Why ISO 22716 Cannot Be UKAS‑Accredited — And How Apex Global Quality Ensures Full Integrity Without It

ISO 22716:2007 is one of the most widely requested standards in the cosmetics sector, yet it remains one of the most misunderstood when it comes to accreditation. A recurring question we receive is:

“Are your ISO 22716 certificates UKAS‑accredited?”

The short answer is no — but not because of anything lacking in our process. The reason is far simpler:

UKAS does not accredit ISO 22716 certification.
They never have, and currently have no programme to do so.

This means no certification body in the UK — large or small — can offer a UKAS‑accredited ISO 22716 certificate, because the accreditation simply does not exist.

This is not a matter of interpretation or opinion; it is a structural limitation of the accreditation system itself.

Why UKAS Doesn’t Accredit ISO 2271

ISO 22716 is a guidance standard, not a management system standard. Because of this, it does not fall under ISO/IEC 17021‑1 (the accreditation standard used for ISO 9001, ISO 14001, etc.).

Instead, if accreditation were to exist, it would fall under ISO/IEC 17065, which is used for product and process certification schemes.

This distinction is confirmed in an independent article by Oxebridge Quality Resources, which describes a case where a UK certification body was misled by a fake accreditation provider into believing ISO 22716 could be accredited under ISO 17021‑1. The article states:

“ISO 22716 is a guidance document… To offer accredited ISO 22716 certificates, the CB would have to pursue ISO 17065 accreditation, and not ISO 17021‑1.”

The same article also confirms that UKAS does not offer accreditation for ISO 22716, and that some organisations have been targeted by “accreditation mills” selling illegitimate accreditation for this standard.

The certificafation body referenced is us and we are not afraid to admit it because we learnt from it and are better off now.

Our Internal Audit Identified a Fake Accreditation Body

During our early development, we engaged an external internal audit provider to assess our management system. During this audit, it was identified that the accreditation body we had initially been in discussions with was, in fact, a non‑recognised accreditation mill — the organisations referenced in the Oxebridge article.

The internal audit report clearly documented:

  • The accreditation body was not recognised by UKAS, IAF, EA, or any national authority
  • They were offering ISO 17021‑1 accreditation for ISO 22716 — something that is structurally impossible
  • Their practices matched known patterns of accreditation scams
  • Proceeding with them would have compromised impartiality, credibility, and legal standing

We are fully transparent about this and are willing to publish the internal audit report in full, on request by potential and existing clients.

This experience reinforced our commitment to building a legitimate, standards‑aligned, future‑proof certification system — not a shortcut, not a badge, and not a façade.

How Apex Global Quality Ensures Integrity Without UKAS Accreditation

Even though UKAS does not accredit ISO 22716, we have built our certification scheme to the same level of rigour expected of an accredited body.

1. Our system is aligned to ISO/IEC 17065 (the correct accreditation standard)

We operate under a structured ISO 17065‑aligned management system, including:

  • Impartiality safeguards
  • Conflict‑of‑interest controls
  • Certification decision separation
  • Risk management processes
  • Auditor competence and qualification controls
  • Documented scheme rules and governance

This ensures the same protections and integrity you would expect from a UKAS‑accredited body.

2. All audits are performed by UKAS‑certification‑body auditors

Our auditors actively work with, or have previously worked with, recognised UKAS bodies such as:

  • Intertek
  • SGS
  • LRQA
  • TÜV

This ensures:

  • Technical depth
  • Audit discipline
  • Evidence‑based assessment
  • Consistency with accredited‑body expectations

3. Impartiality is strictly protected

As a qualified BRCGS, ISO 22716 and ISO 9001 auditor myself, I am not permitted to audit clients where I have commercial or scheme‑management involvement. This is a core ISO 17065 requirement, and we follow it strictly.

All audits are conducted by independent auditors within our network.

4. Our approach is practical, transparent, and compliance‑focused

We avoid unnecessary bureaucracy and focus on:

  • Clear interpretation of ISO 22716
  • Practical implementation guidance
  • Evidence‑based conformity assessment
  • Transparent communication throughout the process

Many clients choose us after comparing our approach with larger certification bodies, often citing our responsiveness, clarity, and technical competence.

Future Accreditation Plans

While UKAS does not accredit ISO 22716, we are actively preparing for UKAS accreditation for BRCGS certification, which is UKAS‑accreditable, but this is a while off.

By building our system to ISO 17065 from the start, we ensure:

  • Minimal changes when we expand into accredited schemes
  • A “right‑first‑time” approach
  • A future‑proof certification infrastructure

This means clients benefit today from a system built to accredited‑body standards, even where accreditation is not available.

Independent Evidence Supporting Our Position

To ensure full transparency, we reference:

  • Oxebridge article confirming UKAS does not accredit ISO 22716 and warning about accreditation mills
  • Our internal audit report, which independently identified the accreditation‑mill issue and confirmed ISO 17065 as the correct standard for any future accreditation

Both pieces of evidence reinforce that:

  • We have taken the correct path
  • We have avoided the pitfalls that have affected other organisations
  • Our system is built on integrity, not shortcuts

Closing Reassurance

Apex Global Quality provides ISO 22716 certification with the same level of rigour, impartiality, and governance expected of an accredited certification body — even though UKAS does not accredit this particular standard.

Our commitment is simple:

  • Technical accuracy
  • Transparent governance
  • Independent auditing
  • Future‑proof system design
  • Zero tolerance for accreditation mills or shortcuts

Quality isn’t a department

I know this might ruffle some feathers, but hear me out. My perspective comes from years of firsthand experience as an auditor, consultant, and employee collaborating with diverse third parties across various industries. What I’ve consistently observed is a fundamental misunderstanding of where quality truly resides within an organization.In most businesses, the quality department operates within a familiar hierarchy: a quality manager overseeing supervisors, controllers, and lab technicians, for instance. Their typical remit involves conducting secondary assessments—or sometimes even the primary ones—on materials, products, stock items, and processes, all in the name of ensuring adherence to established standards. But here’s the crux of my argument: quality should not be confined to a single department; it must be the inherent responsibility of every individual within the organization.While the traditionally assigned quality department undeniably plays a vital role in running validation, verification, and release processes, the very essence of quality needs to be deeply embedded in every function, at every level. Each role carries a quality responsibility. Consider this:

* Goods In Operatives are the crucial first point of contact for quality. Their responsibilities extend beyond simply tallying deliveries. They should be meticulously trained to scrutinize the physical condition of packaging for any signs of damage incurred during transit, rigorously verify the accuracy of labeling against purchase orders, and even conduct initial assessments for obvious defects or discrepancies in the delivered materials. While they don’t hold the authority to release the goods, their diligent early detection of potential issues acts as a vital filter, preventing substandard materials from progressing further into the supply chain.

* Production Operatives are active creators of product quality, not just assemblers. Their contribution involves ensuring components are precisely fitted and aligned according to stringent specifications, vigilantly monitoring machinery for any indicators of malfunction that could compromise product quality, and meticulously documenting key process parameters to maintain comprehensive traceability. Their unwavering attention to detail in verifying correct label application and ensuring batch code legibility is paramount for both regulatory compliance and ultimate customer satisfaction.

* Even Sales and Marketing teams wield significant influence over perceived and actual quality. Accurately and ethically representing product specifications and capabilities to customers from the outset is crucial for establishing realistic expectations and preventing future quality-related grievances. Furthermore, their direct engagement with the market provides invaluable feedback, acting as a vital early warning system for potential areas of product or process improvement.

* The foundation of quality is laid long before the production line, within Engineering and Design. These teams are responsible for developing robust and unambiguous product specifications, carefully selecting appropriate materials and manufacturing methodologies, and conducting rigorous testing and validation during the design phase. By proactively integrating quality considerations at this foundational stage, they significantly minimize the potential for downstream defects and ensure the product inherently meets the intended performance and reliability benchmarks.My proposition is straightforward yet transformative: rebrand the quality department as a technical compliance department. This seemingly simple shift sends a powerful message throughout the organization—quality isn’t policed by a single team; it’s an integral component of the company’s very DNA.Under this revised structure, quality managers evolve into technical compliance managers, and QC personnel/technicians transition into compliance technicians or release operatives. This subtle but significant change cultivates a culture where quality isn’t an afterthought but rather a deeply ingrained principle guiding every process and informing every decision, at every organizational tier.Ultimately, quality transcends the boundaries of a department. It’s a fundamental mindset, a shared commitment that should drive your entire organization towards excellence.