A private label AHA serum (glycolic, lactic,
mandelic) sold as a cosmetic exfoliant is a standard cosmetic that any
competent cosmetic contract manufacturer can make. A BHA serum built on
salicylic acid is the fork in the road: market it for acne treatment and the
same 0.5–2% salicylic acid becomes an over-the-counter drug under 21 CFR Part
333, which has to be made in an OTC drug facility, not a cosmetic one. Same
molecule, different label wording, two completely different supply chains.
If you are sourcing an acid exfoliant serum, the decision that controls your
whole project is not the acid percentage or the bottle. It is the sentence you
plan to print on the front of the carton. Get that right before you request a
single quote, because it decides which kind of factory you are even allowed to
talk to.
What’s actually different between AHA and BHA for a founder?
AHAs — alpha hydroxy acids — are water-soluble and work on the surface.
Glycolic is the smallest molecule and penetrates most readily; lactic is
gentler and doubles as a humectant; mandelic is larger and slower, which is why
it suits reactive skin. BHA means beta hydroxy acid, and in practice that is
salicylic acid: oil-soluble, so it travels into the pore rather than staying on
the surface.
For formulation, the practical gap is pH and compatibility. An AHA serum at
5–10% is relatively forgiving to make. Salicylic acid has to sit at a low
enough pH (roughly 3–4) to do anything, and combining AHA and BHA in one bottle
— common in consumer products — means managing that pH against two actives at
once and proving the result is stable. A manufacturer who under-buffers the
formula ships an irritating product; one who over-buffers ships an inert one.
That is a real reason the factory you pick matters.
The rule that decides everything: cosmetic or OTC drug?
In the United States, what a product claims to do determines how it
is regulated, not what is in it. Salicylic acid at 0.5–2% is a recognized
over-the-counter acne active under
21 CFR Part 333, Subpart D. The moment your product both
contains that salicylic acid and makes an acne-treatment claim on the
label, the FDA classifies it as an OTC drug. That product must be made under
drug GMP (21 CFR Part 211) in an FDA-registered drug facility — a different
category from a cosmetic manufacturer.
Position the identical formula as a cosmetic — “exfoliates dead skin cells,”
“visibly refines the look of pores,” “helps skin appear smoother” — and it is a
cosmetic. A standard cosmetic contract manufacturer can make it. AHAs make this
easier still: glycolic and lactic acid have no OTC drug monograph for
exfoliation, so an AHA serum sold on appearance claims is cosmetic territory by
default. The FDA’s own
guidance on cosmetic labeling claims is the plain-English
version of where that line sits, and the agency’s
small-business
compliance guide for topical acne drug products spells out what tips a
salicylic acid serum into drug status.
The trap is wording you would type without thinking. “Anti-acne serum,”
“unclogs pores so breakouts stop,” “fights blemishes” — each of those reads as a
drug claim, and a cosmetic factory cannot legally make the product behind it.
Decide your claims first; they pick your factory for you.
White label vs custom formulation for an acid serum
Once you have settled on cosmetic positioning, the next question is build
route. The two industry terms are used loosely across suppliers, so it is worth
being precise about what they mean at a specific factory. The figures below are
Moe’s Group’s, confirmed by the owner; other manufacturers set their own.
- White label (ready-to-go / existing formula)
- An existing formula you brand as your own. Fastest to market because there
is no development phase. At Moe’s Group the minimum order is 200 units, and
nothing runs below 200. - Private label (custom formulation)
- A formula developed for you — your actives, your acid blend, your pH and
sensory target. It adds a formulation and sampling phase, so it takes longer.
At Moe’s Group the minimum order is 1,000 units. - Contract manufacturing
- The umbrella service: formulation, filling and labeling for a brand.
Pricing, formula ownership and lead time are set per project, not by the term
itself.
The useful way to read this: an existing formula removes the development fee
and the sampling lead time, which is why white label reaches shelves sooner. A
custom acid serum is the route when you need a specific percentage, a particular
AHA/BHA ratio, or a texture no stock formula gives you — and you are ordering at
least 1,000 units. Do not assume one is simply “cheaper”; what you are really
buying with white label is removed development time.
What to ask a manufacturer about an acid serum
Acid serums expose whether a factory actually understands formulation or just
fills bottles. Five questions separate them:
- What final pH do you target, and how do you verify it batch to
batch? A salicylic serum outside ~3–4 is either harsh or inactive. - How do you handle AHA and BHA together? Combining them is
a stability and pH problem, not a mixing one. - What preservative system do you use, and do you run preservative
efficacy testing? Low-pH aqueous serums still need it; it is not
optional. - Do you run full stability testing before scale-up? Acid
serums have a shorter comfortable shelf life than many formats. - Are you a cosmetic facility or an OTC drug facility? This
is the one that decides whether they can legally make your product at all if
you are making acne claims.
Moe’s Group’s own
skincare
manufacturing page names salicylic acid in its cleanser work and AHA/BHA in
its toner formats, and lists stability testing and packaging-compatibility
checks as part of custom development — which is the kind of concrete answer the
questions above are fishing for. Verified live 2026-10-22.
Where a cosmetic manufacturer is the wrong fit
The honest part. A cosmetic contract manufacturer — Moe’s Group included — is
the wrong call in several real situations, and knowing which is yours saves
weeks:
- You want to make acne-treatment claims. A salicylic acid
product marketed as an acne treatment is an OTC drug and needs a 21 CFR Part
211 drug facility. Search specifically for OTC drug manufacturers; most cosmetic-only
factories, Moe’s Group among them, are not set up for it. - You need fewer than 200 units. For a DTC market test below
that, Moe’s Group is not the route. US-based
AJ Cosmo Labs advertises
glycolic acid serum runs it describes as starting around 100–500 units
(their claim; facility registration not independently confirmed at
publication, so verify before you rely on it). - You are price-led at 3,000+ units and open to offshore.
Chinese manufacturers such as
Skincraft Lab (Zhongshan;
ISO 22716 and FDA CFSAN GMP certificates listed, valid through 2028) quote
glycolic acid at 2/5/8% from roughly 500 units private label and 3,000 custom.
The trade-off is lead time, import compliance and the certification bar you are
comfortable with — verify the live certificate numbers in FDA FURLS yourself.
(Competitor details checked 2026-10-22.) - You are filling tiny batches yourself. Buying
cosmetic-grade glycolic from an ingredient supplier and hand-filling is legal
at micro scale, but it breaks down the moment you hit retail, Amazon FBA
testing and labeling, or MoCRA facility registration.
Where a US-based cosmetic manufacturer like Moe’s Group does fit is the
middle of that range: a cosmetically-positioned AHA or BHA serum, white label
from 200 units or custom from 1,000, formulated, filled and labeled in one
FDA-registered facility. If that is you, the
product
inquiry form is where a real conversation starts.
Frequently asked questions
Can I add salicylic acid to my serum and still sell it as a cosmetic?
Yes, if you make no acne-treatment claims. Describe it with appearance and
feel wording (“exfoliates dead skin cells,” “helps skin look clearer”) and it is
a cosmetic. Make an acne-treatment claim and the same ingredient makes it an OTC
drug.
What is the difference between AHA and BHA?
AHAs (glycolic, lactic, mandelic) are water-soluble and work on the skin’s
surface. BHA (salicylic acid) is oil-soluble and works inside the pore. Only the
BHA carries an OTC drug monograph in the US when used with acne claims.
What is the minimum order for a private label glycolic acid serum?
It depends on the manufacturer. At Moe’s Group a white label (existing)
formula starts at 200 units and a custom formulation starts at 1,000. Some
offshore manufacturers quote from around 500.
Do I need FDA approval for an exfoliant serum?
No — the FDA does not approve cosmetics, and the word “approved” does not
apply to them. A cosmetic serum is made in an FDA-registered facility. Only if
your product is an OTC drug (an acne-claiming salicylic acid serum) does a drug
GMP facility come into play.
Can I combine AHA and BHA in one private label serum?
Yes, and many consumer products do. The catch is formulation: the pH has to
work for both acids and the finished product has to pass stability and
preservative efficacy testing. Ask a prospective manufacturer how they handle
it before you commit.