White label cosmetics refers to finished products manufactured by one company and branded or sold by another. The term itself has no legal definition in most jurisdictions. Instead, cosmetic regulations define roles such as Responsible Person, Importer, Distributor, or Manufacturer, which determine who holds regulatory responsibilities.
Globally, compliance generally includes product safety substantiation, compliant labelling, claims support, ingredient restrictions where applicable, safety reporting, and product notification or registration. In the EU, UK, ASEAN, and China, a Responsible Person established in the market must maintain a Product Information File and notify products before they are placed on the market. In the United States under MoCRA, the Responsible Person is typically the brand owner, importer, or packer named on the label and is responsible for adverse event reporting and facility listing. In Canada, manufacturers or importers must submit a Cosmetic Notification Form within ten days of the first sale and ensure a responsible entity is established in the country. Other Asian and Australian frameworks often require a local responsible entity or notification before market entry.
