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Growing the operation

Having somebody else make it

Updated

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Contract manufacturing is more attractive here than in any other property in this estate, and for a reason that is not about volume.

A stronger case than in most crafts

A co-packer buys raw materials at industrial scale, which solves the drum-minimum problem that makes small-scale production expensive.

They already have the filling line, the induction sealer and the labeling equipment.

And they have the regulatory infrastructure: safety data sheets, hazard classification, and often transport classification too.

Which means the case for contracting out arrives earlier here than elsewhere.

What they need from you

A formula in percentages with supplier and grade per line.

A process with order of addition, mixing and pH targets.

A specification with tolerances, so there is something to accept or reject against.

Approved packaging components and compliant label artwork.

Which is why the recipe-to-product work pays twice: a maker with a document can be quoted in a week.

Who holds the regulatory position

The clause to settle explicitly.

Whose name is on the label as the responsible firm, and therefore who owns the labeling compliance.

Who produces and maintains the safety data sheet.

Who is responsible for the California ingredient disclosure, and who maintains the web page.

And if the product ever carries pesticidal claims, whose EPA establishment number applies, because a registered pesticide must be produced in a registered establishment.

Their infrastructure does not remove your responsibility as the firm named on the label.

Minimums

Usually thousands of units per run per SKU, and a run cannot be topped up in a hurry.

Plan inventory against their lead time rather than your sales rate, and remember that a reformulation means a new run rather than an adjustment.

References

US Environmental Protection Agency. Pesticide Registration Manual, Chapter 4: Additional Considerations for Antimicrobial Products. What an antimicrobial pesticide is, and what registration requires. epa.gov
OSHA Hazard Communication Standard, 29 CFR 1910.1200, which requires a safety data sheet and GHS labeling for hazardous chemicals supplied for workplace use. osha.gov
California Cleaning Product Right to Know Act of 2017 (SB 258). Designated products — air care, automotive, general cleaning, and polish or floor maintenance products — must disclose ingredient information on the product website from January 1, 2020 and on the label from January 1, 2021. leginfo.ca.gov
Written from the federal regulation and agency guidance named on each page, not from a laboratory or a legal practice. Whether a particular product and a particular label make a cleaner or a pesticide is a determination about your product, and this is not that determination.