ISO 22716 is the floor, not the finish line
Most cosmetics quality projects start with ISO 22716 and stop there. Controlled SOPs, training records, batch documentation, done. The problem is that cosmetics quality is inseparable from cosmetics regulation: the batch record is evidence in the PIF, the specification is what the CPSR was written against, and the deviation may be the reason a market notification needs revisiting.
Any quality system that can't see the regulatory side leaves you assembling that connection by hand, usually under time pressure, usually for a retailer or an inspector.
