Private Label and White Label

This page explains private label and white label arrangements on the Platform: who is the brand of record, what the Platform requires, who carries regulatory responsibility, and what happens in common failure cases. This page summarizes the Private Label & White Label Policy, which governs.

Private label in brief

Private label means products manufactured by one company and sold under another company's brand. The product is made by a contract manufacturer; the bag, box, or label carries your brand. The arrangement is a legitimate and common way to build a product line, and it raises one question the Platform must answer clearly: whose brand is it, legally?

The brand of record rule

In a private label arrangement, the label owner is the brand of record: not the contract manufacturer and not the formulator. The company whose name is on the package

• Claims the brand. See Claiming Your Brand.
• Holds the owner of record entry.
• Sets Minimum Advertised Price for the brand. See Minimum Advertised Price.
• Answers for the product on the Platform.

Private label concentrates responsibility in the label owner while knowledge is divided between the label owner and the manufacturer. The label owner knows the market; the manufacturer knows the formula. When something goes wrong: a mislabeled ingredient, contamination, or a recall: the Platform works with one responsible party, and the policy selects the label owner. Choose your contract manufacturer as if the liability is yours, because on the Platform it is.

What the Platform requires

Private label and white label arrangements operate through the standard Brand Registry and manufacturer application processes. See Brand Registry and Manufacturer Program. The requirements are

The brand must be established

Private-label brands go through the same registry and verification as any other brand. A new brand still requires the application and the evidence. See the Brand Ownership Verification Policy, which governs ownership verification.

The manufacturing relationship must be documented

Provide the following

• The manufacturer's identity.
• The facility where the product is made.
• The agreement between you and the manufacturer.

This information supports the recall procedure. When a lot is defective, the Platform traces the lot through you to the facility promptly. A manufacturer who will not identify its facilities may not supply ingestible products for sale on this Platform.

Regulatory responsibility follows the label

AAFCO labeling, state feed registrations, and EPA numbers for pesticide products are the label owner's obligations, governed by the Private Label & White Label Policy, which governs. Product data must meet the Manufacturer Product Data Standards, which governs, and the label owner is responsible for that data.

Your contract manufacturer may prepare paperwork as your agent, but registrations are held in your brand's name and the liability for a missing registration is yours.

No pass-through of responsibility to the Platform

Your contract with your manufacturer may provide that the manufacturer indemnifies you. That agreement is between you and the manufacturer. It does not reduce what you owe the Platform under the brand and seller terms, and the Platform's remedies run against the brand of record. Resolve any recovery from your manufacturer separately.

The white-label distinction

White label means generic products sold under many different brands. Each brand selling a white-label product is independently responsible for

• Its own listing accuracy.
• Its own Minimum Advertised Price compliance.
• Its own customer obligations.

The fact that many brands sell the same white-label product does not reduce any one brand's responsibility for what its listing states. The catalog rule still applies: one product family has one product record, and brand-specific listings attach as offers, not as separate products.

Common failure cases

The contract manufacturer changes the formula without telling you

Prevent this in your contract by requiring change notification, and check supply on receipt. If the shipped product no longer matches the listing, the listing-accuracy violation is yours as label owner. The fact that the manufacturer changed the formula without notice may affect how intent is assessed; it does not erase the violation.

The manufacturing relationship ends

The brand stays yours, because you are the brand of record. You need a new supply source before you continue selling.

1. Pause listings for product you cannot supply.
2. Secure the new supply source.
3. Resume the listings only when supply is in place.

Continuing to list product you cannot supply creates a fulfillment violation.

The manufacturer sells your formula to someone else

That is a contract dispute between you and the manufacturer, not a Platform matter, unless the other party lists the product under your brand. In that case the listing is treated as counterfeit and handled through Complaints, Takedowns and Anti-Counterfeit. Recall duties for the label owner are governed by the Manufacturer Recall Cooperation Policy, which governs.