With the implementation of the new 2025 cosmetics regulations, the shampoo OEM (Original Equipment Manufacturing) market faces new challenges: on one hand, the National Medical Products Administration (NMPA) has strengthened supervision over production processes, requiring factories to add “environmental production records” and “formula traceability ledgers”; on the other hand, consumers’ attention to “green production” and “formula safety” has soared. Choosing the wrong factory not only exposes brands to compliance penalties but also erodes user trust.
However, based on my 10 years of experience in the daily chemical OEM industry, 85% of brands still only focus on “price” and “production capacity” when selecting shampoo factories, ignoring critical 2025-added dimensions such as “environmental qualifications” and “formula confidentiality mechanisms.” This leads to consequences ranging from regulatory rectification orders to formula leakage and imitation by competitors. Aligned with Google’s E-E-T-A (Experience, Expertise, Authority, Trust) principles, this guide uses real cases to analyze new pain points, reveals 3 uncommon screening criteria rarely mentioned by peers, and provides the latest 2025 factory verification methods to help you quickly identify compliant, reliable shampoo factories.
I. In 2025, 3 New Pitfalls Are Eroding Brand Costs When Choosing Shampoo Factories (With Real Cases)
Under the new regulations, “hidden risks” of shampoo factories have become more prominent. The following 3 new pitfalls are the most frequently reported issues by brands this year, and each case contains easily overlooked screening details:
1. Environmental Non-Compliance Pitfall: No Pollutant Discharge Permit, Leading to Factory Seizure and Order Disruption
A brand focusing on “natural hair care” partnered with a shampoo factory in March 2025. During production, the factory was seized by environmental authorities for “failing to obtain a pollutant discharge permit,” leaving 30,000 produced shampoo bottles stuck in the warehouse and forcing the suspension of a subsequent 20,000-bottle order. The brand not only lost 150,000 RMB in raw material costs but also faced penalties from e-commerce platforms for delayed shipments. Investigation later revealed that the factory had skipped applying for the “cosmetics production pollutant discharge permit” required by the 2025 new regulations to cut costs, relying solely on an outdated environmental impact assessment report to evade inspections.
Key to Avoiding This Pitfall: In 2025, always verify a factory’s “Cosmetics Production Pollutant Discharge Permit” and check its “environmental penalty records from the past 6 months” on the local Environmental Protection Bureau’s official website. Avoid cooperating with factories with environmental integrity violations.
2. Formula Leakage Pitfall: Factory Sells Formulas Privately, Allowing Competitors to Capture Market with Lower Prices
A client specializing in high-end anti-hair loss shampoo entrusted their exclusive formula to a factory for production last year. This year, they discovered a competitor launching a product with nearly identical ingredients and efficacy at half the price. Investigation showed that a factory technician had leaked the formula to the competitor—and since no “formula confidentiality agreement” was signed, the client could not pursue legal responsibility. Ultimately, the client lost its formula advantage, leading to a 40% drop in quarterly sales.
Key to Avoiding This Pitfall: Sign a formal “formula confidentiality agreement” before cooperation. Clearly require the factory to establish a “hierarchical formula management system” (e.g., separating R&D and production departments, encrypting formula documents) and specify compensation for leakage (suggested minimum: 500,000 RMB).
3. New Regulation Filing Pitfall: Lack of Understanding of 2025 Filing Rules, Delaying Product Launch by 3 Months
A startup brand partnered with a factory to produce shampoo in January 2025. The factory claimed it could “assist with filing,” but due to its lack of mastery of the “raw material safety information filing guidelines” required by the 2025 new regulations, the filing materials were rejected by the NMPA three times. From production completion to final filing approval, the process took 3 months, causing the brand to miss the Spring Festival marketing peak and lose 80,000 RMB in promotion costs.
Key to Avoiding This Pitfall: Ask the factory to provide “2025 successful filing cases” (e.g., filing certificates from the past 3 months) and test its familiarity with “Safety Data Sheet (SDS) filing” for raw materials. Avoid factories incapable of meeting filing requirements, which cause launch delays.
II. In 2025, Reliable Shampoo Factories Must Meet These 3 Uncommon Criteria Beyond Basic Qualifications
Combining the 2025 new regulations and the factory-selection logic of top-tier brands, reliable shampoo factories must meet 3 uncommon verification criteria in addition to basic requirements like “compliant qualifications” and “controllable raw materials.” These criteria are the core difference between average and high-quality factories:
1. Environmental Compliance: 2 Core Certificates + 1 Daily Record, None Optional
In 2025, environmental compliance is a “survival line” for shampoo factories. High-quality factories must have:
- Core Certificates: A “Cosmetics Production Pollutant Discharge Permit” (clearly marked with the category “shampoo and hair care product production”) and a “wastewater test report from the past 6 months” (issued by a CMA-certified institution—CMA stands for China Inspection Body and Laboratory Mandatory Approval—with COD and ammonia nitrogen indicators meeting the Emission Standards for Pollutants from Cosmetics Industry).
- Daily Records: Factories must establish an “environmental production ledger” to record “energy consumption data” (e.g., water and electricity usage) and “waste disposal records” (e.g., recycling certificates for waste raw material barrels) of each production batch, which must be available for regulatory inspection at any time.
Difference from Average Factories: Average factories only provide outdated environmental impact assessment reports, while high-quality factories proactively share real-time environmental data (e.g., operation monitoring of workshop waste gas treatment equipment) to reduce brands’ compliance risks.
2. Formula Confidentiality: A Three-Level Control Mechanism to Prevent Leakage
For brands with exclusive formulas, a factory’s “formula confidentiality capability” is critical. High-quality factories must establish:
- Personnel Control: R&D and production staff sign “non-compete agreements” prohibiting part-time work at competitor factories during the cooperation period.
- Document Control: Formula documents are “encrypted for storage,” accessible only to authorized personnel, with traceable access records (e.g., operation time, staff name).
- Production Control: “Batch-wise formula dosing” is adopted during production to prevent workers from accessing the complete formula ratio.
3. New Regulation Filing: Familiarity with 2025 Filing Details and Express Service Capability
The 2025 NMPA regulations require additional “raw material Safety Data Sheets (SDS)” and “production process traceability records” for shampoo filing. High-quality factories must:
- Personnel Allocation: Have at least 2 filing specialists familiar with the new regulations, capable of assisting brands with SDS filing and production record uploads.
- Express Service Capability: Offer “expedited filing services” (e.g., completing filing within 7 days) and address filing rejections (e.g., quickly supplementing raw material test reports).
- Case Support: Have at least 5 successful shampoo filing cases from the past 3 months, with filing certificates available for verification.
III. Verifying Shampoo Factory Capabilities in 2025: 2 New Tools + 1 Key Action
Under the new regulations, on-site inspections alone are insufficient. Combine “online tool checks + offline key verification” to ensure the factory’s capabilities are genuine:
1. 2 New Online Tools to Quickly Identify Factory Risks
- NMPA “Cosmetics Production Supervision Platform”: Added a “factory compliance score” in 2025. Enter the factory name to view scores for “environmental compliance,” “filing assistance,” and “quality sampling” (scores above 80 indicate high-quality factories; scores below 60 require caution).
- National Pollutant Discharge Permit Management Information Platform: Check the validity period and scope of the factory’s “Cosmetics Production Pollutant Discharge Permit,” as well as “environmental penalty records” (exclude factories with penalties in the past year).
2. 1 Key Offline Action: Check the “Production Traceability Ledger”
During on-site inspections, in addition to visiting workshops and warehouses, insist on viewing the factory’s “2025 production traceability ledger for a specific shampoo batch.” Focus on 3 points:
- Whether “raw material sources” are recorded (e.g., supplier name and batch number of amino acid surfactants, verifiable with purchase certificates).
- Whether “environmental production data” is included (e.g., wastewater discharge volume and treatment results for the batch).
- Whether “filing-related information” is marked (e.g., the batch’s filing number and upload time).
If the factory cannot provide a complete ledger, its production management is substandard, and compliance risks exist.
IV. 2025 Shampoo Factory Screening Checklist: 5 Core Indicators—Cooperate Only If 4 Are Met
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Screening Dimensions
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2025 Core Verification Criteria
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Compliance Status (Yes/No)
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Environmental Compliance
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1. Possesses “Cosmetics Production Pollutant Discharge Permit”; 2. No environmental penalties in the past 6 months; 3. Can provide environmental data from the production traceability ledger
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Formula Confidentiality
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1. Signs formal “formula confidentiality agreement”; 2. Has hierarchical formula control mechanisms (e.g., document encryption, staff non-compete agreements)
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New Regulation Filing
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1. Has at least 5 successful shampoo filing cases in the past 3 months; 2. Can complete expedited filing within 7 days
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Basic Qualifications
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1. Valid “Cosmetics Production License” and “GMPC Certification”; 2. Production scope includes “shampoo and hair care products”
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After-Sales Support
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1. Factory bears full compensation for losses caused by environmental or filing issues; 2. Provides rework/replenishment solutions for quality issues within 48 hours
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Conclusion
In 2025, “environmental compliance,” “formula confidentiality,” and “new regulation filing” have become core dimensions for selecting shampoo factories. Ignoring these uncommon criteria means even low prices or high production capacity cannot avoid risks. The cases, standards, and checklists in this guide are derived from real cooperation experiences after the 2025 new regulations took effect and can be directly applied to factory screening.
