White label, private label or custom: which route suits your brand
By British VitaTech, published , reviewed on
White label puts your brand on a supplier's ready-made formula, private label usually starts from the same catalogue with small changes such as flavour or strength, and custom (bespoke) development builds a new formula from your brief that your brand can own. In the white label vs private label vs custom choice, a stock formula suits a brand testing a market quickly, and custom suits a brand whose product is its point of difference, because owning the formula, specification and data lets you control changes, scale up and move manufacturer.
At a glance
- With white label, and usually private label, the supplier owns the formula. With custom development the contract decides, so get ownership assigned in writing.
- As of October 2026, in Great Britain and the EU the business under whose name a food is marketed answers for its food information (Regulation (EU) No 1169/2011, Article 8).
- As of October 2026, in the US the company named on a supplement label is the "responsible person": it must report serious adverse events to FDA within 15 business days of receiving a report and keep records for 6 years (21 U.S.C. 379aa-1).
- Get in writing: the formula, specification, stability data, test reports, artwork copyright and barcodes.
White label, private label, custom and contract manufacturing defined
White label is a shelf product: the supplier's ready-made formula, owned by the supplier and sold to any brand that asks, each with its own label.
Private label supplements usually start from the same catalogue, with small changes such as flavour, strength or pack. The supplier usually keeps the formula, so the product cannot move with you.
Custom (bespoke) development, or custom formulation, builds a new formula from your brief, for your customer, claims and markets. The contract decides who owns it.
Contract manufacturing covers all three. FDA describes such a brand as a distributor "that contracts with a manufacturer to manufacture a dietary supplement that you distribute under your own label" (FDA, 2017). So contract manufacturing vs private label is not a real choice; what differs is whose formula goes in.
How the terms get used loosely
Oxford Learner's Dictionaries defines white label as "a product that is made by one company but sold by another company using their own name" (Oxford University Press, 2026), which fits all three routes. In retail, private label means "a label associated with a specific chain store" (Merriam-Webster, 2026), and in that sense US store brands reached a record 23.5% unit share in 2025, across all products, not supplements alone (PLMA, 2026). Some manufacturers, us included, also say private label for a brand's own formula under its label. So ask whose formula it is, and who holds its specification and data.
White label vs private label vs custom, side by side
| White label | Private label | Custom (bespoke) | |
|---|---|---|---|
| The formula | The supplier's catalogue formula | A catalogue formula with small changes | A new formula from your brief |
| Who owns the formula and specification | The supplier | Usually the supplier | Whoever the contract names; with us, your brand |
| Differentiation | Label and price; others can sell the same formula | Small: flavour, strength or pack | Formula, dose, format, taste and claims |
| Regulatory and claims work | Fixed by the stock formula; you answer for your label | Checked for the changes; you answer for your label | Designed in from the brief, market by market |
| Development stage | None beyond artwork | Samples of the changed version | Formulation, samples, sensory work, pilot batch and stability |
| Speed to market | Fastest | Fast | Slower: development and stability come first |
| Control over changes and supply | The supplier decides | Mostly the supplier | Your written approval and planned supply, if the contract says so |
| Exit and switching manufacturer | The product stays with the supplier | The same, unless your version is assigned to you | If you own them, your formula, specification and data move with you |
Who owns the formula, and why it matters when you scale or move
The formula is every ingredient, its form and its amount per serving; the specification is the standard every batch is made and tested against; the data are the stability results and test reports behind both. A formula can be protected as a trade secret if it is secret, has commercial value because it is secret and has been subject to reasonable steps to keep it secret (Trade Secrets (Enforcement, etc.) Regulations 2018; Directive (EU) 2016/943). US federal law lists formulas among its examples (18 U.S.C. 1839).
Artwork needs the same care. In UK law the author of a work is the first owner of its copyright, or the employer if an employee made it in the course of employment, and an assignment must be in writing, signed by or on behalf of the assignor (Copyright, Designs and Patents Act 1988, ss.11 and 90). If a supplier's designer draws your label, get the copyright assigned. For barcodes, GS1 makes the brand owner, the organisation that owns the item's specifications, normally responsible for allocating the GTIN "regardless of where and by whom it is manufactured" (GS1, 2024).
When you scale or move manufacturer
New strengths, formats, markets and second sites all build on the formula and its data, so a brand that owns them works from its own file, while a white label brand has to ask a supplier that can sell the same product to its competitors. The US FDA says a brand that has supplements made for it has "an obligation to know what and how manufacturing activities are performed", so it can decide whether they meet their specifications and can be released (FDA, 2017). When you move, a formula the supplier owns stays behind and you start again. A formula you own is matched from your specification and put on stability in your final pack, as our page on moving your supplements to a new manufacturer explains.
Worked example: what the specification and data pin down
Say your label declares 80 mg of vitamin C per daily portion. The European Commission's 2012 tolerance guidance accepts minus 20% to plus 50% for vitamins in food supplements, measurement uncertainty included, for the entire shelf life (European Commission, 2012): 64 mg to 120 mg until the best before date. Vitamin C degrades in storage, so the formula carries an overage set from stability data. In Great Britain and the EU, the business named on the label must keep its food information accurate, best before date included (Regulation (EU) No 1169/2011, Articles 8 and 9). If the specification, overage and stability data sit in a supplier's file, your evidence leaves with the supplier.
What to get in writing
- The formula: every ingredient, its form and grade, the amount per serving and any overage.
- The specification: each test, method and limit, at release and through shelf life.
- Stability data: protocol, conditions, time points, results and the pack tested.
- Test reports: a certificate of analysis for every batch, in your company's name.
- Ownership: a clause assigning the formula, specification and data to your brand, with confidentiality.
- Change control: no change to the formula or its materials without your written approval.
- Artwork and barcodes: a copyright assignment and GTINs from your own GS1 company prefix.
- Exit: what transfers, in what form and when.
Claims and regulatory responsibility stay with your brand
The law does not ask which route you chose; it asks whose name is on the pack. As of October 2026, in Great Britain and the EU, a brand that places supplements on the market is a food business operator, responsible for ensuring food law is met within the business under its control (Regulation (EC) No 178/2002, Articles 3 and 17). The operator responsible for food information must ensure it is present and accurate, and operators that do not affect food information must not supply food they know or presume to be non-compliant (Regulation (EU) No 1169/2011, Article 8).
| Great Britain | EU | US | |
|---|---|---|---|
| Who answers for the label | The business under whose name the food is marketed, or the importer if that business is based outside the British Islands | The same, or the importer if it is based outside the EU | The manufacturer, packer or distributor named on the label, the "responsible person" (21 U.S.C. 379aa-1) |
| Name on pack | That business's name and address | That business's name and address | Name and place of business, with "Manufactured for" or "Distributed by" where it did not make the product (21 CFR 101.5) |
| Health claims | Authorised claims in the GB NHC register, which covers England, Scotland and Wales (DHSC, 2026) | Authorised claims in the EU lists (Regulation (EC) No 1924/2006, Article 10) | Structure/function claims with FDA's disclaimer, notified to FDA within 30 days after first marketing (21 CFR 101.93) |
| Other duties | Register as a food business at least 28 days before trading, even with no food on site (FSA, 2026a; FSS, 2026) | Notify with a model of the label where a member state requires it (Directive 2002/46/EC, Article 10) | A US address or phone number on the label (FDA, 2009); serious adverse event reports to FDA within 15 business days, records kept for 6 years (21 U.S.C. 379aa-1) |
As of October 2026, EU nutrition and health claims law still applies directly in Northern Ireland (DHSC, 2021), and the FSA's registration guidance covers it too (FSA, 2026a).
White label does not hand this responsibility to the supplier: the stock formula's amounts decide which claims it can carry, but your name is on them. In 2017 FDA told a distributor selling a contract-made supplement under its own label that it cannot contract out its ultimate responsibility under the supplement good manufacturing practice rules, citing missing written quality control procedures and reserve samples (FDA, 2017). Our guide to supplement label requirements covers the mandatory text.
When white label supplements make sense, and the risks
A stock formula can be the right first step: to test demand before investing in development, or for a clinic, gym or creator adding a standard product under its own name. The risks:
- Identical products. The supplier can sell the formula to other brands, so a competitor can launch the same product under another name. On a marketplace, where listings sit side by side, price becomes the lever.
- Evidence in your name. As of October 2026, TikTok Shop's US rules ask for a lab report from an approved laboratory, issued within the last 180 days and showing the selling account's company name and address (TikTok Shop, 2026).
- A formula built for one market. As of October 2026, titanium dioxide (E 171) is authorised in England, Scotland and Wales (FSA, 2025), but it has not been authorised in food in the EU since 7 February 2022 (Regulation (EU) 2022/63) or in food made in Northern Ireland (FSA, 2026b), so a stock tablet coated with it cannot follow you into the EU.
Private label narrows some of these risks if the contract makes your version exclusive. Ask for that in writing.
A decision checklist for your brief
- Point of difference. Is it your audience, your brand or the product? If it is the product, brief a custom formula.
- Speed. Do you need to prove demand first? A stock formula can answer that.
- Markets. Check every ingredient, additive and claim against each market on your plan.
- Claims. Do the formula's amounts meet the conditions of use for the authorised claims you need?
- Ownership. Who owns the formula, specification, stability data and test reports, in writing?
- Exclusivity and change. Can the supplier sell, change or discontinue your product?
- Evidence. Can you get test reports in your company's name?
- Exit. If you move, what do you take with you?
Our guide on how to choose a supplement manufacturer turns these into supplier questions.
How we approach it at British VitaTech
Bespoke development leads our work. It starts from your brief, not a catalogue, and your formula is yours: the formula, its specification and its data belong to your brand, so nobody else can buy your product, as our page on formula ownership sets out. We also make a brand's existing formula under its label, as our page on private label and contract supplement manufacturing explains. If another manufacturer owns your current formula, we develop a new one to your brief, and that one is yours; if you own it, we match it or reformulate it.
Development runs as a paid R&D stage and moves through eight stages: brief and feasibility, formulation, bench samples, sensory evaluation, regulatory and claims review for each market, a pilot batch on production equipment, stability in the final pack at ICH conditions with partner laboratories, and release and handover. You receive the formula, specifications, stability data and test reports. Our claims and regulation review covers each market, and our label design and artwork service takes labels to print.
Every batch is tested by accredited partner laboratories (ISO/IEC 17025), and batch testing is part of every order. Quality control releases each batch against its specification, with a certificate of analysis. British VitaTech is ISO 9001, HACCP and GMP certified by BSI, and FDA registered. We make capsules, tablets, softgels, gummies, powders, liquids, pouches and more in-house in the UK (see supplement formats) and run large programmes and multi-market launches.
Sources
- legislation.gov.uk, The National Archives (2021). Regulation (EU) No 1169/2011 on the provision of food information to consumers, Article 8 (responsibilities), as it applies in Great Britain ('British Islands' wording from 27 May 2021; no outstanding effects; checked October 2026).
- EUR-Lex (2011). Regulation (EU) No 1169/2011 on the provision of food information to consumers, EU text: Article 1(3), Article 8 and Article 9(1)(h).
- Legal Information Institute, Cornell Law School (2026). 21 U.S.C. 379aa-1, serious adverse event reporting for dietary supplements (current text, checked October 2026).
- US Food and Drug Administration (FDA) (2017). Warning letter to Ultra Perform, Inc. (ref. HAF4W(DEN)-18-01-WL, 22 November 2017), a dietary supplement distributor that contracts with a manufacturer and distributes under its own label; the 'obligation to know' passage cites FDA's final rule on dietary supplement current good manufacturing practice, 72 Fed. Reg. 34752, 34790 (25 June 2007).
- Oxford University Press (2026). Oxford Learner's Dictionaries: white label, noun (business).
- Merriam-Webster (2026). Private label, noun (first known use 1950).
- Private Label Manufacturers Association (PLMA) (2026). U.S. Private Label Industry Reached $282.8 Billion in Sales in 2025 (20 January 2026; PLMA/Circana Unify+ data).
- legislation.gov.uk, The National Archives (2018). The Trade Secrets (Enforcement, etc.) Regulations 2018 (SI 2018/597), regulation 2, definition of 'trade secret' (latest revised version; no outstanding effects; checked October 2026).
- EUR-Lex (2016). Directive (EU) 2016/943 on the protection of undisclosed know-how and business information (trade secrets), Article 2(1).
- Legal Information Institute, Cornell Law School (2026). 18 U.S.C. 1839, definitions, paragraph (3): trade secret (current text, checked October 2026).
- legislation.gov.uk, The National Archives (1988). Copyright, Designs and Patents Act 1988, section 11, first ownership of copyright (latest revised version; no outstanding effects).
- legislation.gov.uk, The National Archives (1988). Copyright, Designs and Patents Act 1988, section 90, assignment and licences (latest revised version; no outstanding effects).
- GS1 (2024). Who is responsible for numbering trade items? GS1 GO customer service portal (modified 28 August 2024).
- European Commission, Health and Consumers Directorate-General (2012). Guidance document for competent authorities for the control of compliance with EU legislation with regard to the setting of tolerances for nutrient values declared on a label (December 2012), FSAI copy.
- legislation.gov.uk, The National Archives (2021). Regulation (EU) No 1169/2011, Article 9 (list of mandatory particulars), as it applies in Great Britain: 9(1)(f) date of minimum durability; 9(1)(h) name and address of the Article 8(1) operator (no outstanding effects).
- legislation.gov.uk, The National Archives (2020). Regulation (EC) No 178/2002 (general food law), Article 3, definitions (2) food business, (3) food business operator and (8) placing on the market, as it applies in Great Britain (no outstanding effects).
- legislation.gov.uk, The National Archives (2020). Regulation (EC) No 178/2002 (general food law), Article 17(1), responsibilities of food business operators, as it applies in Great Britain (no outstanding effects).
- EUR-Lex (2002). Regulation (EC) No 178/2002 laying down the general principles and requirements of food law, EU text: Articles 3(3) and 17(1).
- Legal Information Institute, Cornell Law School (2026). 21 CFR 101.5, food; name and place of business of manufacturer, packer, or distributor (paragraphs (a) and (c)).
- Department of Health and Social Care (DHSC) (2026). Great Britain nutrition and health claims (NHC) register (GOV.UK, last updated 19 May 2026; applies to England, Scotland and Wales).
- EUR-Lex (2014). Regulation (EC) No 1924/2006 on nutrition and health claims made on foods, consolidated text of 13 December 2014: Articles 10(1) and 20(1).
- eCFR (2026). 21 CFR 101.93, certain types of statements for dietary supplements (up to date as of 23 October 2026).
- Food Standards Agency (FSA) (2026a). Starting a food business (GOV.UK guidance, last updated 19 August 2026; applies to England, Northern Ireland and Wales).
- Food Standards Scotland (FSS) (2026). Registering a food business (page undated; checked October 2026).
- EUR-Lex (2002). Directive 2002/46/EC on the approximation of the laws of the Member States relating to food supplements: Articles 2(a) and 10.
- US Food and Drug Administration (FDA) (2009). Guidance for Industry: Questions and Answers Regarding the Labeling of Dietary Supplements as Required by the Dietary Supplement and Nonprescription Drug Consumer Protection Act (September 2009; content current as of 20 September 2018).
- Department of Health and Social Care (DHSC) (2021). Nutrition and health claims: guidance to compliance with Regulation (EC) 1924/2006 (GOV.UK, first published 11 January 2021, updated 10 November 2021), sections 1.1 and 1.7 on Northern Ireland.
- TikTok Shop (2026). TikTok Shop Academy (US): Dietary Supplements Requirements (dated 9 October 2026: shown as 10/09/2026 in the page's US date format and as 09/10/2026 when opened in British English; read on 29 October 2026).
- Food Standards Agency (FSA) (2025). Authorised Regulated Food and Feed Products for Great Britain: titanium dioxide (E 171), status Authorised, applies in England, Scotland and Wales (status change date 31 December 2020; entry last updated 1 April 2025; checked 29 October 2026).
- EUR-Lex (2022). Commission Regulation (EU) 2022/63 of 14 January 2022 amending Annexes II and III to Regulation (EC) No 1333/2008 as regards the food additive titanium dioxide (E 171), OJ L 11, 18 January 2022: not authorised in the food categories of Annex II Parts D and E; in force 7 February 2022 (Article 4); foods made under the earlier rules could be placed on the market until 7 August 2022 (Article 2).
- Food Standards Agency (FSA) (2026b). Approved additives and E numbers (GOV.UK, published 25 June 2026; applies in England, Northern Ireland and Wales): as of 7 February 2022, titanium dioxide (E171) is no longer permitted for use as a food additive in the manufacturing of food products in Northern Ireland; the transition ended on 7 August 2022.