Private label means: a manufacturer makes the product, you sell it under your brand.
Costs include formula, documents, packaging, production and logistics, not just the unit price.
Selling under your own brand can make you the Responsible Person under EU law.
A manufacturer produces cosmetic products that you sell under your own brand. You decide on name, design and range; the formula comes from the manufacturer’s portfolio or is adapted for you.
This differs from contract manufacturing of an entirely new, proprietary formula. That route takes more effort, because development, stability tests and safety assessment start from the beginning.
In five steps: briefing, formula and samples, packaging and label, safety assessment with CPNP notification, and production and delivery. Each step ends with your approval.
Legal basis: Regulation (EC) No 1223/2009 (EUR-Lex).
There are one-off costs such as formula adaptation, samples, safety assessment and label design, and recurring costs such as production, packaging and shipping per unit. Their level depends mainly on quantity, packaging and formula.
| Cost block | Type | Depends on |
|---|---|---|
| Formula and samples | one-off | existing formula or adaptation |
| Safety report, Product Information File | one-off per formula | number of products and variants |
| Label and packaging design | one-off | scope, agency or in-house design |
| Packaging (bottles, jars, boxes) | per unit | material, standard or custom, quantity |
| Production and filling | per unit | formula, fill size, batch size |
| Shipping and storage | recurring | quantity, destination, delivery terms |
| Trademark registration | one-off | register and number of classes |
Whoever places a cosmetic product on the market under their own name or trademark is the Responsible Person under Article 4(6) of the EU Cosmetics Regulation. This includes retailers with their own brand.
The Responsible Person must ensure that the safety report, the Product Information File and the CPNP notification are in place, and that the product complies with the regulation. Tasks can be delegated by written mandate, so agree in the contract who does what. Source: Regulation (EC) No 1223/2009 (EUR-Lex).
A brand name that does not conflict with existing trademarks, registered before labels are printed. Cosmetics fall under Nice class 3.
Trademark searches are possible in national registers and at the European Union Intellectual Property Office (EUIPO). For assessing possible conflicts, a trademark professional is advisable. Plan time for packaging lead times, especially for custom containers, and for the safety assessment of new or adapted formulas.
Last updated: October 2026This page provides general information on cosmetics and trade practice. It is not legal, tax or medical advice.
It depends mainly on whether an existing formula is used and on packaging availability. New or changed formulas need additional time for stability testing and safety assessment.
As a rule, yes. They depend on product type, packaging and manufacturer. Standard packaging and existing formulas usually allow lower starting quantities.
Yes, but a changed formula generally needs an updated safety assessment and an updated CPNP notification.
With white label, an existing product is sold under your brand without changes. With private label, formula, fragrance or packaging are often adapted to your brand. In practice, the two terms are often used interchangeably.
If your company is the Responsible Person, yes – the CPNP is accessed with an EU Login. If another party takes on this role, they handle the notification. Our EU regulation guide explains the steps.
Claims must be truthful and supported by evidence. ISO 16128 provides a way to calculate natural origin content, but it is not a label. More in the natural cosmetics guide.
As a rule, whoever created the design or acquired the rights to it. If an agency designs it for you, have the rights of use set out in writing.
In principle yes, but each market has its own rules. In Great Britain, for example, a Responsible Person in the UK and a notification on the SCPN portal are needed. We check requirements per destination; see private label.
Among others the UK (SCPN), the USA (product listing under MoCRA) and Canada (Cosmetic Notification Form). Details in our export guide.
Ask who prepares the safety report and the Product Information File, who notifies in the CPNP, who owns the formula, how batches are traced and how minimum quantities are calculated.
Responsible Person, PIF, CPSR, CPNP, labelling and claims: EU duties for importers and distributors of cosmetics.
UK Responsible Person, MoCRA, Canada’s Cosmetic Notification Form, AICIS and Swiss law: the export rules for private label cosmetics at a glance.
Definition, mandatory documents, labelling and supplier checks: the key questions before your first order, with references to EU law.
Tell us which products, quantities, sales channel and country you have in mind. We reply personally with questions or a proposal for samples.
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