Required clinical tests complete
SPF, Broad Spectrum, safety and stability tests are already done.
SPF, Broad Spectrum, safety and stability tests are already done.
Immediate production on the same line/scale where process validation was completed.
Concentrate on your brand — without the R&D and complex regulatory burden.
[The 3 OTC development tracks compared]
| ODM | Hybrid White Label | White Label | |
|---|---|---|---|
| Formulation | Newly developed | Existing formulation + concept ingredient + fragrance change | Validated formulation as-is + micro-level adjustments |
| Fill size | Brand-specified | Customizable | Validated fill size as-is |
| Container | Brand-specified | Customizable | Designated container with ST/CT validation complete |
| Production | New scale-up | New scale-up | Same PV-completed line/scale |
| ST/PV | Run anew (+3 months) | Run anew (+3 months) | Skipped (existing data bridging) |
| Brand's role | Heavy R&D/regulatory burden | Partial regulatory validation needed | Focus on package design & marketing |
| Time to launch | 12–18 months | 6 months | Production in 1.5 months (once packaging materials arrive) |
| MOQ | 18,000 ea | 18,000 ea | 3,000 ea |
| Development fee | Available on consultation | Available on consultation | Available on consultation |
1) ODM: Everything from formulation development through stability/efficacy testing, FDA labeling review and process validation (PV) is developed to the brand's input. It takes at least 12 months and a high upfront cost.
2) Hybrid White Label: Uses a 'ready-to-go' formulation whose regulatory and formulation validation is already complete, adjusting concept ingredients or fragrance for the brand. It dramatically shortens time-to-launch to around 6 months and minimizes development risk.
3) White Label: An OTC platform whose formulation, packaging and production process are 100% FDA-validated. The proven formulation, container and production line are provided as-is, so the brand only adds its trademark and package design — launching in as little as 3 months.
US OTC sunscreens are governed by the FDA's OTC Monograph system. To sell in the US market in compliance with those requirements, the relevant regulatory steps — including Drug Listing — must still be completed.
No. When the validated white label formulation and UV filter levels are used as-is, the existing SPF/Broad Spectrum clinical data and stability data can be leveraged directly, minimizing the development timeline.
Using the validated formulation as-is carries no regulatory risk and allows the fastest launch. Minor adjustments to fragrance and concept ingredients are possible, but under OTC rules a supplementary review/stability test may be required to confirm they do not affect the UV protection performance or stability of the active ingredients.
Container labels and carton design can be fully changed to match the brand's tone and manner. However, the white label containers that have completed compatibility testing with the sunscreen formulation must be used.
It varies with package design confirmation and container lead times, but production and shipment are usually possible within about 1.5 months after contract signing and receipt of packaging materials.
The MOQ starts from 3,000 units — far lighter than custom manufacturing — and is negotiable. The initial development fee is provided on consultation.