Follow-up products under your brand: personalized supplements and cosmetics as white label

Reviewed by Dr. Daniel Wallerstorfer, molecular biologist and founder of Novogenia · Updated: 13 October 2026 · Reading time: 10 min

In short

Your genetic or blood data become a product that carries your name: personalized supplements in daily servings and, based on genetic data, personalized skincare with a day serum, night serum and body lotion. Formula, packaging, inserts and shipping run under your brand; supplements are produced from a single unit, cosmetics from small batches. Whoever sells under their own name is responsible for the product, its labeling and its marketing claims. In Germany, the manufacturer or importer notifies food supplements to the BVL (§ 5 NemV) – in most cases Novogenia handles this; Austria has no notification requirement, and Switzerland relies on self-monitoring. For cosmetics, Novogenia takes on the role of the responsible person.

Your name on the breakfast table

A lab report is read, discussed and filed away. A follow-up product sits on the table every morning. Each daily serving is a small business card for your brand – and a reminder that the analysis with you was the beginning, not the end.

For labs, DNA testing companies and health platforms, this means the relationship with the customer does not end with the result. Genetic or blood data turn into a personal product that the customer uses up, reorders and associates with your name. This article shows which follow-up products are possible under your brand, what they look like and who is responsible for what. The partner models are explained in Business models for labs and data owners.

What runs under your brand

At Novogenia, interpretation, formulation, manufacturing, packaging and shipping come from a single source. So your lab or platform coordinates one partner instead of five suppliers. Everything your customers see runs under your brand:

Building block	Under your brand
Saliva kit	in your brand’s design, if the genetic analysis runs through Novogenia
Report	as a report and, on request, via a platform, under your brand
Formula	calculated from your customers’ data
Packaging and inserts	your design – or, to get started, a white box with your sticker
Shipping	directly to your customers
Billing	via Novogenia or via your own system, with Novogenia as your fulfillment partner

Under your brand also means under your responsibility. The business under whose name a food is marketed is responsible for all information about it (Art. 8(1) Regulation (EU) No 1169/2011). And where the law requires the parties involved to be named, for example in the privacy notice, your brand stays in front and the information still stays complete – more in Data protection and roles between lab and manufacturer.

Personalized supplements: from Microtransporter to box

With personalized supplements, each person gets their own formula. To make that work in production, each nutrient sits in its own Microtransporters – tiny pellets from 1.6 mm in diameter. They are combined for each person according to their formula, like building blocks that make a different model every time. This is what the product looks like:

Daily serving in a stick pack: Each daily serving goes into a white, brand-neutral stick pack with a window. Two lines of text of up to 25 characters each make it personal, for example with the customer’s name. If the requirement exceeds the volume of one stick pack, it is split across two.
Box: a dispenser box with 30 or 90 daily servings, fully in your design – or a white box with your brand sticker, the fastest option for getting started.
Subscription: One delivery with 90 daily servings lasts 90 days. The 90-day subscription reorders automatically.
Always recalculated: The formula is recalculated for every production run – with the current age and new questionnaire, blood or genetic results.
Safe limits: Every dose stays within a fixed window and at or below EFSA’s tolerable upper intake levels. Details in Dosing and safety: limits and rules.

Production starts from a single unit. 22 nutrients are in stock as finished Microtransporters, and development takes one week to three months overall. Probiotics are not part of the range. How producing one formula per person works in detail is described in Manufacturing personalized supplements.

Personalized skincare: three products from one genetic profile

If you hold genetic data, you can offer skincare alongside supplements. Under the name BeautyMe, Novogenia makes three personalized products that you can also offer under your own brand: a day serum, a night serum and a body lotion. They are based on the genes behind collagen, UV protection and moisture. The genetic result changes the selection and dosage of the active ingredients in all three products.

Own cosmetics production: The skincare is formulated and filled separately from the supplements in our own cosmetics factory, certified to ISO 22716.
From small batches: You start small and grow with your customer base. Your own formula takes 3 to 5 months of development.
Reorders without a new sample: The skin profile remains in place; your customer reorders without providing a new saliva sample.
One profile, several products: One genetic profile can drive supplements and skincare at the same time. That keeps your range consistent.

If you only hold blood values, a genetic analysis is added for the skincare, because the personalization of the cosmetics is based on genetic data. More about the products in Personalized cosmetics: how genes shape the formula.

Responsibility and notification: Germany, Austria, Switzerland

Food supplements do not need marketing authorization in the EU. However, Directive 2002/46/EC allows Member States to require a notification: the manufacturer or the person placing the product on the market sends the authority a model of the label (Art. 10). For cosmetics, the EU requires a responsible person established in the EU (Art. 4(1) Regulation (EC) No 1223/2009), who notifies the product electronically before it is placed on the market (Art. 13). The countries at a glance:

Topic	Germany	Austria	Switzerland
Notifying food supplements	Mandatory: the manufacturer or importer notifies the BVL at the latest at first placing on the market, with a sample of the label (§ 5 NemV)	Not provided for in the Food Supplements Ordinance (NEMV)	No product notification in the FDHA Ordinance on Food Supplements (VNem); self-monitoring (Art. 26 LMG)
Other duties	Composition and labeling under the NemV and EU law	Composition and labeling under the NEMV and EU law	Maximum amounts under Annex 1 VNem (Art. 2(5)), the name “food supplement” (Art. 3(1)); businesses notify their activity to the cantonal enforcement authority (Art. 20 LGV)
Cosmetics	responsible person in the EU, notification via the CPNP	same	no notification like the CPNP; self-monitoring for foodstuffs and utility articles, which include cosmetics (Art. 5 and 26 LMG)

Important: what counts is the country where you sell, not the country of production. A product made in Austria that you offer in Germany has to be notified to the BVL. In most cases, we handle the notification for you or guide you through it. Both topics are covered in detail in Notifying food supplements and, for cosmetics, Responsible person, safety assessment, notification.

For cosmetics, Novogenia takes on the role of the responsible person. If you have products made under your name, you are legally the manufacturer (Art. 2(1)(d) Regulation (EC) No 1223/2009). By written mandate, you designate us as the responsible person, and we accept the mandate in writing (Art. 4(3)). The safety assessment, product information file and notification then lie with us.

What you may say about your product

A lab enjoys trust – which makes it all the more important that the marketing for the follow-up product stays clean. Three rules go a long way:

Only authorized health claims: Health claims are only permitted if they are authorized and listed (Art. 10(1) Regulation (EC) No 1924/2006), in the wording of Regulation (EU) No 432/2012. Claims about diseases, cure or prevention are off limits.
No disparaging of a normal diet: Labeling, presentation and advertising must not state or imply that a balanced and varied diet cannot provide appropriate quantities of nutrients in general (Art. 7 Directive 2002/46/EC). Switzerland has the same rule (Art. 4 VNem).
Sell personalization honestly: Sell personalization as what it is – a transparently calculated, individually dosed formula – and not as a health promise. A follow-up product is a food supplement, not a treatment; abnormal blood values belong in a physician’s hands.

For cosmetics: they serve to clean, protect, keep in good condition and change the appearance of the skin (Art. 2(1)(a) Regulation (EC) No 1223/2009). Claims must meet the common criteria of Regulation (EU) No 655/2013. What that means in practice is shown in Health claims: what you may advertise and Advertising cosmetics.

Your brand kit: what to prepare

Brand and design: logo, colors and copy for the box and inserts. For the pilot, a sticker on the white box is enough.
Text for the stick pack: what the two lines of up to 25 characters each should say.
Product choice: supplements, skincare or both – and which product you start with.
Target markets: which countries you sell in, because notification, language and labeling depend on it.
Customer service: who answers questions about the formula and who looks after the subscription.
Marketing copy: reviewed before it goes live.

Checklist: a follow-up product under your brand

The follow-up product is chosen: personalized supplements, skincare or both.
The data basis fits: for skincare, genetic data are available or a genetic analysis is planned.
Packaging and inserts are designed, or the white box with sticker has been chosen for the start.
Subscription rhythm, shipping and billing are defined.
The target markets are set; notification is clarified for each country.
For cosmetics, the mandate for the responsible person has been given and accepted.
Marketing claims use only authorized claims and promise no cure.
Data protection and roles are settled before the first data flow.

How we do it at Novogenia

How we bring your follow-up product to life at Novogenia:

All under one roof: genetic lab, food supplement production and cosmetics factory in Eugendorf near Salzburg, Austria – one partner instead of many suppliers.
From a single unit: We produce personalized supplements from a single unit and cosmetics from small batches.
Your packaging: a dispenser box with 30 or 90 daily servings in your design or, to get started, a white box with your brand sticker.
Subscription and shipping: 90-day subscription with automatic reorder, shipping directly to your customers, billing via us or via your own system.
Responsible person: For cosmetics, we take on this role – with the safety assessment, product information file and notification.
Notification: In most cases, we handle the regulatory notification of food supplements for you or guide you through it.
Certified: ISO 22000:2018 and ISO 9001:2015 as well as ISO 22716 for cosmetics, each by Quality Austria.

Frequently asked questions

Can I sell personalized supplements under my own brand?

Yes. Formula, packaging, inserts and shipping run under your brand, and billing goes through Novogenia or through your own system, with Novogenia as your fulfillment partner. Responsibility for the information on the product lies with the business under whose name it is marketed (Art. 8(1) Regulation (EU) No 1169/2011) – for your brand, that is you.

Is there a minimum order quantity?

Novogenia produces personalized supplements from a single unit. Personalized projects typically start with a pilot of 200 to 500 customers. We produce cosmetics from small batches.

Do I have to notify my food supplement?

That depends on the country where you sell. In Germany, the manufacturer or importer notifies the BVL at the latest when the product is first placed on the market, submitting a sample of the label (§ 5 NemV). The Austrian Food Supplements Ordinance does not provide for notification. In Switzerland, the Ordinance on Food Supplements has no product notification; self-monitoring applies (Art. 26 LMG). In most cases, we handle the notification for you or guide you through it.

Who is the responsible person for the cosmetics?

Novogenia. If you have products made under your brand, you are legally the manufacturer (Art. 2(1)(d) Regulation (EC) No 1223/2009). By written mandate, you designate us as the responsible person, and we accept it in writing (Art. 4(3)). The safety assessment, product information file and notification then lie with us; your brand and presentation stay yours.

Can I offer supplements and cosmetics from one profile?

Yes. One genetic profile can drive several products: the supplement formula and the selection and dosage of active ingredients in the day serum, night serum and body lotion. The cosmetics are formulated separately in our own cosmetics production. Their personalization is based on genetic data; if you only hold blood values, a genetic analysis from a saliva sample is added for the skincare.

Follow-up products for your data?

Tell us which data you hold and who your customers are – we will show you which follow-up product fits.

Request a project →Offer for labs

Note: This guide is general information for businesses and professionals and does not replace medical or legal advice. The genetic traits determined in a genetic analysis are well documented (each gene included is backed by at least three independent studies); recommendations derived from them are logical conclusions, not scientifically proven. Regulations can change; errors and changes excepted.