Facial Soap Bar Label-rules

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Whether you can make these claims or not is pretty much up to you and how many hoops you want to jump through.

A claim of treating medical problems (acne) lands your soap in the drug category. This will require you to do due diligence on the active ingredients you are claiming will treat acne. You will want to adhere to FDA labeling requirements for drugs, which includes calling out the active ingredients that constitute the acne-fighting ingredients in your soap. If your don't have any such active ingredients, you really shouldn't be making this claim for your soap.

Claiming your soap will treat dry skin is (I believe) a cosmetic claim. You would need to adhere to FDA requirements for cosmetic labeling.

This is just a very brief overview, not a definitive answer. The plain-language expert on this is Marie Gale -- check out her website. Also the FDA website has plenty of info about these issues. Get started here -- Frequently Asked Questions on Soap
 
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I agree with what DeeAnna says. You even need to be careful with implied cosmetic/drug claims. Such as "contains tea tree which is known for treating acne". Your best bet is to just label it as a facial bar with no claims other than it cleans your face. I sell a castile soap made with pink clay and charcoal that most customers buy as a facial bar, so I have this marketed as "Gentle cleansing this soap is my recommendation for a facial cleansing bar."
 
[thank you so much!
QUOTE="DeeAnna, post: 829427, member: 9248"]
Whether you can make these claims or not is pretty much up to you and how many hoops you want to jump through.

A claim of treating medical problems (acne) lands your soap in the drug category. This will require you to do due diligence on the active ingredients you are claiming will treat acne. You will want to adhere to FDA labeling requirements for drugs, which includes calling out the active ingredients that constitute the acne-fighting ingredients in your soap. If your don't have any such active ingredients, you really shouldn't be making this claim for your soap.

Claiming your soap will treat dry skin is (I believe) a cosmetic claim. You would need to adhere to FDA requirements for cosmetic labeling.

This is just a very brief overview, not a definitive answer. The plain-language expert on this is Marie Gale -- check out her website. Also the FDA website has plenty of info about these issues. Get started here -- Frequently Asked Questions on Soap
[/QUOTE]

Thank you so much - I agree!! Thank you!
I agree with what DeeAnna says. You even need to be careful with implied cosmetic/drug claims. Such as "contains tea tree which is known for treating acne". Your best bet is to just label it as a facial bar with no claims other than it cleans your face. I sell a castile soap made with pink clay and charcoal that most customers buy as a facial bar, so I have this marketed as "Gentle cleansing this soap is my recommendation for a facial cleansing bar."
 

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