A sunscreen stick is one of the easiest private label formats to produce and ship — and one of the harder ones to label correctly. In the US, any product that carries an SPF claim is regulated as an over-the-counter drug, so a small twist-up stick still needs a full Drug Facts panel even though it looks like a cosmetic. In the EU, that same stick is a cosmetic under Regulation (EC) No 1223/2009, with its own ingredient list, responsible person and durability rules. Get the two label sets right once, and a single tested formula can serve both markets; get them wrong, and the first carton may stop at customs.
The stick format changed how brands ship sun care. There is no pump, no nozzle and no pressurized canister — the formula is a solid balm that the user twists up and rubs on directly. Fewer moving parts mean fewer packaging components to source, and a solid format does not leak in a container.
But the format does not change the regulation. What the product does decides how it is labeled. A sunscreen — in a tube, a jar or a stick — is an over-the-counter drug in the United States because its SPF claim is a drug claim. The FDA's cosmetics and OTC resources make the split clear: cosmetics are products applied to the body to clean or beautify, while sunscreens are regulated under the OTC drug monograph because they claim to protect against sunburn. A tinted SPF 50+ stick, like the OEM Custom Face Sunscreen SPF 50+ Travel Tinted Sunblock Stick in Lanthome's private label sunscreen collection, sits at the intersection of both worlds: a drug, plus a color cosmetic.
The practical takeaway for buyers: decide your two or three target markets before you order artwork. The label, not the formula, is where the markets diverge — and the label is the cheapest part of the project to fix.
In the US, the stick's label must identify every active ingredient by name and concentration, and it must carry a Drug Facts panel that follows the same layout consumers know from other OTC medicines. The panel lists the active ingredients, the purpose of the product, directions for use, warnings, other information (including the net quantity and how to store the product), and the name of the manufacturer or distributor.
Two details matter for sticks specifically:
US rules cap how the SPF number is displayed: values above 50 are labeled "SPF 50+". If your formula tests at 60 or 80, the shelf label still reads SPF 50+ — a nuance that surprises buyers coming from markets that print the full number. "Broad Spectrum" may be added when the formula meets UVA protection criteria, and certain claims such as "blocks 100% of the sun's rays" or "complete protection" are not permitted.
The reference product's listing describes a waterproof, long-lasting formula, and that is exactly the claim that needs documentation. Under the OTC sunscreen monograph, a US label may say only "Water Resistant (40 minutes)" or "Water Resistant (80 minutes)" — and only after the formula passes the corresponding in-vivo water resistance test. The word "waterproof" by itself is not an acceptable label claim in the US.
If your formula has not been tested to a specific duration, the compliant path is to leave the water-resistance claim off the US label entirely rather than soften the wording. The EU approach differs: "water resistant" can be used as a claim when substantiated, without the 40/80 minute bracketing. One formula, two different water claims — build both into the label artwork from day one.
In the EU the stick is a cosmetic, and the label follows Regulation (EC) No 1223/2009 rather than the OTC monograph. The minimum information set on the packaging (or the outer carton when the stick itself is too small) includes:
| Element | What to expect on the stick / carton |
|---|---|
| Function | e.g. "Sun protection for the face" |
| Instructions for use | Clear application directions |
| Ingredients | Full INCI list, introduced by "Ingredients:" |
| Responsible person | Name and address of an entity established in the EU |
| Batch number | Traceability code for the production run |
| Durability | Date of minimum durability or the PAO (period-after-opening) symbol |
| Precautions | Warnings where applicable |
| Nominal content | Net quantity (20 g for the reference stick) |
Three EU-specific notes for sun care labels:
The reference stick is tinted — it carries both UV protection and light coverage in one formula. That combination adds one layer to the label set.
In the US, a tinted sunscreen is a combination product: the sunscreen duties above, plus the color cosmetic duties. The colorant must be a color additive that is certified or exempt as appropriate for that cosmetic use, and the ingredient declaration must reflect the full formula. In the EU, the tinted formula is a single cosmetic, so everything — UV filters, pigment, and the hyaluronic acid and niacinamide the reference stick lists as main ingredients — appears in one INCI list.
The formulation itself does not need to change between markets; the label does. If you are planning a tinted line, run the label review before the artwork is printed, because adding or removing the color declaration after plates are cut is the most expensive fix in the project. For a deeper look at supplier evaluation on sun care formulas, see our earlier guide, How to Evaluate a Private Label Sunscreen Manufacturer.
A sunscreen stick is a small mechanical system: a rotating base, an inner cartridge that holds the balm, a housing, and a cap. When you specify the mechanism with an OEM partner, these are the levers that matter:
| Spec (reference stick, model PS66-SP) | Value |
|---|---|
| Form | Solid stick, twist-up |
| Net weight | 20 g (30 / 60 / 150 ml for liquid variants) |
| Color option | Green |
| Single package size | 4.3 × 2.5 × 8.8 cm |
| Single gross weight | 0.049 kg |
| Main ingredients listed | Hyaluronic acid, niacinamide |
| Skin type / age group | All skin types, adults |
| Shelf life (as listed) | 3 years |
The green colorway on the reference model is a buyer-customizable surface — housing and carton colors are standard OEM options, and the label artwork carries your brand, so the mechanism choice should follow your brand palette rather than force it.
Format choice quietly shapes your logistics cost. Aerosol sunscreens carry propellants, which brings dangerous-goods paperwork, restricted airline options and surcharges. A non-aerosol stick typically ships as an ordinary cargo article — no UN classification, no flammable-goods documentation — which is one reason the travel-ready stick has become a favorite for DTC brands that ship direct to customers by air.
Three practical points for buyers:
Retail chains, spas and hotel groups increasingly ask about the plastic bill before they ask about the price. For a stick, the honest answers are simple:
These are positioning decisions, not certification claims. Present them as design choices your OEM can execute, and let the buyer's own compliance team make the final call in their market.
A workable sequence for a private label sunscreen stick, using the reference product's listed parameters as the concrete example:
The reference product page also states that "the product labeling and formula strictly follow according to EU cosmetics standard, avoiding the import problems" — exactly the kind of supplier commitment to get in writing for your own SKU. You can review the company's capabilities on its About Us page, or send the full label draft to the Lanthome inquiry team for a review before you commit to production.
Is a sunscreen stick a cosmetic or a drug in the US?
In the US it is an over-the-counter drug whenever it carries an SPF claim, so the label needs the Drug Facts panel in addition to any cosmetic information. The physical format (stick, lotion, spray) does not change that classification.
Can one formula sell in both the US and the EU?
Yes — the formula is tested once, and the label is adapted per market. The US label carries the OTC drug layout; the EU label carries the INCI list, responsible person and durability information required by Regulation (EC) No 1223/2009.
Why does the label say "SPF 50+" instead of a higher number?
US rules cap the printed value at "SPF 50+", and EU labeling practice uses "SPF 50+" as the top protection tier. A formula that tests higher simply prints as 50+ in both markets.
Does the stick need an expiry date or a PAO symbol?
The EU requires either a date of minimum durability or a period-after-opening symbol, plus a batch number. The US OTC label needs the "other information" block on the Drug Facts panel; a printed durability date is common practice. Confirm the exact requirement for your SKU with your label reviewer.
Can a solid sunscreen stick be shipped by air?
A non-aerosol stick is generally ordinary cargo, and its solid format also keeps it out of consumer carry-on liquid limits. Still, confirm the exact SKU and incoterms with your forwarder, since carrier rules vary.
Is 20 g the only size available?
The reference stick is listed at 20 g, with 30 ml, 60 ml and 150 ml options listed for the family's liquid formats. Custom sizes and formats are standard OEM discussions — bring your retail shelf requirements and ask.
About the Author
This article was prepared by the Lanthome skincare manufacturing team, with experience in private label formulation, packaging development, quality control, and international OEM/ODM projects.
