?
Do follow-up audit activities include verification of the
effectiveness of corrective actions?
9.3 Management Review
9.3.1 General
Does Management review include review of compliance to
GMP?
9.3.2 Management Review Input
Do inputs include conformance to requirements of GMP
What measures are used and what data is considered to

perform this analysis?
Are there periodic reviews of key indicators? W hat are these
indicators?
9.3.3 Management review Output
No additional requirements above ISO 9001:2015
Page 37
10 IMPROVEMENT
10.1 General
No additional requirements to ISO 9001:2015
10.2 Nonconformity and Corrective Action
Are procedures for corrective actions implemented to

address the root causes of nonconforming CIs, returns, and
complaints? Do these procedures invoke change control
when implementing the corrective actions?
Are procedures for preventive actions implemented to

address problems at a level corresponding to the risk? Do
these procedures invoke change control when implementing
the preventive actions?
10.3 Continual Improvement
What inputs drive continual improvement activities? How

are these managed?
What procedures are established for investigation of
nonconforming CIs, returns, complaints, etc.? How are
these causes determined and how are appropriate parties,
including management, notified?
Page 38

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EFfCI GMP AUDIT CHECKLIST

Prepared by the European Federation

Personal Care Products Council

Copyright EFfCI 2012, 2017

Purpose and Scope

Copyright © 2017 - The European Federation for Cosmetic Ingredients

Copyright © 2017 - The European Federation for Cosmetic Ingredients

CHECKLIST OBSERVATIONS, FINDINGS, GAPS ACTION STATUS

4 CONTEXT OF THE ORGANISATION

4.1 Understanding the Organisation and its context

Are issues reviewed and in particular is relevant legislation

4.2 Understanding the needs and expectations of interested

4.3 Determining the Scope of the Quality Management

Does the scope of the organisations GMP include a list of

Is the scope of the organisations GMP and QMS defined

Copyright © 2017 - The European Federation for Cosmetic Ingredients

4.4 Quality Management System and its Processes

Copyright © 2017 - The European Federation for Cosmetic Ingredients

5.1 Leadership and Commitment

Copyright © 2017 - The European Federation for Cosmetic Ingredients

5.3 Organisational Roles, Responsibilities and Authorities

Is there an identified Quality Unit?

Are reporting lines for members of the Quality Unit

Does the Quality Unit exist on an organisational chart, does

Is there a written description of the responsibilities of the

Copyright © 2017 - The European Federation for Cosmetic Ingredients

Does the internal audit programme verify that these

Are there written, current job descriptions for personnel

Copyright © 2017 - The European Federation for Cosmetic Ingredients

6.1 Actions to address risks and opportunities

Has the risk assessment process been defined?

Are there other risk assessments?

Who has prepared these risk assessments, one person or a

Are risk assessments maintained and is there evidence of

If the risk assessment recommends additional measures

Is there evidence of evaluation of effectiveness of controls

Are the acceptance criteria for risks made clear?

6.2 Quality Objectives and planning to achieve them

Are there quality objectives which have been set by top

Do these include adherence to GMP?

Are objectives deployed within the organisation?

Copyright © 2017 - The European Federation for Cosmetic Ingredients

6.3 Planning of changes

Is there a documented procedure for the control of

Is the scope of the procedure appropriate – e.g. process,

Does the Quality Unit participate in reviewing changes?

How are changes managed?

What is the organisations definition of “significant change”?

Is there a procedure for assessing the impact of significant

Does the change control system require customers to be

Copyright © 2017 - The European Federation for Cosmetic Ingredients

Is there any evidence of planning resources to meet needs

Are there enough people to manufacture, test, pack and

Did the risk assessment identify that any additional control

What are the controls on access to computer systems which

Copyright © 2017 - The European Federation for Cosmetic Ingredients

Where the CI is exposed, are there adequate measures to

Is there adequate space to ensure CI integrity and to

Are there adequate laboratory facilities to perform required