What does white label mean? A ready-made product under your brand

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^[2]. 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^[2], 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^[3], 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^[4]. That manufacturer must show its name, registered trade name or trademark, and postal and electronic address^[4] on the product, or on its packaging or an accompanying document where that is not possible.

Where private label comes in

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^[5], 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. For a new brand choosing between the two routes on exclusivity, cash and time to first stock, see private label vs white label.

Example: a first white label serum order

What a first white label serum order costs

	White label serum
Formula development	$0, the factory's stock formula
Samples of the stock product	$150
Minimum order	500 units
Unit price, filled and labeled with your brand	$3.20
First order cost	$1,600
Cash before the first sale, excluding freight and duty	$1,750
Time to first stock	4 weeks

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

A white label quote is mostly a unit price on a product that already exists, so the cash and the wait stay small, which suits a product whose demand you have not proven. With a white label serum you change the label and the packaging, sometimes a color or scent, but not the formula. What white label does not buy is exclusivity: unless your contract says otherwise, the same serum can be sold under other brands. 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. To search beyond it, the guide to finding a manufacturer covers where factories list themselves and how to tell a plant from a trader. If a stock white label product would do for a first order, say so when you request quotes.