Implementing ISO 22716 – 90‑Day Action Plan

Implementing ISO 22716 – 90‑Day Action Plan
Cosmetics Industries

Implementing ISO 22716 – 90‑Day Action Plan

Last Updated on October 24, 2025 by Hafsa J.

How to Build a 90-Day ISO 22716 Implementation Plan That Works

Let’s be honest—implementing ISO 22716 can feel overwhelming. Between documentation, training, and audits, many cosmetic manufacturers don’t know where to start or how long it should take.

But here’s the good news: you don’t need a year. You just need structure.

After guiding dozens of cosmetic businesses—from boutique skincare brands to contract manufacturers—I’ve learned that a focused 90-day action plan is often all it takes to build a compliant, audit-ready GMP system.

This article walks you through that plan step by step: what to do each month, how to manage your time, and where to use proven tools to save effort.

By the end, you’ll have a clear roadmap to achieve ISO 22716 compliance without confusion or chaos.

Step 1: Assess & Plan (Weeks 1–2) – Know Where You Stand Before You Start

The first two weeks set the tone for everything that follows. Don’t rush this part.

Start with a Gap Analysis. Compare your current operations against the ISO 22716 requirements. Look closely at documentation, hygiene, traceability, and training.

Then, define your scope:

  • Which production areas or product lines are covered?
  • Do subcontractors or testing labs fall within your system?

Next, assign roles. Every task needs an owner—quality, production, maintenance, and warehouse should each know their part.

Create your ISO 22716 Project Plan with tasks, deadlines, and responsibilities. Keep it simple but visible—ideally in a shared tracker.

Pro Tip: Two weeks is enough to assess, document the gaps, and set direction. Clarity now saves rework later.


Implementing ISO 22716 – 90‑Day Action Plan Step 2: Build Documentation (Weeks 3–6) – Create the Backbone of Your GMP System

Documentation is where ISO 22716 becomes real. This is the foundation auditors will examine, so aim for clear, practical procedures—not textbook language.

Use a ready-made ISO 22716 Template Toolkit to save time. Customize the following key documents:

  • Quality Policy and GMP Commitment
  • SOPs for cleaning, equipment, production, deviations, and complaints
  • Records and forms for traceability and maintenance
  • Checklists for hygiene and storage controls

If you already run ISO 9001 or ISO 14001, integrate shared elements like document control or internal audits instead of duplicating them.

Pro Tip: Write documents in your team’s voice. The simpler it is to read, the easier it is to follow.

Common Mistake: Copy-pasting generic SOPs from the internet. Auditors spot those instantly. Each procedure should reflect your actual workflow.

Step 3: Train & Engage Staff (Weeks 7–8) – Turn Procedures into Daily Habits

Now that the system is written, it’s time to bring it to life.

Plan short, focused GMP training sessions for production and quality staff. Keep them practical: show real examples of cleaning, documentation, and labeling.

Topics to cover:

  • Personal hygiene and protective clothing
  • Equipment cleaning and calibration
  • Batch record completion
  • Handling deviations and reporting issues

Keep sessions under 30 minutes. Short bursts work better than long seminars.

Pro Tip: Measure competence, not attendance. Ask supervisors to observe if staff apply what they learned on the shop floor.

Common Mistake: Treating training as a formality. The best-written SOP is useless if the person following it doesn’t understand why it matters.

Step 4: Run Internal Audits & Correct Gaps (Weeks 9–10) – Test Your System Before Auditors Do

With training complete, it’s time to put your system to the test.

Conduct an Internal Audit using your ISO 22716 checklist. Check that documentation matches real practice. Look at cleaning records, batch documentation, equipment logs, and complaint handling.

Document all findings—major, minor, or opportunities for improvement. Then create a Corrective and Preventive Action (CAPA) plan assigning responsibility and deadlines.

Pro Tip: Treat this like a rehearsal. The goal isn’t perfection—it’s readiness.

One cosmetics lab I worked with cut its external audit findings in half just by running two internal reviews before certification. Small adjustments made a big difference.

Step 5: Final Review & Certification Prep (Weeks 11–12) – Get Audit-Ready

At this stage, your GMP system should be in place and functioning. Now it’s about polishing.

  • Review document control: every SOP should have version numbers, approvals, and references.
  • Verify training and competence records.
  • Ensure calibration, cleaning, and batch logs are up to date.
  • Conduct a management review to evaluate readiness.

If certification is required, contact your chosen certification body and confirm your audit date. For smaller businesses, you can also prepare a self-declaration package with full documentation and records.

Pro Tip: Use a final “audit readiness checklist” to verify everything—from premises and labeling to complaint records and traceability.

Keep Momentum After 90 Days – Continuous Improvement & Maintenance

Once you’re certified (or self-declared), the real work begins—maintenance.

Set a simple rhythm:

  • Monthly GMP meetings to track issues and improvements
  • Biannual refresher training for staff
  • Annual internal audits and management reviews

Link improvements to business results—fewer complaints, better efficiency, and reduced waste. That’s where GMP turns into profit.

Pro Tip: Treat ISO 22716 as a continuous business tool, not a one-time compliance project.

FAQs – Common Questions About the 90-Day ISO 22716 Plan

1. Can small cosmetic companies really achieve ISO 22716 compliance in 90 days?
Yes. With clear priorities, templates, and a disciplined plan, even small teams can get there in three months.

2. Do we need a consultant to follow this plan?
Not necessarily. A good documentation toolkit and internal commitment are enough for most SMEs.

3. What happens after certification?
Maintain your system through regular audits, training, and updates. Compliance isn’t a finish line—it’s an ongoing cycle.

Your Roadmap to a Compliant, Confident GMP System

Implementing ISO 22716 doesn’t have to drag on for months or cost a fortune. When you follow a structured 90-day plan, you turn uncertainty into progress—quickly and confidently.

At QSE Academy, we’ve helped hundreds of cosmetic manufacturers build strong GMP systems using this exact phased approach—clear steps, smart tools, and real accountability.

If you’re ready to start your own 90-day journey, grab the ISO 22716 Implementation Toolkit or schedule a consultation with our experts.

[Download Your Toolkit] or [Talk to a GMP Consultant]

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