In a software company, some part of the employees salary is COGS, since programmers are required to build the product/service and hence that is COGS. In a fashion company, the cost of the designers salary will be COGS, the garment costs will be COGS.

Basically anything that goes into directly making the product or service can be considered as COGS.

Also keep in mind that accounting rules are many times subjective, meaning different companies might have different interpretations of the same.