This is Marie Gale's take on it- Some common drug claims for soap include: “anti-bacterial,”kills fungi,” “treats or cures eczema,” etc. Note that if a claim is made for an ingredient in the soap it is still considered a claim for the soap itself, so claiming that it contains tea tree oil which is “known to be antibacterial” can make the soap a drug. http://blog.mariegale.com/ingredient-labels-soap/ Is SOAP a COSMETIC? IF the soap is "true soap" (made from oil and lye), and the ONLY claims are that it cleanses and is soap, then no, it is not a cosmetics. HOWEVER, if there are ANY claims that it (or any of the ingredients) moisturizes, soothes, softens, exfoliates or anything other that just "cleans", then it is a cosmetic. As a cosmetic, it requires the ingredients to be listed. http://www.mariegale.com/soap-cosmetic-labeling/quick-labeling-faq