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FDA Labeling Regulations


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I am about to start selling my soaps and other supplies at my friend's craft store. I read on the FDA website that as long as your product is labeled "soap" and has no medicinal or cosmetic claims, you are not subject to any FDA regulations. How in the world do you label bath bombs and lip balms without making any moisturizing claims? I mean, moisturization is the reason people would use them, right? Do you just put the scent on the label and hope people will figure out the product's usage?

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I aways list all ingredients on my soap and other B & B products and would never label it with just "soap". Way too many people are allergic to some of the ingredients I use, such as shea butter, which is from a nut. I definately don't want someone to sue me because they had a bad reaction to one of my products because there was no ingredient list warning them!!

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I guess my question is ...if you have different types of soap available with different ingredients that help different things, then how would you let your customer know without labeling it? And if you put that on your label, won't you get in big trouble?

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I do have 5 different recipies for my CP soaps, but never say or sell claiming anything other than it is soap, lotion, lip balm, lotion bar, etc. Most people know by the ingredients what will help them and what won't. It could be a big problem saying or even putting it on the label that your products will 'cure' anything, moisturize, zap zits, etc. and I just won't go there!!

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I put the key ingredient in the soap or product name. For example, my vanilla almond buttermilk soap is called exactly that- Vanilla Almond Buttermilk soap. Most people already know what most ingredients do anyway. I also list every ingredient on every product. I won't buy any soap or product without ingredients listed on it, but that is just me.

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I am about to start selling my soaps and other supplies at my friend's craft store. I read on the FDA website that as long as your product is labeled "soap" and has no medicinal or cosmetic claims, you are not subject to any FDA regulations. How in the world do you label bath bombs and lip balms without making any moisturizing claims? I mean, moisturization is the reason people would use them, right? Do you just put the scent on the label and hope people will figure out the product's usage?

SOAP is exempt. Bath bombs and lip balms are not soap. They are cosmetics. You need to follow the laws for cosmetics - and fortunately you are allowed to say they are moisturizing.

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  • 6 months later...
SOAP is exempt. Bath bombs and lip balms are not soap. They are cosmetics. You need to follow the laws for cosmetics - and fortunately you are allowed to say they are moisturizing.

Not true. You can not make any such claim at all. http://www.fda.gov/cosmetics/productandingredientsafety/ProductInformation/ucm115449.htm

And, Noodle, you can't state those ingredients in your name of the soap either. FDA says you can only call it soap. Stupid rule I agree but it says that it leads the consumer to believe that the only thing your soap consists of is "vanilla almond buttermilk". You can only state it is soap and what scent it is.

Just like with lotions, you can not say Goats milk lotion at all. You have call it lotion and the goats milk can be in the ingredients listing but that is it. Granted the FDA is not going to go after all b&b sellers but I am not going to be one that is slapped on the hand for not properly labeling my products.

The FDA can get pretty serious and up your butt if they want too. Look at all these well known cosmetic companies getting "the letter".

http://www.fda.gov/Cosmetics/GuidanceComplianceRegulatoryInformation/ComplianceEnforcement/WarningLetters/ucm081086.htm

Everyone making b&b should read up on the FDA site to avoid the warning letter.More than likely it would never happen but who wants to risk having all your products confiscated and thrown away or a huge fine.

Edited by TexasBrat
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