A shampoo is a cosmetic, but an anti-dandruff shampoo
is a drug — and that one distinction decides your paperwork, your
timeline, and sometimes your manufacturer. Before you order, you have to settle
four things: whether you want a ready-made formula or your own, your minimum
order quantity, whether any claim on the label makes it an over-the-counter
drug, and which lab is actually the right fit for your scale.
If you already have a brand name and you want a shampoo to put it on, the
hard part is not finding a factory. It is knowing what you are deciding before
you call one. This is a shampoo-specific companion to our broader overview of
what is different about private label hair care;
here we stay on the pre-order decisions.
Is a shampoo a cosmetic or a drug?
Most shampoo is a cosmetic: it cleans hair, and cleaning is a cosmetic
function. The moment a shampoo claims to do something to the body — control
dandruff, relieve a flaky scalp condition, or otherwise affect the structure or
function of skin — it can cross into being an over-the-counter (OTC) drug in
the eyes of the US Food and Drug Administration. The FDA’s own guidance,
Is It a Cosmetic, a Drug, or Both?,
turns on intended use: what you say the product does, on the label and in
marketing, is what classifies it.
In practice, active ingredients are the tell. Zinc pyrithione, selenium
sulfide, coal tar, and salicylic acid at active concentrations are the classic
anti-dandruff actives, and a product built around them to treat dandruff is
regulated as an OTC drug, not a cosmetic. That means a monograph to follow,
different labelling, and a different manufacturing conversation. A sulfate-free
cleansing shampoo that simply says it leaves hair feeling clean and soft stays a
cosmetic. Decide which one you are making before you decide anything else,
because it changes every answer below.
White label, private label, or contract manufacturing?
These three terms get used loosely across the industry, and suppliers do not
all mean the same thing by them. Here is how Moe’s Group — the contract
manufacturer that owns this publication (see our
editorial policy) — uses them, so you can read the
rest of this page against a fixed definition.
- White label
- A ready-made, existing formula you put your own label on. Also called
ready-to-go. Moe’s Group’s minimum order is 200 units. - Private label
- A custom formulation developed for your brand. Moe’s Group’s minimum order
is 1,000 units. - Contract manufacturing
- The manufacturing service itself. Ownership, pricing, and lead time depend
on the agreed project rather than on the label you attach to it.
The trade-off is not simply a price ladder. A white-label shampoo typically
asks for less development investment and a lower entry order, because the formula
already exists — you are buying speed and lower risk. A private-label custom
formula asks for more up-front work and a larger minimum, and in return you get a
formula that is yours and that nobody else can sell. Which is “better” depends
entirely on whether you are testing demand or building a differentiated line, not
on which word is cheaper. We cover the mechanics of real minimums in more depth in
small-batch cosmetic manufacturing.
What is the minimum order, and where is Moe’s Group the wrong fit?
Moe’s Group starts at 200 units for a ready-to-go shampoo and 1,000 units for
a custom one. That is a sensible floor for a brand with some traction. It is the
wrong floor for a brand bottling fifty units to see whether anyone buys. If that
is you, name it honestly: you want a lab whose model is built for tiny opening
runs, and several US labs publish minimums well below 200.
Independent round-ups are the fastest way to scan the field. The October 2026
compilation at suppliers.ai lists US
hair-care labs with entry points ranging from a handful of units per SKU up
through a few hundred — names like Spa De Soleil, Botanical Science, Pravada,
Dreamline Beauty, and RainShadow Labs appear there as lower-minimum options, and
Dreamline in particular runs hair care only. For larger custom programs,
GAR Labs is cited with a higher minimum but no separate development fee, which is
unusual. Treat every one of those figures as a starting point, not gospel:
MOQs change without notice, so confirm the current number on the lab’s own site
before you commit. For brands weighing overseas production on unit cost, the
August 2026 list at keronhair.com covers
manufacturers in China, Italy, and Spain, and makes the useful point that an
advertised MOQ sometimes excludes packaging.
Where is Moe’s Group genuinely the wrong fit? Three places. Below 200 units,
the labs above serve you better. If your entire line is hair care and you want a
supplier optimised end-to-end for it, a hair-only specialist is a legitimate
alternative. And if a true OTC drug shampoo is the goal, that is a different
manufacturing conversation entirely — one to raise directly rather than
assume. Where Moe’s Group does fit is the brand that wants a sulfate-free, syndet,
or traditional surfactant shampoo made, labelled, and filled under one roof;
their private label haircare manufacturing page lists
shampoos among the formats they run, and their
custom hair care development page consolidates formulation,
testing, and filling for the private-label route.
Do you have to register your shampoo with the FDA?
Under the Modernization of Cosmetics Regulation Act of 2022 (MoCRA), cosmetic
facility registration and product listing moved from voluntary to mandatory, and
the law directed the FDA to establish good manufacturing practice (GMP)
regulations for the sector. The agency does not clear cosmetics for sale the way
it does drugs — cosmetics are not subject to premarket agency sign-off —
but the compliance floor for the people who make your product has risen. That
makes a manufacturer’s compliance status a fair question to ask on the first
call. Read the FDA’s own
MoCRA overview for the current state of
the rules, since the specifics continue to be phased in. When a contract
manufacturer says it is FDA registered, that means its facility is on file with
the agency — it is a registration of the facility, not an agency endorsement
of any product.
Frequently asked questions
What is the minimum order for private label shampoo?
It depends on the manufacturer and on whether the formula is ready-made or
custom. At Moe’s Group, a ready-to-go (white label) shampoo starts at 200 units
and a custom (private label) formulation starts at 1,000 units. Several US labs
publish lower minimums for ready-made formulas; confirm the current figure on
each lab’s own site before ordering.
Is anti-dandruff shampoo a cosmetic?
No. A shampoo marketed to control or treat dandruff is regulated as an
over-the-counter drug in the US, not a cosmetic, because the claim describes an
effect on the body. A plain cleansing shampoo that makes only appearance and feel
claims stays a cosmetic. The classification follows the claim.
Do I need to register my shampoo with the FDA?
There is no agency clearance step for a cosmetic the way there is for a drug.
Under MoCRA, the facility that manufactures it must be registered and the product
listed with the FDA, and GMP requirements apply. Ask any manufacturer you are
considering about their registration and GMP status.
How long does it take to make a private label shampoo?
A ready-made formula is generally quicker to produce than a custom one,
because there is no formulation and stability work to complete first. Exact
timelines vary by formula, packaging, and order size, so ask your manufacturer
for a lead time against your specific brief rather than relying on a category
average.
Weighing a specific brief against a manufacturer’s capabilities
is the only way to get a real answer. If Moe’s Group looks like a fit for your
scale, you can start that conversation on their
product inquiry form.
