The topic is short and compact
With white label, the formulation remains with the manufacturer; nevertheless, the brand is considered the manufacturer within the meaning of the Cosmetics Regulation and, if based in the EU, the responsible person.
Hygiene products such as hand sanitizer gels may fall under the Biocidal Products Regulation instead of the Cosmetics Regulation; the classification is determined on a case-by-case basis.
A new fragrance affects allergen labeling and preservation; new packaging requires its own stability and compatibility data.
Before making a selection, check stability data in the target packaging, preservative efficacy testing, safety report, formulation ownership, and the division of roles.
Those who need exclusivity, their own active ingredient combinations, or a texture outside the standard range are better advised to choose Private Label.
So läuft die Entwicklung bei Labtree
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Konzeptionierung
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Bemusterung – Standardmuster in 24 h
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Individualisierung
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Prototyping
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Produktion
White Label 2–3 Monate · Private Label 3–6 Monate · Produktion ab 1.000 Stück
What exactly does white label mean in cosmetics?
With white label, the brand adopts a ready-made, tested formulation from the manufacturer and has it tailored specifically. The formulation remains the property of the manufacturer. The brand adds packaging, design, product name, and positioning. Private label is the opposite model: the formulation is newly developed according to the brand's requirements, and rights and exclusivity are contractually regulated. In the market, both terms are often conflated, but the distinction is crucial for contracts and cost calculations.
Legally, the model changes nothing regarding the role of the brand. According to the Cosmetics Regulation, the manufacturer is whoever places a product on the market under their own name or trademark (Art. 2(1)(d) Regulation (EC) No 1223/2009). In the case of white label, this is the brand, not the contract manufacturer. If the brand is established in the EU, it is therefore the responsible person; it may designate a person established within the EU, such as the contract manufacturer, as the responsible person by written mandate, who accepts the mandate in writing (Art. 4(3) Regulation (EC) No 1223/2009). For imported goods, the importer is the responsible person. Anyone who does not clarify this question before the project starts will end up with a product that lacks a clearly designated entity responsible for the product information file and CPNP notification.
Which products are suitable for white label, and what does not count as cosmetics?
Well-suited are categories with established formulation types where the brand differentiates itself through fragrance, texture nuances, packaging, and claims: facial and care creams, hand and body creams, barrier creams for stressed skin, shower gels, hand soaps, facial cleansers, and deodorants. In makeup, lip products or skin tints work well on an existing base, provided the brand's color shades fall within the formulation's pigment system.
Hygiene products are not automatically cosmetics
For hygiene products, the intended purpose determines the applicable law. A product is a cosmetic product if it is exclusively or primarily intended to clean, perfume, change the appearance of, protect, keep in good condition, or correct the body odors of the skin, hair, nails, lips, or oral cavity (Art. 2(1)(a)). For hand cleansers and leave-on hand disinfectants, the European Commission on borderline products cites either the Cosmetic Products Regulation or the Biocidal Products Regulation as a potential legal framework and notes that the classification of a borderline product is decided on a case-by-case basis. A similar principle applies to barrier creams: If an effect against skin diseases is claimed, the product shifts toward medicinal products. Clarify the classification before choosing a white-label formulation, as biocidal or medicinal product authorization cannot be achieved simply by relabeling a cosmetic base.
What are the real benefits of white label?
Time. Formulation development, initial stability testing, and scale-up to production scale are already complete when using an existing base. The timeline then depends primarily on whether standard packaging is used and how extensive the customizations are. Any customization that triggers new testing extends the timeline.
Lower technical risk. Viscosity, emulsion behavior, fillability, and behavior in the packaging material are known for the base. The brand decides how texture and sensory profile perform based on a physical sample rather than a specification on paper.
Predictable costs. Development costs are lower because no formulation is created from scratch. In contrast, unit costs continue to be determined by batch size, packaging, filling format, and raw material prices, equally for both white and private labels. How minimum order quantities arise is explained in the article MOQ in Cosmetics.
Which adjustments are possible, and which checks do they trigger?
Whether a white-label base is customizable is not decided by the list of possible modifications, but rather by which tests each change entails. The following overview shows typical adjustments and their testing requirements:
Adjustment | Typical testing requirements | Impact on the timeline |
|---|---|---|
New fragrance or fragrance proportion | Allergen declaration, skin compatibility, impact on the preservation system | low to medium |
Addition of active ingredient or higher concentration | Stability, safety assessment, substantiation of claims | medium |
Different packaging (e.g., tube instead of jar, airless dispenser) | Stability and compatibility in the new packaging material, filling trial | medium to high |
Altered viscosity or texture | New stability series, fillability, preservation challenge test if necessary | high, close to a new development |
Fragrance. A new fragrance alters the list of fragrance allergens subject to mandatory declaration; labeling requirements were expanded by Regulation (EU) 2023/1545. In addition, preservatives must be compatible with all components of the formulation, explicitly including perfume, and the overall formulation affects their efficacy (Halla et al. 2018, Molecules). For major fragrance modifications, a new preservation challenge test according to ISO 11930 is therefore recommended. Fragrance also matters for stability: The Cosmetics Europe guideline mentioned below advises that it may be necessary to test all fragrance variants, because fragrances are more likely to react with the product than color shades.
Packaging. Stability data apply to the packaging material in which the product was tested. The Cosmetics Europe and CTFA stability guideline recommends testing in packaging made of the exact same material in which the product is sold, and testing each type if multiple packaging types are used. If the brand switches from the tested jar to a tube, the existing stability statement is not automatically reliable for the new packaging.
Documentation. Any substantial modification is incorporated into the safety assessment pursuant to Art. 10 of Regulation (EC) No 1223/2009 and into the product information file pursuant to Art. 11, which must remain available for ten years after the last batch is placed on the market. The temperature and duration of accelerated stability tests are selected based on the product category and empirical values; the guideline recommends confirming the projection after launch with retain samples stored at room temperature. How these tests are structured is described in the article Stability and Safety Testing for Cosmetics.
Where does white label reach its limits?
Exclusivity: Because the formulation remains with the manufacturer, the same base can generally also be offered to other brands. Anyone needing exclusivity must agree on it contractually or switch to private label.
Change of manufacturer: With white label, the brand does not own a formulation that it can take along. A later change usually means a new development or redevelopment with its own stability and safety testing.
Differentiating efficacy claim: If an advertising claim is to be based on an proprietary active ingredient combination, an adjustment is rarely sufficient. Advertising claims must be substantiated for the finished product, not just for a raw material.
Sensory profile outside the base: A significantly lighter or richer texture changes the emulsifier system and rheology. From this point on, the effort is comparable to a new development.
Borderline products: Disinfectant or therapeutic claims cannot be implemented on a cosmetic base without changing the legal framework.
Which contractual points protect formulation ownership and confidentiality is covered in the article Confidentiality with the contract manufacturer: NDA and formulation ownership.
How does a white-label product differ from the competition?
The legitimate concern with white label is an interchangeable product. Differentiation arises at the levels not determined by the base:
Targeted formulation adjustment: Fragrance profile, active ingredient content within tested limits, or a shade of color make the product recognizable as your own.
Format and packaging: Dispenser, tube, or stick shape the application, dosage, and pricing logic, with the testing effort described above.
Positioning and claims: Target audience, application context, and verifiable promotional claims drive the purchase decision in retail more strongly than the base formulation.
A middle ground has proven successful: a white-label base that is selectively adjusted. The brand retains most of the time advantage while still visibly standing out. For an initial product line, a small, focused range is recommended, which can later be expanded with additional bases, as each base is already manufacturable.
Stability data in primary packaging: In which packaging, under which conditions, and over what period was it tested?
Preservation: Is a preservation efficacy test according to ISO 11930 available, and for which fragrance and active ingredient variant does it apply?
Safety assessment and INCI: Is a safety report available, and who updates it following any adjustment?
Ownership and licensing: Is the formulation the manufacturer's own development or licensed from a third party? This determines how extensive adjustments may be.
Limits of customization: Which modifications are possible without a new stability series, and which are not?
Roles: Who assumes the role of the Responsible Person, maintains the Product Information File, and handles the CPNP notification?
Labtree operates as a B2B cosmetics developer and cosmetics manufacturer with its own laboratory and production capacities in Germany, covering formulation development, sampling, feasibility testing, and cosmetics production. In the white label model, market-ready, tested Labtree formulations are customized for the brand; the standard formulations remain the property of Labtree. Samples of pre-qualified formulations are usually dispatched from the sample warehouse within 24 hours; with standard packaging, a white label product is typically ready for delivery in 2 to 3 months. The minimum order quantity is generally 1,500 units per product, depending on product type, filling size, and packaging. If this foundation is insufficient, a new development under the private label model—typically taking 3 to 6 months to market readiness—is the next step; learn more in the article Private Label Kosmetik and on the page Kosmetik entwickeln lassen.
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FAQ
Who owns the formulation in white label cosmetics?
With white label, the formulation remains the property of the manufacturer, while the brand obtains the right to sell the adapted product under its own name. Anyone wishing to own or exclusively use the formulation requires a contractual agreement or a new development under the private label model. For more in-depth information, see the magazine article Confidentiality with the contract manufacturer: NDA and formulation ownership.
Is a white-label hand sanitizer gel considered a cosmetic product?
Not necessarily. Depending on its intended purpose, a hand gel may fall under the Cosmetics Regulation or the Biocidal Products Regulation, and according to the European Commission, such borderline cases are classified on a case-by-case basis. If disinfection is the primary purpose, the requirements for biocidal products apply, which a cosmetic base does not fulfill.
Can a white-label barrier cream be advertised for treating skin eczema?
No, as a cosmetic product it may protect and care for the skin, but it cannot claim to treat diseases. A therapeutic claim would classify the product as a medicinal product. Therefore, formulate advertising claims within the cosmetic framework from the outset and substantiate them for the finished product.
Can I change manufacturers later with a white-label product?
The product itself, yes, but usually not the formulation, because it remains with the previous manufacturer. A switch usually means redevelopment with the new manufacturer, including a new stability test, safety assessment, and product information file. Factor in this effort if the product is intended to become a core product in the long term.
Does a white label product need its own safety report?
Yes. Every cosmetic product requires a safety assessment specifically for that product before being placed on the market, and any significant modification to fragrance, active ingredient, or packaging must be taken into account. Existing data from the base formula shortens the work, but does not replace the product-specific report.
What is the minimum order quantity for white label cosmetics?
The minimum order quantity depends on the product type, fill size, and packaging, as batch size and filling setup efforts determine the lower limit. At Labtree, it is typically 1,500 units per product. You can find more details in our magazine article on MOQs in cosmetics.
How does stricter allergen labeling affect white-label projects?
With Regulation (EU) 2023/1545, the list of fragrance allergens requiring labeling in Annex III was expanded. Cosmetic products that do not meet the new requirements were only permitted to be placed on the market for the first time until July 31, 2026, and may still be made available on the market until July 31, 2028. For white-label products, this means: New batches already need the extended labeling now, and the INCI list must be re-checked with every fragrance adjustment.
