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Private Label Face Masks: Sheet and Clay Masks, MOQs, Rules

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Private label face masks are skin care masks (sheet masks, clay masks, gel and peel-off masks) made by a cosmetics manufacturer and sold under your brand. Sheet masks are mostly made in Korea, with minimums from about 3,000 units at smaller labs up to 100,000 sheets at larger plants. Clay masks are easier to source in the US, with bulk minimums of a few gallons. Two rules shape the category: an acne claim turns a mask into an OTC drug, and imported masks must meet the same FDA rules as US-made ones.

Note that this is about skin care masks, not protective or medical face masks, which are regulated as devices.

Mask types and minimums

From manufacturers’ own published terms:

Manufacturer Location Mask type Published minimum
RainShadow Labs St Helens, Oregon Clay masks 10 gallons for stock private label; custom from 25 gallons
OEMKorea South Korea Sheet masks 3,000 to 10,000 units, depending on format
Seoul Coslab Seoul, South Korea Sheet masks Quoted per project; a first run from about 3,000 units is workable in some categories
Hanform Cosmetics South Korea Sheet masks 100,000 sheets

My take: a clay mask from a US lab is the lower-risk first product. Small minimums, simple formula, short lead time. Sheet masks suit brands ready for import logistics and bigger runs.

Cosmetic or drug: the acne line

The FDA says products marketed to treat or prevent disease, or to affect the structure or function of the body, including the skin, are drugs. Acne products fall under the OTC acne monograph, which permits specific actives at set ranges:

Active Allowed range
Benzoyl peroxide 2.5% to 10%
Salicylic acid 0.5% to 2%
Sulfur 3% to 10%

So a “clarifying clay mask” is a cosmetic, while a mask claiming to treat acne must follow drug rules, including a Drug Facts label. In my view, launch with cosmetic claims (deep-cleansing feel, hydration, glow) and add an acne product only with a manufacturer set up for OTC drugs. Our guide to private label OTC manufacturers explains what that involves.

Importing sheet masks

The FDA says cosmetics imported into the US must comply with the same laws as domestic ones, and that cosmetics other than color additives don’t need FDA approval before sale. Shipments can be held for unsafe ingredients, unapproved color additives, contamination, missing English labeling, or drug claims. Before importing, I’d confirm:

  • every colorant is approved for its use (some must be FDA batch-certified);
  • the label is in English with all required elements;
  • no drug claims appear on packs or inserts;
  • the foreign facility handles its MoCRA registration.

What to ask a mask manufacturer

  1. Serum and sheet material: what’s in the essence, and what the sheet is made of.
  2. Preservation and stability testing, especially for sheet packs.
  3. Color additives and their approval status.
  4. Minimums per formula and per pouch design.
  5. Documents: GMP certificate and Certificate of Analysis, which Amazon may request.

When samples arrive, test the sheet fit on several face shapes and check how much serum is left in the pouch. Those two details drive reviews.

Selling face masks on Amazon

Amazon’s beauty guide lists invoices for 10 or more units, a GMP certificate, a Certificate of Analysis and MoCRA documentation among documents it may request. Masks sell well in multipacks and variety boxes. For related categories, see our hub on private label beauty products and our guide to private label skin care. If you’d like a team to source and vet manufacturers, that’s our complete sourcing management service.

FAQ

What is the minimum order for private label sheet masks?

Korean manufacturers publish minimums from about 3,000 units at smaller labs up to 100,000 sheets at large plants.

What is the minimum order for private label clay masks?

One US lab publishes a 10-gallon minimum for stock private label clay masks and 25 gallons for custom formulas.

Can I say my face mask treats acne?

Only if it’s made and labeled as an OTC acne drug, using permitted actives such as salicylic acid at 0.5% to 2%. Otherwise keep claims cosmetic.

Do imported face masks need FDA approval?

No, cosmetics other than color additives don’t need approval, but imported masks must meet the same FDA rules as US-made ones.

Are skin care masks the same as protective face masks?

No. Skin care masks are cosmetics; protective and medical face masks are regulated differently.

What documents does Amazon need for face masks?

Amazon may request invoices for 10 or more units, a GMP certificate, a Certificate of Analysis and MoCRA documentation.


Last updated: October 6, 2026. General information, not legal advice. Sources: FDA, cosmetics labeling claims; 21 CFR 333.310; FDA, importing cosmetics; FDA, cosmetics importers; Amazon, how to sell beauty products; RainShadow Labs; OEMKorea; Seoul Coslab; Hanform Cosmetics.

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