White label insect repellent: what brands need for the EU

A white label insect repellent puts your brand on a product that someone else formulates, documents and fills. In Europe that product is a biocide, so the work sits less in the logo than in the files, the label and the order in which they are done.

What a white label insect repellent includes

Insect repellents fall under the EU Biocidal Products Regulation, (EU) No 528/2012, as product type 19, repellents and attractants. Every bottle placed on the market has to meet it, whatever the brand on the front.

Through Powered by Affix Labs, a brand owner or retailer gets one formulation under their own brand, the regulatory documentation behind it, a label review before print and a co-branding pack. The brand brings the market, the customers and the shelf.

The formulation is the one used in Repeltec.

The formulation stays as it is

Brand owners often ask for their own scent, colour or strength. The answer is no, and the reason is regulatory rather than commercial.

The formulation is what the regulatory files describe. Changing it means a new dossier, a new procedure in every market and a new timeline. A different fragrance already counts as a change. If your range needs something the current product does not do, that is a development project, not a variant.

Registration files for each market

There is no single EU shelf. Each country where the product is sold has its own authority, its own procedure and often its own language rules.

Affix Labs Netherlands B.V. holds the dossiers for the formulation. Whether a partner can be placed on an existing file or needs its own depends on the market and on whether the product is sold unchanged. Our regulatory lead decides this per market before anything is agreed commercially.

Two checks apply everywhere. The active substance supplier or the product supplier must appear, for the right product type, on the ECHA list kept under Article 95 of the regulation, at every step of the supply chain. Great Britain runs its own version of the regulation with its own supplier list, so a range for the United Kingdom is a separate file.

Partners receive safety data sheets, labels, the technical data sheet, certificates and letters from the authorities, per market and per language, through the professional portal. Documents are versioned and dated, so always pull the current one.

Label artwork for a white label repellent

Article 69 of the regulation sets out what a biocide label must show, clearly and indelibly. It also lets each country require the label in its official language, so a label for Germany is written in German and one for France in French.

On a co-branded Affix Labs label, the split looks like this:

• Fixed: the claims for the market, in their approved wording.
• Fixed: the active substance and its concentration, the reference number for the market, the holder, the directions for use and the batch details.
• Fixed: the mandatory biocide notice, in the market language.
• Yours: the brand name, the design, the colours, the photography and the shelf copy outside the claims.

Wording is narrower than most brand teams expect. The regulation lists terms that may never appear on a biocide label or in its advertising, and in June 2024 the EU Court of Justice ruled that “skin friendly” in a biocide advert falls under that ban. Every proof goes to our Lab Director for approval before print.

Packaging, the lockup and minimums

You choose your own label and, within the bottle formats we already fill, your own bottle. A pack size outside the current range is a tooling and filling question, so ask before you design around one.

The Powered by Affix Labs lockup always sits behind your own logo, at most half its height. The co-branding pack holds the logo files, clear-space and minimum-size rules, and a two-page guide to placement on pack, in retail artwork and online.

Minimum quantities are set per format and confirmed in the supply agreement. Timing is set by the regulatory route, not by production. Artwork approval and a production run take working days, while the route per market sets the launch date, which is why it is settled first.

To discuss a range under your own brand, visit the Partners page and send an enquiry with your market, your current range and an approximate volume. The Partners FAQ answers the questions on files, artwork and lead times.