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Drugstores and supermarkets: test kits on the shelf – what fits and what applies
What fits on drugstore and supermarket shelves are saliva collection kits for non-medical lifestyle analyses and non-personalized products of your own brand. Personalized supplements and BeautyMe are only made after the analysis and go straight to the customer’s home. After the purchase, the customer registers, gives consent and sends her saliva sample to the lab; the analysis takes 4 days. What is printed on the packaging and the shelf sign is part of the kit’s intended purpose – it speaks of lifestyle, not of diseases. In Switzerland, a kit for self-use is not allowed for lifestyle analyses: there, certain health professionals order the analysis, including druggists HF, and the sample is collected in their presence.
The same box, two legal situations
A saliva collection kit for a lifestyle analysis can stand on the shelf of a German or Austrian drugstore. In a Swiss drugstore, the very same box may not be sold to take home. That is not down to the product but to a deliberate decision by the legislator.
In Germany, the Genetic Diagnostics Act does not list analyses without a medical purpose – such as those on strength or endurance type – in its scope (Section 2(1) GenDG). Austria’s Gene Technology Act only treats as a genetic analysis what allows statements about, for example, a disease risk or an existing disease (Section 4(23) GTG). Switzerland, by contrast, also regulates genetic testing outside medicine – and rules out the self-test for lifestyle analyses. What that means for your shelf follows below.
Think of the kit on the shelf as an admission ticket. It is bought at the checkout, but the show takes place elsewhere: in the lab, in the report and, if the customer wishes, in a product made just for her. For the show to succeed, the ticket has to be printed correctly in the first place.
What fits on the shelf – and what does not
| Product | On the shelf? | Why |
|---|---|---|
| Saliva collection kit for lifestyle analyses | yes, in Germany and Austria; in Switzerland not for self-use | non-medical device, fully stocked with instructions, packaging, return materials and unique labeling |
| Non-personalized products of your own brand | yes | one formula for everyone, in fully printed packaging with a barcode |
| Personalized supplements | no | produced for one person after the analysis and shipped directly; one delivery lasts 90 days |
| Personalized skincare (BeautyMe) | no | mixed for one person and shipped directly |
| Medical genetic analyses | no | where the law requires it, they go through physicians; sales partners do not offer them |
A shelf with a genetic test kit is therefore always the start of a range pathway that takes your customer from the analysis to the repeat purchase. The personalized goods reach her by mail, under your brand if you use white label. Why this interplay works is described in Personalized products in retail.
Lifestyle only – and shelf language to match
In retail, you offer exclusively non-medical analyses, on lifestyle, nutrition, beauty and sport. For these, Novogenia supplies saliva collection kits as a non-medical device, for uses without a medical intended purpose. Medical analyses are only available through physicians, with kits classified as a medical device.
How a kit is classified depends on its intended purpose. Under EU law, that includes the information on the label, in the instructions for use and in promotional or sales materials (Art. 2(12) Regulation (EU) 2017/746, IVDR). What is printed on the box, the shelf sign and the display stand is therefore not just marketing. Three rules keep the language clean:
- Lifestyle, not disease: Talk about nutrition, sport, skin and well-being. In Germany, analyses intended to clarify diseases or health disorders count as diagnostic or predictive genetic examinations (Section 3 nos. 7 and 8 GenDG); in Austria, this covers anything that allows statements about a disease risk or an existing disease (Section 4(23) GTG).
- Watch the trigger words: In Switzerland, food intolerances, metabolic disorders or an increased risk of sports injuries are expressly medical topics (Art. 37(2) GUMV). They do not belong on a shelf sign for lifestyle analyses.
- A report, not a diagnosis: A lifestyle analysis does not constitute a diagnosis or medical advice and does not replace a medical examination. Novogenia’s terms say so, too.
More on how kits are classified in Saliva kits: medical device or not?, and more on permitted advertising claims in Marketing personalized products.
From shelf to lab: what happens after the purchase
- Purchase at the checkout: The kit contains instructions, packaging, return materials and unique labeling, in your brand’s design on request.
- Registration and consent: Before the sample, your customer registers and gives her consent – consent comes before the sample, not after it. How this works technically is something you set up with Novogenia.
- Saliva sample: She collects the sample at home following the instructions in the kit. The unique labeling links the sample to exactly one person.
- Return shipment and analysis: The sample goes to the lab in Eugendorf near Salzburg; the analysis takes 4 days.
- Report: digital via a secure portal, printed on request, in up to 18 languages.
- Personalized product: If she orders personalized supplements or skincare, the product is made for her and shipped directly to her – under your brand if you use white label.
- Next delivery: One supplement delivery lasts 90 days; then the next one follows.
Be honest about the timing: 4 days of analysis plus the time for sample collection and mailing. The analyses are intended for adults; for minors, there are exclusively non-medical analyses, and only with the written consent of their legal guardians. Who is your customer’s contract partner when she buys the kit in your store, and how the analysis and the product are billed, is something you set out in your contract with Novogenia. Each station is shown in detail in The customer journey: from kit to subscription.
Shelf-ready: packaging, barcode, listing
For retail, you generally need fully printed packaging with a barcode and a price calculation that covers the retail margin. A few more points are worth clarifying early:
- Samples: on request for sign-off or for listing approval, before anything is printed.
- Documentation: Retailers may also ask for their own documentation. If you supply a chain as a brand, ask early which documents the buying department needs.
- Shelf life and storage: You receive the details for the kit with the quote; they are also printed on the kit.
- Quantities and lead time: Volume tiers and lead time are part of the quote. Supplements are available from a single unit, cosmetics from small batches.
- Pilot: Test a new line in selected stores first, watch the sell-through and only then roll it out widely.
- Exclusivity: White label means your own brand, not exclusivity. More in Building your own online brand.
How a shelf brand and personalized products work side by side is also shown in Own brand: supplements and cosmetics in the Pharmacy guide; the sales channels are compared in How to sell supplements.
The team at the shelf: five questions, five clear answers
A genetic test kit raises questions – and that is exactly its strength in a store. Your team should be able to answer these five:
- What does the analysis show? How the body handles nutrition, sport or skincare – no diseases, no diagnosis.
- How does it work? Register, give consent, collect the saliva sample at home, send it to the lab; after 4 days of analysis, the report is in the portal.
- Who sees my data? The report sits in a secure portal. Whether you as a retailer see reports is your decision – and your customer should know beforehand.
- What comes next? On request, a personalized product, straight to her home, one delivery for 90 days.
- When do I refer elsewhere? For complaints, illnesses or medications, to a physician.
For professional preparation, there is the NOVO Academy: free and optional, about 5 hours of video per language, with a certificate for each completed topic – in German, English, Czech, French, Portuguese, Italian and Dutch.
Switzerland: no genetic test kit on the self-service shelf
Switzerland regulates genetic testing in the Federal Act on Human Genetic Testing (GUMG), outside medicine as well. Tests of physiological characteristics whose knowledge can influence a person’s lifestyle (Art. 31(1)(a) GUMG) include, according to the ordinance, in particular analyses of eating behavior, physical activity and general well-being (Art. 37(1) GUMV). That is exactly where lifestyle analyses sit. For them:
- No self-test: Ready-to-use tests intended for use by the person concerned may only be supplied for the remaining category of tests (Art. 13 GUMG) – such as hair and eye color or the senses of smell and taste (Art. 37(3) GUMV).
- Ordered by professionals: Only health professionals who are authorized to practice on their own professional responsibility and who acquired knowledge of human genetics in their education and training may order these tests (Art. 34(1) GUMG). The ordinance lists, among others, physicians, pharmacists and druggists HF, i.e. druggists with a diploma from a Swiss college of higher education (Art. 40 GUMV).
- Sample in their presence: The sample is collected in the presence of the person ordering the test (Art. 34(3) GUMG).
- The lab is named: The written information names the lab performing the test, companies and labs abroad that are involved, and the contact details of a professional for questions and of the person responsible for data processing (Art. 32 GUMG). A lab abroad is only permitted with, among other things, the written consent of the person concerned (Art. 36 in conjunction with Art. 29 GUMG).
- Advertising with mandatory information: Public advertising for these tests informs about the rules on ordering, information and communication of the result, and must not be misleading (Art. 14(3) GUMG). Anything that promotes the sale of products for such tests also counts as advertising (Art. 4(3) GUMV).
For Swiss drugstores, this means: a take-home kit is ruled out. A model in which a druggist HF orders the analysis during a consultation and the sample is collected in their presence, on the other hand, matches the structure of the law. Whether and how such an offer can be set up in your drugstore is something we clarify in a personal conversation. A supermarket without a professional who can order the test cannot offer lifestyle genetic analyses as a shelf product in Switzerland. Non-personalized products of your own brand are governed there by the Swiss Foodstuffs Act (LMG). The three countries are compared in Selling genetic tests online: DE, AT, CH and in Law: offering genetic tests in DE, AT and CH.
Checklist: genetic test kits on the shelf
- Only kits for non-medical lifestyle analyses and non-personalized products of your own brand are on the shelf.
- Box, shelf sign and advertising speak of nutrition, sport, skin and well-being – not of diseases.
- Registration and consent before the sample are clarified with Novogenia.
- Contractual roles and billing after the purchase are set out in your contract with Novogenia.
- Personalized products are shipped directly to the customer, under your brand if you use white label.
- Packaging with a barcode, a price calculation that covers the retail margin, and samples for listing approval are prepared.
- A pilot in selected stores is planned.
- Your team can answer the five questions and knows the NOVO Academy.
- In Switzerland, no kit for self-use is sold.
Frequently asked questions
Which genetic test kits can I put on the shelf?
What happens after the customer has bought the kit?
Can a drugstore in Switzerland offer genetic tests?
Do I have to keep personalized products in stock?
What does a product need for a drugstore or supermarket shelf?
Related: Offer for drugstores · Offer for retail and supermarkets · Saliva kits: medical device or not?
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Request a project →Offer for e-commerceNote: 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.
