Huh...Who Knew? "True Soap" is exempt from FDA cosmetic label regulations...

[MoonShadow]

Interesting: http://blog.mariegale.com/ingredient-labels-soap/#more-987

[lovemylabs]

There's a lot of good information here. Good reminders

[ChrisR]

Very true on the labeling, BUT I will not buy anyone's soap without a list of the ingredients because of allergies to some of the oils, butters, etc. used. Also, no vegan will buy a soap wihout a list of ingredients to make sure no animal products are use. It's just way easier to list what you use in your soaps.

Also, as it states lots of M&P soaps are not considered 'true soaps' and must list the ingredients as some detergents are used in the bases.

[Flicker]

I just blogged on this a while back. Here is what my blog info stated on the matter with info direct from the CPSC. And I agree with Chris R....LABEL! Even if by common names it should have what's in it for YOUR sake. Cover your own butt! Here is the paste of that section of the blog which can be found here: http://bittercreekcandle.blogspot.com/2012/07/labeling-your-products.html

I am a member of a number of online resources/groups/blogs etc. and lately I have noticed a large increase in the number of questions regarding what needs to be labeled on a cosmetic, soap etc. and what claims can be and can not be made regarding these products.

The FDA guidelines often read with such gray area that I myself find it confusing and often frustrating to read through even after almost 15 years experience in the business!. With the busy holiday season just around the corner, this seemed like a super time to go back over the FDA website to help our customers understand what is needed in body care labeling.

Good manufacturing practices are essential when creating and packaging Cosmetics & Soaps. Often times the gray area I talked about above comes from knowing the difference. Is it soap? Is it a cosmetic? Is it a drug or maybe it's a combination hybrid?! This has been very confusing over the years and this should help clarify this, or that is my hope at least.

True soap is NOT included in regulations by the FDA but rather the Consumer Product Safety Commission: http://www.cpsc.gov/ Over the years this has been a STRONG debate in the world of hand crafted soaps and cosmetics. I actually recently got confirmation on what IS needed on a soap label and what truly defines it as soap directly from the CPSC. This is copied and pasted from a response they emailed to me:

The Consumer Product Safety Commission (CPSC) regulates true soaps that are made primarily of fats and alkalis and that are manufactured for consumer use. The CPSC has no specific labeling requirements for such soaps. However, if the product meets the definition of a hazardous substance, under the Federal Hazardous Substances Act (FHSA) it may require cautionary labeling as specified under the statute.

Section 2(p)(1) of the FHSA, 15 U.S.C. § 1261(p)(1), requires that hazardous substances bear certain cautionary statements on their labels. These statements include: signal words; affirmative statements of the principal hazard(s) associated with a hazardous substance: the common or usual name, or chemical name of the hazardous substance; the name and place of business of the manufacturer, packer, distributor, or seller; statements of precautionary measure to follow; instructions when appropriate, for special handling and storage; the statement “Keep out of the reach of children” or its practical equivalent; and, when appropriate, first aid instructions.

A product is determined to be a hazardous substance if the substance or a mixture of substances is toxic, corrosive, an irritant, a strong sensitizer, is flammable or combustible, or generates pressure through decomposition, heat or other means, and if the substance or mixture of substances may cause substantial personal injury or substantial illness during customary or reasonably foreseeable handling or use, including reasonably foreseeable ingestion by children. A determination that a product is toxic may be based on the results of animal tests or on human experience.

It is the responsibility of a manufacturer or importer of a product to determine whether its product meets the definition of a hazardous substance and, if so, to fulfill its obligations under the FHSA for appropriate precautionary labeling. The U.S. Consumer Product Safety Commission does not perform pre-market clearance for household products containing hazardous substances nor does it certify those products.

The Food, Drug and Cosmetic Act specifically excludes soap because soap is not defined in the act. In administering the act, the Food & Drug Administration interprets the term “soap” to apply only to articles that meet the following conditions:

1) The bulk of the nonvolatile matter in the product consists of an alkali salt of fatty acids and the detergent properties of the article are due to the alkali-fatty acid compounds; and

2) The product is labeled, sold and represented only as soap.

The interpretation goes on to state that products intended to cleanse the body and which are not “soap” as defined above are considered “cosmetics” regulated by FDA.

If your product meets the definition above (1 & 2) then it would be subject to the Federal Hazardous Substances Act. If the product meets the definition of a hazardous substance it is required to be labeled for the hazards it presents to the consumer during reasonable and foreseeable use.

I stand by my long time belief that "MOST" melt and pour soap is still considered a cosmetic and thus requires labeling per the FDA guidelines. If you look at a list of standard ingredients for melt and pour soap, you find that they are primarily comprised of detergents and other chemical ingredients and not fats (vegetable oils, animal fats like lard etc.) and alkalis (potassium or sodium hydroxide) or the product of mixing a fat and an alkali like sodium cocoate = soap created by the combination of sodium hydroxide and coconut oil. This is a list of a pretty basic melt and pour soap:

Glycerin, Propylene Glycol, Sodium Stearate, Sodium Laureth Sulfate, Sorbitol, Cocos Nucifera (Coconut) Oil, Sodium Myristate, Triethanolamine, Sodium Laurate, Sodium Cocoate, Water.

To me that isn't true soap and thus should be labeled as a cosmetic as it is not primarily a fat and alkali base. In this particular melt and pour, the top ingredients, Glycerin and Propylene Glycol are neither a fat OR an alkali.

Although true soap does not require by law ingredients declaration, I personally find it a good practice to always label what is in your product. People often have allergies or are sensitive to a certain ingredient and this way, you are protecting them and yourself by letting them know in advance what is in your product.

[lovemylabs]

We put all of our ingredients on our labels too. Today, many people are allergic to so many things. I'm not willing to take a chance with someones health/life. Plus, we've worked too hard to get where we are NOT to include that information. We appreciate the link to the bittercreek blogspot!

[MoonShadow]

I agree. I just found it interesting. For "True Soap" it seems there's a difference between labeling regulations and best practices.

[TexasBrat]

It's what I've been saying for awhile now. Be careful with your claims on your products, the FDA will have no problem making an example out of little companies.

[kidsngarden]

I list all my ingredients for allergies, etc. and I am VERY careful not to make any claims on my soap whatsoever, not on the label and not even verbally. If they ask something particular about my soap I say, "I make no claims but customers have told me ____" and that is all.

[TexasBrat]

I list all my ingredients for allergies, etc. and I am VERY careful not to make any claims on my soap whatsoever, not on the label and not even verbally. If they ask something particular about my soap I say, "I make no claims but customers have told me ____" and that is all.

You can't do that either. Customers can not make reviews on your website making those claims either. It sucks I completely agree but it is not allowed. Granted not to many people will ever get in trouble but who knows when and where the FDA will strike.

[kidsngarden]

Really? Wow! Well, it's not in writing from anyone at least. I will remember that in the future!