Private Label Children’s Products: How to Prepare and Launch Your First Batch

Order the first batch of children’s products under your own brand after the store has identified its customers, the requirements for the specific product, who is responsible for its safety, and the full launch cost. Start with one product or a narrow range: collect customer requests, approve a sample and documents, calculate expenses, and set out acceptance terms in the contract.

When selling in Ukraine, distinguish children’s products by their intended use. Toys, clothing, cosmetics, and furniture have different requirements. If a store commissions a toy and sells it under its own name or trademark, it assumes the manufacturer’s obligations under the Technical Regulation on Toy Safety. Before paying for the batch, the store must therefore arrange conformity assessment, technical documentation, Ukrainian-language labeling, and records that make it possible to trace problematic goods.

Define the product and how it will be used

A private label is a business model in which a store sells goods commissioned from a manufacturer under its own designation. For the first order, prepare a brief description: who will use the product, for what purpose, at what age, where, and under whose supervision. The buyer needs this description to negotiate with the factory, and the safety specialist needs it to identify the applicable requirements.

Under paragraphs 2–3 and Annex 1 of the Technical Regulation on Toy Safety, whether a product qualifies as a toy depends on its intended purpose. For example, baby pacifiers and fashion accessories for children that are not intended for play are not considered toys. Equipment for public playgrounds is excluded from the scope of this regulation. The exception for collectible items has specific conditions, including a visible indication that the item is intended for collectors aged 14 and over.

Exclusion from the toy regulation means that other applicable requirements must be identified. Under Article 2 of the Law “On General Product Safety of Non-Food Products”, special rules for a particular type of product take precedence, while general rules apply to matters not covered by those rules. Before signing an order, ask a qualified specialist to prepare a list of requirements for the chosen clothing, cosmetics, or furniture.

Assess demand before spending on production

The store owner should identify a specific reason to buy. For example, customers are looking for a set of large wooden blocks with simple shapes and clear care instructions. Test the entire concept: the set contents, price, package size, and ease of use.

1. Collect actual customer requests. During a chosen period, sales staff record what customers were looking for, what was missing from the available range, and why they decided not to buy. Mark recurring requests separately.
2. Compare with similar sales. The buyer compares the number of units sold, actual prices after discounts, returns, and remaining stock. Account for days when the product was out of stock, as they distort demand estimates.
3. Show customers the concept. Use a packaging mockup and a description of the planned product. Ask whether they would buy it at a specific price and what they would choose instead. Label the mockup as a concept.
4. Set launch conditions. Before negotiating with the factory, determine the maximum budget, the acceptable number of unsold units, and the period for assessing the first batch. These are the store’s internal management limits.

For planning, divide the number of units in the order by a cautious forecast of weekly sales. This gives an approximate time to sell through the batch. If the factory proposes a minimum order that would take the store too long to sell, discuss a smaller batch, simpler packaging, or fewer variants. Customer interest alone does not confirm that they are ready to buy at the calculated price.

Check the factory and approve a sample

The buyer needs to establish who will sign the contract, where the goods will be made, and who is responsible for the documents. If negotiations are handled by an intermediary, find out how the store will obtain information from the actual manufacturer about materials, the production process, and changes to components.

• Compare the counterparty’s name in the contract and invoice with the details of the payment recipient.
• Request a sample of the exact design being ordered, using the materials and finishes intended for the batch.
• Ask for documents that identify the specific model. Compare the photos, dimensions, composition, and set contents with the planned product.
• Ask whether the factory will subcontract any work and how it will obtain approval for material substitutions.
• Find out the lead time for repeat orders, how defects are handled, and whether samples from each batch can be retained.

After approval, keep one reference sample at the store and another with the manufacturer. Give them a shared identifier and approval date, and add photos and a description to the specification—the contract attachment that sets out the exact product characteristics. The reference sample will help identify deviations during acceptance. Testing and conformity assessment must be arranged separately.

A toy under the store’s brand: who has the manufacturer’s obligations

Consider a hypothetical product: a set of 12 large wooden blocks with a colored finish, no magnets, batteries, or cords, designed for children aged 18 months and over. The final age group must be justified by the product’s characteristics and safety assessment. This set is intended for play by children under 14, so the toy regulation applies.

A store that commissions this set and sells it under its own name or brand meets the definition of a manufacturer in paragraph 4 of the regulation. In addition, paragraph 31 assigns the manufacturer’s obligations to an importer or distributor that places a toy on the market under its own name or brand or modifies it in a way that may affect its compliance. The contract with the factory must therefore enable the store to meet these obligations.

Arrange safety and conformity assessment

Before first placing a toy on the Ukrainian market, the manufacturer analyzes hazards in accordance with paragraph 50 of the regulation. For wooden blocks, the assessment should include, among other things, strength, edges and possible splinters, detachment of parts, finish properties, flammability, hygiene, and packaging. Special requirements apply to products for children under 36 months concerning the size of components and detachable parts, which must prevent swallowing or inhalation. The toy must also be cleanable and remain safe after cleaning in accordance with the manufacturer’s instructions.

Ask a conformity assessment specialist to identify in writing the applicable standards, necessary tests, and procedure. Under paragraphs 51–58 of the regulation, different procedures may apply:

• Internal production control, Module A. This applies if the manufacturer uses national standards from the relevant list that cover all applicable safety requirements. The manufacturer ensures that supporting documentation is available and that production conforms.
• Type examination, Module B, together with conformity to type based on internal production control, Module C. This is required in the cases set out in paragraph 53, including when there are no applicable standards, standards have been only partly applied or not applied, they have relevant restrictions, or the manufacturer considers third-party involvement necessary. Type examination is conducted by a designated conformity assessment body.

When type examination is required, its certificate must relate to a specific toy and include a description, a color image, dimensions, and a list of tests with references to the reports. It is reviewed when necessary, including when the process, raw materials, or components change, and in any event every five years. For procurement, determine the required set of documents based on the procedure used. The CE marking on a box alone does not confirm compliance with the Ukrainian regulation.

Compile technical documentation and the declaration

Appoint someone at the store to be responsible for documents and give that person access to information from the factory. Under paragraphs 59–61 and Annex 4 of the regulation, technical documentation covers the design and manufacturing description, components and materials, safety data sheets for the chemical substances and mixtures used, safety assessment results, a description of the conformity assessment procedure, manufacturing and storage addresses, and the documents and test results required for the applicable procedure.

Once conformity has been demonstrated, the manufacturer draws up a declaration using the form in Annex 3 and affixes the national conformity mark for technical regulations. The declaration must be in Ukrainian or translated into Ukrainian, and it must be kept up to date. In drawing up the declaration, the manufacturer assumes responsibility for the toy’s conformity. The manufacturer keeps the technical documentation and declaration for 10 years after placing the toy on the market.

Compare the model designation in the declaration, reports, specification, and on the product. A change to the varnish, adhesive, or design requires an assessment of its effect on safety and documentation. Agree with the factory that it will notify the store about such changes before implementing them.

Prepare Ukrainian-language labeling and warnings

Before the packaging is printed, the person responsible for the product approves the layout in light of paragraphs 9–11, 36–38, and 44–49 of the regulation. The block set must provide for:

• Toy identification: type, batch number, serial number, model, or another element that makes it possible to identify the toy.
• Manufacturer details: name, registered trade name or registered trademark, and contact postal address.
• Importer details, if applicable: the importer’s relevant name and contact postal address.
• National conformity mark for technical regulations: visible, legible, and indelible; if it cannot be seen through the packaging, it must also appear on the packaging.
• Instructions and safety information: in Ukrainian, with justified age restrictions and required warnings.

Identification details and information about the responsible parties are placed on the toy; under the relevant conditions in the regulation, they may instead be placed on the packaging or an accompanying document. The designer should reserve space for this information and the changeable batch number in advance so the printer can produce legible labeling.

Warnings must be preceded by the words «Увага» or «Попередження» (Ukrainian for “Attention” or “Warning”). They must reflect the actual hazards and intended use of the product. For the described block set, which is designed for use from 18 months, a “3+” marking does not remove the hazard posed by small parts: the design must be safe for the intended age group. A warning that the toy is not suitable for children under three applies under the conditions in Annex 5, not automatically to every toy.

The employee who manages the online store must display warnings that may affect a purchase decision so that customers see them before ordering. Prepare product information, instructions, and warnings in Ukrainian. Other languages may be added, but the required Ukrainian information must remain; this is provided for by Article 30 of the Law “On Ensuring the Functioning of Ukrainian as the State Language”.

Agree on the name and trademark rights before printing packaging

A logo is a graphic presentation of a designation. Having a designer create it does not in itself mean that the trademark is registered. Under Article 5 of the Law “On Protection of Rights to Marks for Goods and Services”, the scope of protection is determined by the registered designation and the list of goods and services. The law also provides protection for international registrations and well-known marks without a Ukrainian certificate.

Before placing a large packaging order, ask a specialist to check the name and image for previously acquired rights and grounds for refusal under Article 6. Identify the goods for which protection is needed. Agree in writing with the factory on the use of the designation, access to layouts, and a prohibition on making third-party orders using your design. For a license to use a registered mark, observe the requirements of Article 16 concerning written form, methods of use, territory, term, and quality control.

What to include in the contract for the first batch

You can use the list below as a brief for preparing the contract. It helps allocate work and costs between the store and factory; the legal obligations of responsible parties remain in force.

• Specification. Model, intended use, age group, dimensions, materials, finish, colors, set contents, packaging, and identification of the reference sample.
• Production changes. Written approval for changes to raw materials, component suppliers, design, and manufacturing location, as well as an assessment of whether additional testing is needed.
• Documents. Who prepares and provides technical information, arranges and pays for testing, draws up the declaration, and provides access to documentation.
• Batch and labeling. The rule for assigning a batch number, applying it to the product, and linking it to delivery documents.
• Acceptance. Location, deadlines, sampling method, list of inspections, recording discrepancies, and conditions for releasing the goods for sale.
• Defects. How the store reports a problem, who determines its cause, how soon the factory must remedy defects, replace goods, or refund payment, and who pays for transportation.
• Unsafe products. Contact persons for urgent communication, provision of batch information, participation in withdrawal or recall, and allocation of related costs.
• Commercial terms. Quantity, price, payment stages, manufacturing and delivery times, steps to take in case of delay, and terms for repeat orders.

Calculate the margin and the money needed for launch

Ask the accountant to separate the costs of purchasing the batch, costs for each sale, and one-time launch costs. Account separately for taxes based on the store’s operating regime and, in the case of imports, applicable customs duties and charges. Do not mix figures that include value-added tax with figures that do not.

Hypothetical example. The store orders 200 sets. All amounts below are hypothetical and use a single basis excluding value-added tax. The calculation excludes the store’s taxes, rent, and labor costs.

Under these assumptions, sales of 120 sets will cover the one-time launch costs: 18,000 ÷ 150 = 120. This is a partial calculation of cost recovery. After all 200 sets are sold, 200 × 150 − 18,000 = 12,000 UAH will remain before other costs and taxes.

The batch and one-time work require 62,000 UAH: 44,000 + 18,000. The owner should add a reserve for expenses incurred before sales revenue comes in, possible returns, defects, and delays. Repeat the calculation with a lower price and fewer sales. For example, at a price of 360 UAH and the same per-unit costs, 110 UAH will remain, and at least 164 sales will be needed to cover 18,000 UAH.

Accept the batch and ensure traceability

Traceability is the ability to establish where a product came from and how it subsequently moved. For the first batch, appoint an employee to receive the goods and a responsible person to authorize their sale after the checks are complete. Until then, keep the delivery separate from stock available to customers.

1. Compare the documents. The model, quantity, batch number, and responsible parties must match across the contract, labeling, and conformity documents.
2. Inspect the delivery. Count the packages and units, record packaging damage and compliance with transport conditions. Take samples from different boxes according to the agreed inspection plan.
3. Compare the goods with the sample. Check the set contents, dimensions, edge finishing, finish, and other agreed characteristics. A visual inspection can reveal visible deviations; hidden hazards must be assessed using appropriate testing methods.
4. Check the labeling. Verify legibility, Ukrainian instructions, required warnings, the conformity mark, and identification details.
5. Record the decision. Write down the results, discrepancies, number of units not released for sale, and the person responsible for follow-up. If there are signs of a safety risk, do not release the affected goods for sale.

Keep a record for each batch: supplier, date and receipt document, model designation, batch number, quantity, storage locations, transfers between stores, returns, and decisions concerning defects. Maintain the link between the goods and their documents even when a new delivery looks no different from the previous one.

Paragraph 32 of the toy regulation requires businesses to be able to identify the businesses from which they received toys and to which they supplied them. For a manufacturer, the period for providing this information is 10 years after the toy is placed on the market; for other businesses, it is 10 years after the toy is supplied to them. The store must also ensure storage and transport conditions that do not compromise product safety.

Track children’s product inventory in Torgsoft

In Torgsoft, open «Склад → Стан складу» (“Warehouse → Stock Status”) to compare the actual availability of goods with the records. An accounting center is a store or warehouse in the program. For a private label, an employee can filter goods by manufacturer or supplier and review quantities, prices, and cost. The “Змінити” (“Edit”) action opens the product card to edit its name and SKU.

If goods are stocked at several stores, the “Усі склади” (“All Warehouses”) toggle and warehouse selection help display stock by the required accounting centers. For discrepancies, use the inventory movement or stock ledger: it shows the balance after receipts, sales, returns, and internal transfers. Compare these records with receipt documents and a separate batch log linking the factory batch number to the delivery.

To manage repeat orders, set a minimum stock level and use the filter for products running low. Before placing another order, compare stock with actual sales, returns, and customer inquiries. Cost and price in inventory records help manage the goods, while the full launch economics should include the store’s one-time and ongoing expenses.

Prepare a response process for defects or safety risks

The salesperson who receives a complaint should record the model, batch number, and problem description, then pass the complaint to the person responsible for safety. For toys, the manufacturer must immediately take appropriate corrective measures in the event of non-compliance and, if a toy presents a risk, immediately notify the relevant state market surveillance authority. These obligations are set out in paragraph 12 of the regulation; the corresponding paragraphs 23 and 29 apply to importers and distributors.

• Stop selling the suspected product. Separate remaining stock, suspend shipments, and notify every store that received it.
• Determine the scope of the problem. Compare the batch number, materials, manufacturing documents, and other complaints. If the boundaries of the problem are unknown, assess related deliveries as well.
• Choose the appropriate measure. Withdrawal from the market prevents further supply of goods through the sales chain. A recall brings back goods already received by consumers.
• Notify the relevant parties. Provide the factory and market surveillance authority with information about the non-compliance, risk, and measures taken. Prepare a clear notice for customers with photos, model, batch, hazard description, required actions, and contact details.
• Record the outcome. Count remaining stock, returns, and other units handled; document what happens to the goods and the conditions for any resumption of sales.

For products covered by general product safety rules, also consider Articles 8–10 of the Law “On General Product Safety of Non-Food Products.” Under this law, recall is an exceptional measure when other measures are insufficient, or it applies on other grounds established by the law. A process agreed with the factory in advance will help obtain the necessary information quickly, organize returns, and determine costs.

When to place a repeat order

Before ordering the next batch, the store owner and buyer review the results for the period set at the outset: number of sales, actual price, remaining stock, returns, defects, complaints, and expenses. Approve a repeat order after assessing these figures and resolving problems that affect product safety or conformity. If the design, finish, or set contents change, first assess the effect on documentation and production.

Regulations to consider when preparing a product for sale

• Resolution of the Cabinet of Ministers of Ukraine No. 151 of 28 February 2018, “On Approval of the Technical Regulation on Toy Safety”: paragraphs 2–13, 17–32, 33–61; Annexes 1–5—scope, responsible parties, safety, documents, conformity assessment, labeling, and warnings.
• Law of Ukraine No. 2736-VI of 2 December 2010, “On General Product Safety of Non-Food Products”: Articles 1–5, 8–10, 12—application of general requirements, obligations of parties in the supply chain, and measures concerning unsafe products.
• Law of Ukraine No. 3689-XII of 15 December 1993, “On Protection of Rights to Marks for Goods and Services”: Articles 5, 6, 16—legal protection of marks, grounds for refusal, and use of a designation.
• Law of Ukraine No. 2704-VIII of 25 April 2019, “On Ensuring the Functioning of Ukrainian as the State Language”: Article 30—the language of product information and customer service.