White label: a ready-made product sold under your own brand

White label vs private label

The two terms are often used as if they meant the same thing. In sourcing they usually describe two different deals:

Legally, the line is thinner than the table suggests. The Consumer Product Safety Act, which covers consumer products but not, among others, cosmetics, food and drugs, treats a product as private label when it is labeled with the brand or trademark of someone other than a manufacturer^[2], the brand owner authorized it, and the maker's brand is absent. A white label product carrying only your brand meets that test, so it is private label in the eyes of that law.

Your brand on it means the duties are yours

Buying a finished product does not pass the regulatory work to the factory. The name on the label is what regulators follow.

• Cosmetics sold in the US. The responsible person is the manufacturer, packer, or distributor whose name appears on the label^[1], and a responsible person must list each marketed cosmetic product with the FDA, including its ingredients^[3]. White label a face serum and that listing falls to you, not to the factory that makes the serum, unless MoCRA's exemption for certain small businesses^[3], under the Modernization of Cosmetics Regulation Act, covers your business.
• Dietary supplements sold in the US. FDA's compliance guide says a distributor that has a supplement made and sells it under its own label has an obligation to know what manufacturing activities are performed, and how^[4], so that it can decide whether the product meets its specifications and can be released.
• Consumer products sold in the EU. The General Product Safety Regulation counts as the manufacturer any person who has a product made and markets it under its own name or trademark^[5]. That manufacturer must show its name, registered trade name or trademark, and postal and electronic address^[5] on the product, or on its packaging or an accompanying document where that is not possible.

Example: launching one skincare product both ways

	White label serum	Private label serum, your formula
Minimum order	500 units	3,000 units
Formula development and samples	$0, stock formula	$1,500
Unit price	$3.10	$2.40
Time to first shipment	4 weeks	14 weeks
Cash for the first order	$1,550	$8,700

Illustrative figures, not a quote. Real prices depend on the spec, quantity and factory.

The white label route costs more per unit but needs far less cash and time, which suits a product whose demand you have not proven. The private label route costs more up front and can buy a formula no other brand can sell, if your contract makes the formula yours or exclusive to you. Either way, whichever of the duties above apply to your category are yours from the first unit.

Questions to ask before you buy a white label product

• Is the product exclusive to you in any channel or market, or can any buyer order it?
• Can you have the full ingredient or material list, and the test reports your sales channels ask for?
• Will the factory print your name and address details on the label and packaging, and keep its own brand off?
• If you later want changes, can the same factory move you to a formula or design of your own?

To see private label makers by product category, start from private label manufacturers. If a stock white label product would do for a first order, say so when you request quotes.