Herbal capsules in a wooden bowl

How to start a private label supplement brand in the EU

Short answer: to start a private label supplement brand in the EU, choose your products and format, check every ingredient for novel food status, agree order quantities and lead times with your supplier, design a label that meets Regulation (EU) No 1169/2011 and Directive 2002/46/EC, use only authorised claims under Regulation (EC) No 1924/2006, and notify the product in the countries that require it. Plan 5 to 12 weeks for private label production. If you start with products from bulk stock, orders are usually shipped within 1–2 weeks, depending on stock.

What does private label mean for food supplements?

With private label, a supplier provides the product and you sell it under your own brand. You decide on the products, the packaging and the label, and the product reaches your customers with your brand name on it.

That also makes you responsible for the label. Under Regulation (EU) No 1169/2011, the food business operator responsible for the food information is the operator under whose name or business name the food is marketed. In practice: the brand owner answers for the label text, the claims and the national notifications.

What are the steps to launch a private label supplement brand?

  1. Choose products and format. Decide which products you want to sell and in which form: capsules, tablets or powders. Start with a small range that fits your customers and your sales channels.
  2. Check every ingredient. Check the novel food status of each ingredient (see below) and whether there are national rules for specific plants or substances in your target countries.
  3. Agree quantities and lead time. Ask your supplier for the standard order tiers, the price list, the lead time and who arranges transport.
  4. Design a compliant label. Combine the general food labelling rules with the specific rules for food supplements, in the language of each country where you sell.
  5. Check your claims. Use only authorised nutrition and health claims under their conditions of use, and no medical claims.
  6. Notify the product. Submit a notification in each country that requires one before you start selling.
  7. Set up your product file. Keep the specification, the certificate of analysis for each batch, the organic certificate if relevant, the label and your notification receipts together.

What order quantities and lead times should you plan?

Product type Standard order tiers Lead time from bulk stock Private label production
Capsules 20,000 / 50,000 / 100,000 capsules Usually 1–2 weeks 5 to 12 weeks
Powders 10 / 50 / 100 kg Usually 1–2 weeks 5 to 12 weeks
Tablets 10 / 50 / 100 kg On request 5 to 12 weeks

These are the standard tiers at GOA Supply. Smaller quantities are possible on request. Lead times depend on stock, the formula and the availability of ingredients. Prices exclude shipping, and we can arrange transport. Our capsules are filled by an external Dutch contract manufacturer, whose organic certificate is available on request.

What must be on a food supplement label in the EU?

Regulation (EU) No 1169/2011 sets the general rules for food information. The main mandatory particulars are:

  • the name of the food;
  • the list of ingredients, with allergens from Annex II emphasised;
  • the quantity of certain ingredients where required;
  • the net quantity;
  • the date of minimum durability;
  • any special storage conditions or conditions of use;
  • the name and address of the responsible food business operator;
  • the country of origin where required, and instructions for use where needed.

Mandatory particulars must be printed in a minimum font size, with an x-height of at least 1.2 mm (0.9 mm on small packages), in a language easily understood by consumers in the country of sale. Food supplements are exempt from the standard nutrition declaration of Regulation (EU) No 1169/2011.

Directive 2002/46/EC adds specific rules for food supplements. The label must include:

  • the name "food supplement" (in the language of the country);
  • the names of the categories of nutrients or substances that characterise the product;
  • the recommended daily portion;
  • a warning not to exceed the recommended daily dose;
  • a statement that food supplements should not be used as a substitute for a varied diet;
  • a statement that the product should be stored out of the reach of young children;
  • the amount of nutrients or substances with a nutritional or physiological effect per daily portion.

Do you need to notify your product in each country?

Directive 2002/46/EC allows EU member states to require a notification when a food supplement is placed on their market. The rules differ per country:

Country Notification How
Netherlands No notification duty for food supplements Register your company with the NVWA and check the NVWA rules and blocklist for specific ingredients
Belgium Notification file before marketing Via the FOODSUP application of the FPS Public Health; the notification number is not a marketing authorisation
France Declaration before marketing Via Compl'Alim, the declaration platform of the Ministry of Agriculture (DGAL)
Germany Notification at the latest at first placing on the market To the BVL with a sample of the label, by the manufacturer or importer (§ 5 NemV)

For other EU countries, check with the national competent authority before you launch.

Which claims can you use on a supplement label?

Nutrition and health claims are governed by Regulation (EC) No 1924/2006. You may only use claims that are authorised in the EU Register of nutrition and health claims, under the conditions of use set for each claim. Many claims for plant ingredients are still on hold at EU level. Food information may not attribute to a food the property of preventing, treating or curing a human disease, so medical claims are not allowed on supplements. The same rules apply to your website, product listings and social media.

How do you check the novel food status of an ingredient?

Under Regulation (EU) 2015/2283, a novel food is food that was not used for human consumption to a significant degree within the EU before 15 May 1997. A novel food needs an EU authorisation before it can be sold. Check every ingredient, including the plant part and the form, in the EU Novel Food Catalogue and the Union list of authorised novel foods. The catalogue is an orientation tool. If the status of an ingredient is unclear, ask the competent authority in the country where you plan to sell first.

Where to start with GOA Supply

Many brands start with a few products from existing bulk stock, such as ashwagandha capsules or chlorella tablets, and add more products once the first ones sell. Browse our herbal capsules in bulk, read how private label works on our private label page, or see order quantities on our wholesale page.

FAQ

How long does it take to launch a private label supplement?

Private label production usually takes 5 to 12 weeks from formula approval to delivery. Add time for label design and national notifications. Products from bulk stock ship faster: usually within 1–2 weeks, depending on stock.

What is the minimum order for private label?

Our standard tiers are 20,000, 50,000 and 100,000 capsules, and 10, 50 and 100 kg for powders and tablets. Smaller quantities are possible on request.

Who is responsible for the label?

The brand owner. The operator under whose name the food is marketed is responsible for the food information, including mandatory particulars, claims and notifications.

Do I need to notify a food supplement in the Netherlands?

No, there is no notification duty for food supplements in the Netherlands. You do need to register your company with the NVWA, and the general food rules apply.

Can I use one label for several EU countries?

The labelling rules are largely harmonised, but the mandatory information must be in a language consumers in each country easily understand, and notification requirements and some national ingredient rules differ. Multilingual labels are common.

Can I sell my private label products as organic?

Only if the product is certified under Regulation (EU) 2018/848. Ask your control body whether you need your own organic certification as a brand owner.

Sources

Written by Florian Fermin, co-owner of GOA Supply.

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