5 Questions To Ask a Gel Polish Manufacturer Before Signing a Deal

I’ll say the quiet part out loud: the gel industry has a paperwork problem.

Short answers. Pretty PDFs. “Compliant” stamped everywhere. And then, when a batch gives clients swollen cuticles or a customs hold hits your launch, suddenly nobody “owns” the claim that got printed on your label.

So. Five questions. Not cute questions. The kind that force a real manufacturer to show their spine.

And yes—if you’re comparing factories right now, keep your shortlist tight and your standards mean. Start by browsing a real catalog of SKUs and formats (bottles, jars, bulk kg) so you’re not negotiating in the abstract. Here’s one reference point: gel polish catalog for private label SKUs.

Question 1: “Show me the compliance path for the exact markets I’m selling in—US and/or EU. What’s your evidence?”

Three words. Prove it.

Here’s the hard truth: cosmetics aren’t “FDA approved.” If a supplier says that with a straight face, I assume they’ll lie about anything else too.

In the US, MoCRA moved cosmetics into a more serious era—facility registration and product listing are no longer “nice to have.” FDA publicly reminded industry that the registration and listing deadline (per its compliance policy) was July 1, 2024. That’s not gossip; it’s on FDA’s own site: FDA’s June 13, 2024 MoCRA deadline update. (U.S. Food and Drug Administration)

In the EU, you’re living under Regulation (EC) No 1223/2009 reality: CPNP notification, PIF, responsible person, labeling rules—and ingredient decisions that can flip fast when a substance gets a CMR classification.

What I ask for (minimum):

US: facility registration confirmation, product listing approach (who files—manufacturer or “responsible person”), adverse event process.
EU: proof they can support a PIF (Product Information File) package and labeling that matches EU language + warning rules.
GMP: ISO 22716 alignment (or equivalent internal SOPs), plus batch traceability (raw material lot → fill line → finished goods).

If you want a sanity check on what “serious QA” looks like in practice, compare their answers against a published QA framework like this: quality assurance process for gel products.

Question 2: “What’s in it—exactly—and what are you doing about the allergy magnets?”

This is where deals go bad quietly.

Gel chemistry is not mysterious, but it is unforgiving. One repeat offender: 2-hydroxyethyl methacrylate (HEMA, C₆H₁₀O₃), a reactive monomer used in many nail systems. PubChem has the identifier and formula if you ever need to verify what a supplier is hand-waving: HEMA (C₆H₁₀O₃) on PubChem. (pubchem.ncbi.nlm.nih.gov)

Now the part most factories don’t volunteer: how messy real-world labeling gets.

A 2024 market survey in Contact Dermatitis reviewed 394 nail products and found HEMA in nearly 60%—and widespread EU compliance failures on mandatory warnings (including missing “professional use only” and “can cause an allergic reaction” language on a large share of HEMA-containing products). Read it yourself: 2024 HEMA prevalence + EU compliance violations (PubMed). (PubMed)

So I ask manufacturers to answer like engineers, not marketers:

Which monomers are in the base resin system? (HEMA, HPMA, IBOA, etc.)
What’s your allergen strategy: lower-HEMA, HEMA-free, or strict “pro-only” labeling discipline?
What’s your cure spec (lamp wattage, wavelength bands like 365/405 nm, time per layer) and how do you validate it?
Do you provide full INCI, SDS, and batch CoA—without begging?

If you’re sourcing private label, this is also where you ask about custom formulation boundaries. Some suppliers only “tint bases.” Others can actually tune viscosity, pigment load, self-leveling, soak-off speed, and odor profile. If they offer real customization, it should be described like a process, not a vibe: OEM/ODM services for custom gel formulation and labeling.

Question 3: “Walk me through your QC gates. What fails a batch, and who eats the cost?”

Most contracts hide the ugly part: what happens when product doesn’t behave.

I want to hear specific gates and numbers, like:

Incoming raw material checks (viscosity range, inhibitor levels, pigment dispersion, photoinitiator content).
In-process controls (fill weight tolerance, cap torque, label adhesion, lot coding).
Finished goods tests (appearance, sedimentation stability, cure performance, soak-off behavior, odor, brush performance if bottled).
Retention samples kept for X months, tied to each lot.

If they can’t explain a rejection process, you don’t have a supplier—you have a lottery ticket.

And I always ask one mean follow-up:

“If this lot fails after arrival, can I reject it? What’s the timeline? Replacement vs refund? Shipping paid by whom?”

A real manufacturer will already have a written deviation/CAPA workflow. A reseller will change the subject.

Question 4: “Give me your MOQ + lead time—by SKU type—and prove you can hit it when materials get tight.”

Here’s what I’ve learned: “Lead time” is two numbers, not one.

Lab/approval time (shade matching, sample rounds, label proofing)
Production + QA + shipping time (actual capacity)

So I pin it down:

MOQ for stock colors vs custom shades vs bulk kg.
MOQ for bottles vs jars (packaging constraints matter).
Lead time with one sample round vs three sample rounds.
What happens when a raw material gets constrained (pigments, photoinitiators, bottles)? Do they have alternates pre-qualified?

And yes, I ask for on-time delivery metrics. Even a crude monthly dispatch log beats a promise.

If you’re selling multiple product families (base/top, builder, rubber base, BIAB, poly gel), your MOQ/lead-time mix changes fast. Having a supplier that can cover multiple categories under one QA system can reduce chaos later. Example category map: gel polish product line overview and broader site context at Best Gel Polish.

Question 5: “What’s in the contract that protects me when things change—formula, labeling law, or ownership?”

This is where skeptical buyers win.

Because formulas change. Laws change. People change jobs. Your contract is what’s left.

At minimum, I want:

Change control: they can’t tweak formula, supplier, or process without written notice + approval.
Specs as an appendix: viscosity range, cure spec, pigment tolerance, acceptable odor range (yes, you can define it), packaging spec.
IP clarity: who owns custom shades, custom names, and label artwork files.
Claims discipline: no unapproved claims on label, carton, inserts, or listings.
Compliance responsibilities: who maintains PIF support, SDS updates, and market-specific labeling.
Remedies: refund/replace terms, defect definition, and dispute process that isn’t a dead end.

If you need a reminder of how “official” guidance is worded in the US right now, skim the Federal Register notice for FDA’s MoCRA registration/listing guidance: Federal Register—MoCRA registration & listing guidance availability (Dec 12, 2024). ([Federal Register][4])

A fast vetting table you can actually use

What you’re vetting	What to ask for	What “good” looks like	Red flag answer
US compliance (MoCRA)	Facility registration + product listing plan + adverse event process	Clear owner (manufacturer vs responsible person), documented workflow	“FDA approved” or “We don’t do US paperwork”
EU compliance	PIF support docs + labeling/warnings discipline	They know CPNP/PIF basics and warning language requirements	“EU is easy—same label everywhere”
Ingredient transparency	Full INCI + SDS + CoA per lot	Immediate, consistent, lot-tied documents	“Trade secret” used to hide basics
Cure performance	Lamp spec (365/405 nm), time per layer, validation method	Repeatable, tested parameters	“Any lamp works”
QC reality	Reject criteria + CAPA + retention samples	They can describe failure modes and actions	“We never have issues”
Commercial reliability	MOQ/lead time split by SKU type	Numbers by product type + capacity logic	One vague lead time for everything

FAQs

What should I ask a gel polish manufacturer before signing a contract?

You should ask a gel polish manufacturer for a market-specific compliance plan, full ingredient transparency (INCI/SDS/CoA), documented QC gates, MOQ/lead-time by SKU type, and contract clauses covering change control, defects, and ownership—so you can verify they can legally supply, consistently produce, and financially stand behind the exact product you’ll sell. (U.S. Food and Drug Administration) After that, ask for proof, not promises: sample COAs, batch logs, and a written rejection/remedy process.

How do I verify cosmetic manufacturing compliance for the US and EU?

Cosmetic manufacturing compliance means the facility can meet the legal duties tied to your target market—US MoCRA registration/listing and adverse event handling, and EU Cosmetics Regulation obligations like correct labeling, documentation support, and supply-chain traceability—using documented procedures rather than informal assurances. (U.S. Food and Drug Administration) In practice, you verify by reviewing their documents, assigning responsibility (who files what), and baking change control into the contract.

What’s a normal gel polish MOQ and lead time for private label?

MOQ and lead time are the minimum order quantity and total time from approval to shipment for a specific SKU configuration (formula + shade + pack + label), and they vary sharply between stock colors, custom shades, and bulk formats because packaging availability, lab rounds, and line scheduling change the critical path. If a supplier can’t split numbers by SKU type, they’re guessing—or hiding capacity limits.

Which ingredients are the biggest risk signals in gel nail products?

Risk-signal ingredients are substances that raise allergy, labeling, or regulatory exposure—most commonly reactive (meth)acrylates like HEMA and related monomers—because they can drive allergic contact dermatitis reports and trigger mandatory warning language requirements that many market listings and packages still get wrong. (PubMed) Your job isn’t panic. It’s disclosure + correct labeling + validated curing instructions.

What documents should a gel polish supplier provide for every batch?

Batch documents are lot-specific records—typically a Certificate of Analysis (CoA), Safety Data Sheet (SDS), and traceability identifiers—that prove the product matches agreed specifications and can be tracked from raw materials through filling, labeling, and shipment, which is essential for recalls, complaints, and market surveillance. ([Federal Register][4]) If they “can provide later,” assume you’ll never get them when it matters.

Conclusion

If you’re vetting a gel polish manufacturer right now, don’t start with small talk. Start with proof.

Browse a real SKU set first (private label gel polish catalog), then benchmark the supplier’s answers against a documented QA approach (quality assurance) and a clear customization workflow (OEM/ODM services). When you’re ready to pressure-test your shortlist with specific questions, send your requirements and target markets here: contact a gel polish manufacturer.

[4]: https://www.federalregister.gov/documents/2024/12/12/2024-29237/registration-and-listing-of-cosmetic-product-facilities-and-products-guidance-for-industry ” Federal Register \:: Registration and Listing of Cosmetic Product Facilities and Products; Guidance for Industry; Availability “