How To Build A Legally Compliant Vegan Private Label Cosmetics Brand
The market for vegan private label cosmetics is more exciting for beauty brands than ever.
Thanks to new biotech innovations, it’s now possible to create high-quality, effective vegan products using synthetic ingredients that perform just as good as the real thing.
However, creating a legally compliant vegan cosmetics brand can feel overwhelming for a small brand owner.
Even if your lab tells you your products are fully vegan and cruelty-free, the buck ultimately stops with you. This is true even when the mistake is unintentional. And the FTC has taken action in the past.
For example, in 2019, the FTC took action against the cosmetics brand ‘Truly’ for marketing its products as ‘organic’ and ‘vegan’ - despite some products containing ingredients like honey and lactose.
So, how do you choose the right lab and vegan private label products to ensure your brand remains legally compliant?
Innacos is here to help!
Our in-depth guide below discusses the best way to start or level up a private label vegan cosmetics brand in 2026 and beyond.
We cover the latest trends in the cosmetics market and why the animal-based boom is an opportunity for vegan brands - not a threat. We discuss the legal requirements for your vegan cosmetics brand in the US, and how choosing private label can complicate the vetting process even further.
The Market For Vegan Cosmetics In 2026 And Beyond
Animal-based ingredients are having a revival in recent years.
As outlined by Vogue, one of the most popular ingredients in 2026 is PDRN (Polydeoxyribonucleotide) - salmon sperm - with snail mucin, tallow, and collagen among the most popular ingredients in the past five years.
It can be tempting for founders to hop on this trend, but sometimes taking an opposite approach and carving out your own niche is what makes your brand stand out.
While animal-based ingredients are trending, vegan cosmetics are holding their own. According to Fortune Business Insights, the global vegan cosmetics market size was valued at $20.48 billion in 2025, and is projected to grow to $37.43 billion by 2034 - a CAGR of 6.94% over the forecast period.
Although Europe dominated the vegan cosmetics market in 2025 (with a market share of 33.63%), North America is a close second, with the US market projected to reach $4.59 billion by the end of 2026.
Plus, with recent innovations in biotech, lab-made ingredients are more impressive than ever. Vegan brands now have access to ingredients that are virtually identical to animal-derived versions, without compromising on ethics. For example, squalane derived from sugarcane (instead of shark liver oil) is very similar performance-wise to the real deal.
Although Statista reports that as of late 2025, only approximately 6% of the US population are vegan, the total addressable market (TAM) for vegan cosmetics is much higher.
A survey by V label found 85% of consumers regularly use cruelty-free and vegan cosmetics, and a British survey by Cosmetify revealed that 39% of women who only use vegan beauty products are not vegan.
Your market isn’t just people who are vegan: it includes those who strictly only use vegan cosmetics, along with those who view vegan formulas as a bonus.
At Innacos, we offer a wide range of vegan, cruelty-free, clean and sustainable cosmetics on a private label/bulk basis. Look for the ‘vegan’ and ‘cruelty-free’ badges on our product pages to identify the formulas that qualify. Every formula marked with the ‘Innacos’ badge is vegan and cruelty-free by default. View our entire list of private label products and order samples on our website here.
How To Stay Legally Compliant When Building A Vegan Private Label Cosmetics Brand
The first step to creating a compliant vegan brand is understanding the difference between cruelty-free and vegan cosmetics.
Vegan cosmetics are those that do not contain any animal derived ingredients or byproducts at any stage of production.
Meanwhile, cruelty-free cosmetics are products that have not been tested on animals at any stage of the manufacturing process - including by suppliers or third parties.
Cosmetics can be vegan but not cruelty-free. For example, a plant-based serum that was tested on animals by a third party is vegan but not cruelty-free.
Likewise, some cosmetics are cruelty-free but not vegan. This includes formulas that contain animal-derived products like honey or carmine, but were not tested on animals at any stage of the manufacturing process.
Vegan brands need to be aware that most of their consumer base expect formulas that are both vegan AND cruelty-free. Plus, cruelty-free is increasingly becoming a legal standard across the United States, and globally.
For example, in 2020, California passed the Cruelty-Free Cosmetics Act, which banned the sale of cosmetics developed using animal testing. More States soon followed suit, and more are expected to join them in the near future.
At Innacos, not only do we create clean, vegan, cruelty-free, and sustainable formulas, we also provide regulatory compliance services to small beauty brands like yours to ensure your brand is 100% compliant. Learn more about our consulting services on our website here.
The Legal Requirements For Vegan Cosmetics
Although the FDA does not legally define the words ‘vegan‘ or ‘cruelty-free’ when it comes to cosmetic labels, brands cannot put those words on their packaging without any basis. The FDA requires that all labeling and marketing claims be truthful and not misleading.
As the brand owner, you’re legally responsible for making sure your formula contents match up with all the claims you make on your packaging and across your marketing promotions.
For example, if you claim you don’t test on animals, but a third-party lab that tested on your behalf did, that can land you in legal hot water.
Similarly, be cautious when you claim your formula is ‘vegan’ if your supplier has not formally verified the contents of all of their ingredients across the supply chain. The buck ultimately stops with you, and you can’t claim ‘my lab said it was vegan’ as a legal defense.
Vegan Compliance Is Even More Difficult Under Private Label
Be especially cautious if you choose private label as your manufacturing method. Under private label, all of the products are preformulated in advance. You have absolutely no input on what goes into the formula, only on which products you choose to sell.
That’s why you need to ask a lot of questions about each formula before you make your picks. The origins of the ingredients, the supply chain from top to bottom, all the third parties involved - ask for documentation of every stage of the production process to make sure the product is genuinely cruelty-free and vegan.
Be sure to clarify what certifications each formula qualifies for. Having the Leaping Bunny mark or a seal of approval from a Vegan body adds credibility and assurance for your customers that your products match strict cruelty-free and vegan standards.
If you’ve fallen in love with a formula, but it includes just one or two non-vegan/cruelty-free ingredients, consider the custom product creation manufacturing route instead of private label.
This process involves changing a small number of ingredients in a formula, and potentially adding a few more to convert a preformulated product into something more unique to your brand.
If your brand is ready to take the next step up, custom formulating your own line of unique vegan cosmetics is the way to go.
This process involves working with a team of highly trained chemists to create brand new custom vegan makeup or skincare from scratch. Because you have full oversight over each and every ingredient in the formula, you’ve got maximum control to ensure your products are entirely vegan and cruelty-free.
At Innacos, we like to provide as many manufacturing choices for our clients as possible. Not only do we offer a range of vegan and cruelty-free private label cosmetics, but we also offer custom formulating, custom product creation, and contract manufacturing services. Find the right path for your brand by taking our quiz here.
Plus, we can formulate to virtually any certification standard required - including Leaping Bunny and the Vegan Society. Learn more about certifications and standards at Innacos here.
Animal-Based Ingredients Aren’t Always Easy To Identify
For vegan brand owners, staying educated is key to make the right lab selection and choose the right products.
Most people cannot identify vegan ingredients from animal-derived ones. V Label’s 2023 survey of 10,000 consumers found that not one person surveyed could correctly identify all the animal-derived ingredients listed.
The most common ones that tripped people up were guanine, squalene, retinol, or ambergris - with only 18% of those surveyed correctly marking these four as animal-derived.
Guanine is derived from fish scales and used to create shimmer in color cosmetics. Ambergris comes from sperm whales, and is useful in fragrance formulations.
Squalene’s origins are in shark liver oil, used as an emollient. Although many modern retinols are lab-made, animal-derived versions come from fish liver oils or animal liver extracts.
Take the time to learn about the most common animal-derived ingredients still found in cosmetics, and make sure you research each and every ingredient in a private label formula before you sign any contract with a lab.
Other ingredients to watch out for are:
Casein (milk protein, often in hair or nail products)
Carmine (red pigment dye, made from crushed beetles)
Lanolin (from sheep wool, often in lip balms)
Collagen (from animal tissue, common in anti-aging products)
Elastin (animal protein, used in skin care products)
In sum, building a legally-compliant vegan private label cosmetics brand involves the following key steps:
Understanding the current state of the cosmetics market, including new biotech innovations in synthetic ingredients, and what animal-based ingredients are trending
Learning the difference between cruelty-free and vegan, and why both are important for vegan brands
Educating yourself about the legal requirements for vegan cosmetics, and vetting labs thoroughly to ensure you select private label products that are 100% vegan and cruelty-free
Building a knowledge base of common animal-derived ingredients and vetting every formula ingredient by ingredient before signing a contract with a lab
Ready to build your own legally compliant vegan private label cosmetics brand?
At Innacos, we’re experts at clean, vegan, cruelty-free, and sustainable cosmetics. Get in touch to learn more about our preformulated vegan options, or to learn about our custom product creation or custom formulating services for your brand - call: (812) 329-1105 or email: customerservice@innacos.com
