Home address on labels

Since finished soap does not contain any sodium hydroxide (properly made) it would not fall under any restrictions for products containing sodium hydroxide.

Exactly Lin. I read ALL of that and the updates over the years. It is perfectly legal to use your po box as your business address. All that is listed as a guide line. My soaps are listed as soaps becuz they are. No cosmetics or detergents in it. I don't even use sodium lactate cuz even though of nature....its a derivative. I use ingredients I can find in the food aisle. Ex: table salt. Same effect.

I don't sell yet but do plan on using a PO Box address. Different states are probably different, but, when you register your business name I think you have to use a physical address. So if anyone decides to sue you they can easily find out where to serve you. That said, for a home business I don't think it is prudent to use your home address on your product for reasons already listed. You have a phone number a website and a mailing address on your label if someone needs to contact you. The authorities can find you by looking up your business info. If you are getting a PO Box, get one at the Post Office not at a private mail box place. The cost is less and you can also get Fedex and UPS deliveries made there by using the street address of the PO and your box number. If you have a box at a private mail place the PO cannot forward your mail from there if you close that box, you have to rely on the owner of the business to send it on to you.

The USPS states that you can use a p.o. box as your permanent address...business address......and I have for nearly 30 years. Mail will get forwarded to home address automatically if p.o. box fails. And the guideline that ways a way to get in touch with the seller stipulates mailing address, email, as well as a phone since some folks don't use a standard phone either.

http://smallbusiness.chron.com/consumer-product-labeling-laws-soaps-detergents-72629.html

"
Address

One issue for some small business manufacturers is the requirement that a physical street address be shown on the label, unless the address is included in a city directory or telephone directory, to comply with the Fair Packaging and Labeling Act. Since fewer city directories are published, and since telephone books usually only include landlines and may or may not include a street address, some with home-based soap-crafting businesses find themselves having to list their home address on their business products. Some have petitioned the FDA to alter the rules to allow P.O. boxes to be used instead."

Again, that some choose not to comply does not change the law, and the FDA (cosmetics) and the Fair Packaging and Labeling Act (soap) are very clear.

eta: Using a P.O. Box as a business address does not have anything to do with labeling laws for commodities. Perhaps that is the source of confusion or disagreement.

http://www.ecfr.gov/cgi-bin/retriev...60&r=PART&n=21y7.0.1.2.11#21:7.0.1.2.11.3.1.1 as of 2/6/2014 these are the guidelines for labeling.

new12soap said:

Address

One issue for some small business manufacturers is the requirement that a physical street address be shown on the label, unless the address is included in a city directory or telephone directory, to comply with the Fair Packaging and Labeling Act.

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I'm not sure where people are reading the part about physical street address. I read the FPLA and it states.

"§1453. Requirements of Labeling; Placement, Form, and Contents of Statement of Quantity; Supplemental Statement of Quantity.

• (a) Contents of label

No person subject to the prohibition contained in section 1452 of this title shall distribute or cause to be distributed in commerce any packaged consumer commodity unless in conformity with regulations which shall be established by the promulgating authority pursuant to section 1455 of this title which shall provide that -

• (1) The commodity shall bear a label specifying the identity of the commodity and the name and place of business of the manufacturer, packer, or distributor;"

I don't read the words "street address". However, Sally's Soaps, MyTown, Washington is a name and place.

peepla said:

http://www.ecfr.gov/cgi-bin/retriev...60&r=PART&n=21y7.0.1.2.11#21:7.0.1.2.11.3.1.1 as of 2/6/2014 these are the guidelines for labeling.

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Those are guidelines for cosmetics, from which soap is exempt .. unless you make statements about your soap that put it into the cosmetic category.

Lin said:

Since finished soap does not contain any sodium hydroxide (properly made) it would not fall under any restrictions for products containing sodium hydroxide.

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Interesting and I like this statement ... buuuutttt ... if you did have to label ingredients what would you put? Saponified oil?

On commercial soaps I see things like sodium tallowate which I understand to be saponified tallow? I'm new and really just trying to understand.

peepla said:

I don't even use sodium lactate cuz even though of nature....its a derivative. I use ingredients I can find in the food aisle. Ex: table salt. Same effect.

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Are there rules about using derivatives?

peepla said:

Exactly Lin. I read ALL of that and the updates over the years. It is perfectly legal to use your po box as your business address. All that is listed as a guide line. My soaps are listed as soaps becuz they are. No cosmetics or detergents in it. I don't even use sodium lactate cuz even though of nature....its a derivative. I use ingredients I can find in the food aisle. Ex: table salt. Same effect.

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I'm curious about where you found the information about the legality of using a PO box as a business address. Could you please share the source?

@ ilovesoap2 & MzMolly65

There aren't any rules for 'derivatives'. I use sodium lactate as an additive in soap and lotions and like the properties it brings to both items.

I list all ingredients which go into soap just in case someone has an allergy or perhaps is looking for a specific ingredient. I list them before saponification since lye takes what it wants and I don't have any way of determining the percentage of oils after saponification for recipes which have oils used in equal weights. So, my label would look like:

Water, Olive Oil, Tallow, Lard, Sunflower Oil, Coconut Oil, Sodium Hydroxide, Castor Oil, Fragrance, Sodium Lactate, Sugar, Tussah Silk, Mica, Titanium Dioxide, Iron Oxide, Chromium Oxide Green, Tin Oxide

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I have seen some labels which state "Saponified oils of olive, palm, coconut (etc)" so sodium hydroxide doesn't have to be listed. However, I'm not sure how they would show or if they did show other ingredients. There are discussions about CP labeling which goes into more detail.

Now, if I knew exactly how much of each oil was left after saponification, I could use INCI terms like commercial manufacturers. If I did, the oils would be proceeded by the word "sodium" to show the conversion to 'salts of fatty acids'. I'm not positive but I think my label would look like:

Sodium Olivate, Sodium Tallowate, Sodium Lardate, Sodium Sunflowerate, Sodium Cocoate, Sodium Castorate, Fragrance, Sodium Lactate, Sugar, Tussah Silk, Mica, Titanium Dioxide, Iron Oxide, Chromium Oxide Green, Tin Oxide

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You might find WSP's Saponified Terms useful. http://www.wholesalesuppliesplus.com/PDFS/SaponifedTerms.pdf

I appreciate the back ground to this, but if someone wanted to just walk up to your house, they can - even if your address is not published anywhere! For every instance of someone taking an address on a product label and doing something nefarious I imagine there are at least 2 instances of someone just picking a random house and doing something nefarious!

In Canada you are required to have your address on the label. Since Health Canada recognizes that not everyone has a physical address, they will allow a box number on the label. I have rented a post office box for this very reason after checking to make sure it was legal by speaking directly with HC...

I don't know the US rules as well as Canada so I can't say what theirs are but I expect they recognize that there are rural makers as well. You can register your business with them at your physical address so they know where to find you and then use a PO Box for your labels I would think. Although you don't have to register with the FDA either do you?

With the actual ingredient label (in Canada) they want what is in the finished product not what was used to create a chemical reaction in order to produce the product. So here we must label using INCI and since Sodium Hydroxide is not in the completed product it is not to be on there, the Sodium part of the INCI covers that since, for instance, Sodium Olivate means Olive Oil Soap and covers the process of saponification. We are also not allowed to use the term of Saponified oils of.....

Hazel said:

@ ilovesoap2 & MzMolly65

There aren't any rules for 'derivatives'. I use sodium lactate as an additive in soap and lotions and like the properties it brings to both items.

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Thank you.

MzMolly65 said:

I'm glad this topic is being discussed and I appreciate you posting that link. For me, it brings up more questions surrounding labeling and here's what I found when I followed your link.

***
How labeling requirements are different

A cosmetic product must be labeled according to cosmetic labeling regulations. See the Cosmetic Labeling Manual for guidance on cosmetic labeling and links to the regulations related to cosmetic labeling. OTC drugs must be labeled according to OTC drug regulations, including the "Drug Facts" labeling, as described in 21 CFR 201.66 Combination OTC drug/cosmetic products must have combination OTC drug/cosmetic labeling. For example, the drug ingredients must be listed alphabetically as "Active Ingredients," followed by cosmetic ingredients, listed in descending order of predominance as "Inactive Ingredients."

And what if it's "soap"?


Soap is a category that needs special explanation. That's because the regulatory definition of "soap" is different from the way in which people commonly use the word. Products that meet the definition of "soap" are exempt from the provisions of the FD&C Act because—even though Section 201(i)(1) of the act includes "articles...for cleansing" in the definition of a cosmetic—Section 201(i)(2) excludes soap from the definition of a cosmetic.

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 701.20].
  

Products that meet this definition of soap are regulated by the Consumer Product Safety Commission (CPSC), not by FDA. Please direct questions about these products, such as safety and labeling requirements, to CPSC.
***

But when I go to the CPSC website and do a search for soap NOTHING comes up. There are regulations surrounding specific ingredients such as sodium hydroxide and the products made that contain that ingredient. Their only comment that I can find relates directly to the need for child proof containers for any product containing more than 10% of total weight sodium or potassium hydroxide but by my calculations most of my soaps contain 8% or less per total recipe so they wouldn't need to conform. I can't find any other regulations on their website pertaining to soap or soap ingredients.

More reading to do .. murky waters indeed.

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I have sent an email to the CPSC asking details about the labeling requirements. Two years later, I am still waiting for their reply. Given this, I figure if we omit our home address nobody is going to come knocking at our door to enforce these rules.

My understanding from a lot of searching is that in the US, if you sell 'just soap' you only need:

1 - to label it as 'soap'

2 - to put the weight - FDA likes both oz and grams. Not sure if the CPSC wants both oz and grams (they never answered!) So no big deal to me, I list the weight in both oz and grams.

3 - the address of the soap maker. This part is where I had my question, do we need to use our home address or a PO box will do? two years later still no answer.

The ingredients do not need to be listed. This is as far as the regulations.

My customers really appreciate me labeling all the ingredients comprehensively and in plain english, so I go beyond the simple regulations. I make my labels for my customers, and since I also sell some cosmetics I label everything according to the FDA rules, it just makes it simpler for me.

So the answer is that yes, unless you are listed in your town phone book (this is very expensive in some towns) the regulations are that your home address should be listed on the soap, but the ingredients do not need to be (funny thing, my customers seem to care a lot more about the ingredients in their soap than where I live....).

Now for the good news, no one is doing it (none of the local soap makers in any case), and no one seems to be enforcing it either.

I have decided to list our company name and our town only. All of my customers know how to find me. Two years later no one has complained about my labels.

I am sure that this rule (listing the home address) will be eventually dropped from the books. It seems there is no real rush to either change it, or enforce it though.

I too perused the CPSC website, to no avail. Has anyone ever been "busted" for not listing their physical address on their labels? Until there are some stories saying they have, if you use a PO Box, keep doing it.

Moody Glenn said:

And this is excellent advice. According to the lawyer that helped form my business LLC, home craftmaking businesses should never include their exact address. Otherwise you have the potential to have weird people stopping by at all hours to sniff the soap, ask for samples, ask if you have kids, dogs, etc. I think you get the general idea. All it takes is one very determined person. Also, your home insurance may not allow you to showcase your home like this. The lawyer recommended to obtain a PO Box number for added communication purposes. Your home is strictly your home. Allow customer business elsewhere.

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Moody Glenn, you and I are on the same page with this. That was going to be my suggestion. Get a P.O box and list that. I purchase home crafts of all sorts (foods and soaps and more). Never have I seen a home address. Just seems irresponsible to give your home address. I don't know who encourages this practice, but obviously YOUR safety isn't high on their list. A person needs to be careful. I have no problem putting my email address, and/or a p.o box...but why would my home address be required? Sounds like just another way to make you wonder if having your own business is worth the risk. I work for a small business (family run) and we work with the public (some vulnerable adults) and even in this business, we are not required to list a home address.

green soap said:

I have sent an email to the CPSC asking details about the labeling requirements. Two years later, I am still waiting for their reply. Given this, I figure if we omit our home address nobody is going to come knocking at our door to enforce these rules.

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New here, I thought I'd share that I contacted the CPSC a number of months ago and did get a reply. It basically said that because there's no Sodium Hydroxide in the finished product it's not in their jurisdiction. I'm not sure where it got started that the CPSC has any rules about soap, but it's just not true. I can dig up the email and copy the exchange (it's brief) if anyone is interested in the particulars. Soap labeling is confusing enough if you want to follow all the rules, it would be great if the CPSC bit could be effectively "debunked"

Soap labeling falls mainly to the FDA and the Fair Labeling Act. I don't sell yet, but when I do I plan to add something to the tune of that the location is not open to the public under the address. I've also considered finding some small space to rent so I could make soap in a location other than my home and be able to use a different address, but I'd still add that the line about not being open to public. I have no aspirations to run a brick and mortar store front, so I'll likely never be in a position where I'd want people thinking they could just pop by.