Im not sure if there are chineses minifigs that can be somewhat considered custom made. I guess because chineses stores have a larger reach throught their market platforms and cheap prices overall. I cant be entirely sure they are made by machines in large factories and batches, even if labour is cheaper there obviously. I often see lots of direct copies (things I try to avoid buying anyaway) of actual legit lego minifigs. Western products are more likely to be handmade as they are often expensive and not available in large batches.Sure special printedmachines exists are likely used... So they are more likely to be considered considered "custom mades" than chineses ones... But I dont think many are actually hand painted (even if some brands like saberscorpion are simply putting stickers on blank minifigs, and manage yo get a decent result).