Auditing a Vietnam Cosmetics Factory: Checklist and Four Traps

An audit checklist usually has five parts

Customer audits and third-party audits tend to work from the same list: legal entity, certificates, production and QC records, warehouse zoning, and facility and hygiene controls. We prepare against that list rather than assembling documents once an audit is booked — and that cuts both ways: if a factory only starts "getting the paperwork together" after you book, that is a signal worth writing down.

• Legal entity — business licence, registered name and tax code, and whether they match the contract and the customs declaration.
• Certificates — which ones, what numbers, valid until when, and what the scope actually says.
• Production and QC records — whether a batch can be traced back to materials and operators.
• Warehouse zoning — raw material, packaging and finished goods separated; who logs temperature and humidity.
• Facility and hygiene — clean areas, movement flow, water system.

Three credentials: what each proves and what it does not

Read these together with the right-hand column. An audit that only asks "do you have the certificate" has not audited anything.

All three numbers are searchable. To see originals, state the purpose and an inspection can be arranged during evaluation — scans are not published online, to prevent them being reused.

Trap one: looking for the certificate and not the scope line

The scope printed on both the ISO 9001 and the CGMP certificate goes only as far as wet cosmetics. Pressed powders and dry-process work can be run on the lines, but they sit outside what the certificates cover.

When you show a certificate to a regulator or a large customer, they read the scope line. For a category outside it, the certificate offers no support — "can be made" and "in scope" are two different things.

So the question at audit is: what does your certificate scope say? A supplier who cannot answer that, or who says "it covers everything", is holding a piece of paper.

Trap two: reading FDA facility registration as "FDA approval"

FDA never approves a cosmetic formula or product. Facility registration only puts the site address into FDA’s system as a filing under MoCRA — the registration itself says nothing about whether any product conforms.

There is a more practical point: it expires. This registration ran 2024-05 to 2026-05 and has lapsed. The accurate phrasing is "previously registered", not "holds FDA registration".

If a factory tells you it has "FDA certification", do not treat it as a translation slip. Ask one follow-up — is that facility registration or product approval? The answer tells you what you are dealing with.

Trap three: a test report covers that sample and that run only

Reports are issued and stamped by SAIGONSTC (Saigon Hi-Tech Analysis Centre, VILAS 943, ilac-MRA mutual recognition); the plant only submits the sample. That single fact defines its nature: the subject of the report is a sample, not a factory.

The original usually carries two lines — "sample taken by the client" and "sample name and details provided by the client". Those are not boilerplate disclaimers; they draw the boundary of effect at that one item on that one occasion.

So read three things rather than asking whether a report exists: the report date, whether the tested item is the one you are buying, and whether the test methods match your target market’s requirements.

Trap four: social-compliance audits, and most Vietnamese SMEs do not hold one

BSCI and Sedex are not mandatory for cosmetics, but they are frequently a hard gate in European retailers’ supplier onboarding. They audit labour, working hours, safety and environment — not product quality.

We do not hold either. No BSCI, no Sedex, and no third-party social compliance report. Where a checklist includes them, we mark them "not held" rather than substituting another certificate.

This gets its own section because it is the easiest thing to blur. If you are running a European retailer’s private label, a gap here stops you at onboarding regardless of how well the formula and price were negotiated. Knowing two weeks earlier leaves time to change supplier or channel.

On the day: what you can see, and what you cannot

Every position you can walk to: the site, the emulsifying room, the packaging store, the warehouse, the raw-material store and the finished-goods store. You see production as it is running, not a staged sample room. The tour route does not pass through the offices, dormitories or canteen.

Three things are not open: formulations other clients are currently running, other clients’ packaging and artwork, and supplier labels on incoming materials. Not secrecy — that information belongs to other customers.

We have no edited promotional video: if you want to see the lines, see them on site rather than in a recording presented as live. You can ask for this directly when booking — request the running line, not the sample room. A factory comfortable with that usually has reason to be.

Twelve questions to take on site

Write these down and work through them on the day. Every answer here has a reference point on this site, and the list works just as well on any other Vietnamese factory.

1. What is the registered company name and tax code? (Ours is 1101978460.)
2. Read out the scope line on your ISO 9001 certificate, word for word.
3. What is the CGMP number, when does it expire, and where is the renewal?
4. Is the FDA registration facility-level or product-level, and what period does it cover?
5. Which item was your most recent third-party report on, and when? What do the two disclaimer lines on the original say?
6. Do you hold a BSCI or Sedex number? If not, how do you take European private-label work?
7. Can a batch record be traced to materials and operators? Pull one now.
8. How are the raw-material and packaging stores zoned, and who logs temperature and humidity, for how long?
9. How many tonnes of purified water a day, and is that enough for my volume?
10. What is the smallest emulsifying tank, and which band does my volume land in?
11. How many sampling rounds are free, how is round four charged, and when does the clock start?
12. Which port do you ship from, and on what Incoterm? (Ours is FOB Cat Lai, Ho Chi Minh City.)

When to conclude the factory is not a fit

Three kinds of request get sent back on day 0 here: the category does not fit the lines, the volume sits below the MOQ, or the target market asks for something we cannot cover. That is our own practice.

Turn the same measure on any supplier you assess. If a factory answers "yes" to everything you ask, do not celebrate — most likely they did not understand, or do not intend to deliver. A factory willing to say "we cannot do this one" in the first conversation makes the remaining yeses worth something.

Our boundaries are set out on what we turn down, including why dry-process colour cosmetics are "makeable but out of scope".

What a quotation must contain

The audit ends on the quotation. Without these fields the price is not comparable — two quotes that look 10% apart often differ on whether packaging is inside the price and whether the port is the same one.

These six are also the standard we hold our own quotations to, matching documents we issue.