How should I list Shea butter in ingredients?

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SomethingGoodAustin

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Hey there;

I have a neem soap with hemp and Shea butter. I list my ingredients in the following manner: Saponified coconut oil, olive oil, neem oil, shea butter... Blah blah, etc. I used to list sodium hydroxide as an ingredient but one of my favorite customers asked me whether it was "natural." It seemed like a real concern for her, so I assumed it could be a concern for others. Since no lye remains in the soap, I feel mostly comfortable leaving it out... But I am curious--were I to rewrite my ingredient list more formally, how would I do that? I know that some soapmaking companies list their ingredients by what I assume are their formal chemical names--"sodium tallowate," (tallow) "sodium olivate (olive oil) and the like. The closest approximation of Shea butter I've found so far, though, is "sodium sheabutterate" and I refuse to believe that is a real word.

I know that somewhere, sometime, someone posted a compendium of INCI-compliant terms. Can anyone point me in its direction? If not, would some kind person dip into the deep pool of collective soapmaking wisdom here and fetch me a cooling bit of knowledge? How does one list Shea butter as an ingredient in soap?
 

snappyllama

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I do not sell, but I'm a dork that tries to make her gifted soaps compliant (more soaping street cred that way).

If you're in the US and you label (if it's just true soap that you're not making any cosmetic claims for you don't have to label at all), you must follow their guidelines for cosmetic labeling: http://www.fda.gov/Cosmetics/Labeling/Regulations/ucm126444.htm

You must label every ingredient in descending order of prominence in the common name. If you include INCI names, you need to put in the parenthesis after the common name and do so for all ingredients. Ingredients used at 1% or less can be displayed in any order.

If you use a mica colorant, it needs to be labeled as with all of its ingredients. This would be the ingredients for MO Voodoo as an example: Mica, Titanium Dioxide, Manganese Violet, Iron Oxide.

Now, I'm pretty sure that the FDA semi-recently decided that you have to use "what goes into the pot" so Sodium Hydroxide has to be in there. I cannot seem to find that copy and haven't reread the regulations in a bit, so you'll want to do your own research there. Other countries (our neighbors to the north), want to see what came out of the pot, so they have to calculate the glycerin created and such to put on their label.
 

SomethingGoodAustin

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I found this:
http://www.soapqueen.com/bath-and-body-tutorials/cold-process-soap/how-to-label-cold-process-soap/
"Soap is a special case when it comes to labeling. The FDA does not require ingredient labeling for soap. That’s right! Nothing."

Hmm. From the FDA website:
"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.
If a cleanser does not meet all of these criteria...
If a product intended to cleanse the human body does not meet all the criteria for soap, as listed above, it is either a cosmetic or a drug. For example:
If a product

  • consists of detergents, or
  • primarily of alkali salts of fatty acids, and
  • is intended not only for cleansing but also for other cosmetic uses,
it is regulated as a cosmetic. Examples of cosmetic uses include making the user more attractive, by acting as a deodorant, imparting fragrance to the user, or moisturizing the skin.
If a product

  • consists of detergents, or
  • primarily of alkali salts of fatty acids, and
  • is intended not only for cleansing but also to cure, treat, or prevent disease, or to affect the structure or any function of the human body,
it is regulated as a drug, or possibly both a drug and a cosmetic. Examples include antibacterial cleansers and cleansers that are also intended to treat acne.
If a product

  • is intended solely for cleansing the human body,
  • has the characteristics consumers generally associate with soap, and
  • does not consist primarily of alkali salts of fatty acids,
it may be identified in labeling as soap, but it is regulated as a cosmetic."
Very interesting. But I'm still left with the question: Is "sheabutterate" an actual word? :)
 

cmzaha

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FDA also does not recognize the word saponified. I also list what goes in the pot not what comes out. If listing what comes out of the pot you would list Sodium Tallowate, Sodium Palmate, etc. Not Saponified Oils of... Shea Butter would be Sodium Shea Butterate
 
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SomethingGoodAustin

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FDA also does not recognize the word saponified. I also list what goes in the pot not what comes out. If listing what comes out of the pot you would list Sodium Tallowate, Sodium Palmate, etc. Not Saponified Oils of... Shea Butter would be Sodium Shea Butterate
Well, humor aside, it appears that soap is not regulated by the FDA, if I'm correctly reading this paragraph from the excerpt I posted above:
"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"
I checked the CPSC website, and couldn't find anything specific regarding labeling.

I've seen a variety of labels and ingredient lists, as well as product descriptions online--most list what goes in, as you put it; very few list what comes out; and a handful of folks have labels and/or listings that provide almost no ingredient information at all (I've even ordered soap off of Etsy and received product with no label whatsoever).
 
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