It's all up for interpretation but I believe M&P can be a soap, or a cosmetic, or a drug depending on the ingredients and/or claims made. It is my understanding that if there are no synthetics in your soap (w/ the exception of color, fragrance, etc) & you make zero claims it is a soap. If it has synthetics &/or you make a claim like 'moisturizing' it is a cosmetic. If you make a medical claim EX) helps clear acne or relieves anxiety then it is a drug. The first link will help you decide if your soap is a soap, drug or cosmetic. The second will help you label your item properly depending on which category your item falls within. http://www.fda.gov/Cosmetics/GuidanceComplianceRegulatoryInformation/ucm074201.htm Is It a Cosmetic, a Drug, or Both? (or Is It Soap?) This is how the FDA defines soap: "How FDA defines "soap" Not every product marketed as soap meets FDA's definition of the term. FDA interprets the term "soap" to apply only when the bulk of the nonvolatile matter in the product consists of an alkali salt of fatty acids and the product's detergent properties are due to the alkali-fatty acid compounds, and the product is labeled, sold, and represented solely as soap [21 CFR 701.2017]." http://www.fda.gov/Cosmetics/CosmeticLa ... efault.htm Summary of Regulatory Requirements for Labeling of Cosmetics Marketed in the United States.