Labeling Question

[CherryGardenGirl]

I've been researching INCI nomenclature and FDA laws on soap labeling. Are all essential oils and the sodium hydroxide required to be on the labels? Lots of Etsy sellers just say 'essential oils' or 'saponified oils of' instead of individually listing the EO's or lye. The Susan Cavitch book claims sodium hydroxide is used as part of the manufacturing process, and although no lye is left in the completed soap, its required to be labeled.

This is confusing! Its understandable how sellers want to protect their secret EO blends and avoid the words 'lye' and 'sodium hydroxide' to make their soap look more natural. But, is it legal to do those two things with labels?

 

[Sunny]

I'm confused about this as well. Zum Bars, for example, look like this:

Saponified 100% food grade olive, coconut, palm & castor oils, in a goat's milk base, with herbs, pure essential oils and mineral pigments.


How can they get away with doing "in a goat's milk base" (what does that mean?) and mineral pigments (what?).

 

[ewenique]

If I understand labeling laws correctly, if you're selling just soap and make no cosmetic claims like "moisturizing, helps eczema", etc., then an ingredient list isn't even required. BUT people are used to seeing one, and with allergies on the rise, it's probably a good idea to have an ingredient list.

If your soap is not a cosmetic, then you don't have to use INCI names, or even list sodium hydroxide. BUT, if you leave just one ingredient out, and the consumer thinks that the list is complete, you could be accused of fraudulent labeling.

Using the term "saponified oils of..." really shouldn't be used either.

I'm still learning the ins and outs of labeling, too. Marie Gale's Soap and Cosmetice Labeling book is very helpful.

 

[Northland Naturals]

even whole foods branded soaps say "saponified oils of olive or palm" i didn't know you could use "or"!

 

[Best Natural Soap]

I thought I knew the answer to this one, but went to the FDA website to check it out first. The site is really helpful- you just have to keep searching, because there is SO MUCH information, and some of it is really buried!!

One of the best resources they have, is a collection of warning letters that have been sent to other soap and cosmetic makers. In them, the violations are listed... and interestingly, not one of them that I read took issue with manufacturers putting "saponified blend of" or "saponified (insert kind) oil." I thought for sure they would not agree with that labeling. I only put the oils I use. I don't list sodium hydroxide, because according to the FDA, you are only required to state the ingredients in your finished product... not all the steps used to get there. And, hopefully- there is no lye in my finished soap!!!

I didn't see any specific mention of listing individual essential oils, either However, the FDA guidelines clearly require "each ingredient" to be listed, in the order of their amount, so that consumers know what they are purchasing. The intent of the labeling guidelines is to allow consumers to make good decisions about what they're purchasing. So, if someone is allergic to cinnamon oil, and they don't see that on the label, they can purchase it, knowing it is not in there. If you simply state "a blend of essential oils" this does not give consumers the information they need to make informed decisions. I think this sets you up for liability issues, as well as letters from the FDA about misleading the public.

Another important issue with FDA and soap, is whether your product is a soap, or a cosmetic. They are very clear here, that if, in any way, you claim, or imply that your product will treat or help ANY sort of skin condition, including something as simple as your soap will "moisturize dry skin," this makes it a cosmetic in the eyes of the FDA. I don't mess around with this. ALL of my soaps are labeled as if they are cosmetics- just in case. Even saying "Lavender has been known throughout the centuries to induce relaxation" on your website, implies to the FDA that you are adding lavender to your soap to induce relaxation. They state that what is important here, is what the CONSUMER believes your product will do for them, even if you don't state it directly. One step of their investigative procedure, involves asking your customers what they believed your product was capable of. So, be very careful with your statements. And, carry liability insurance. I don't want to lose my home or lifestyle, because of someone like the ones who sued McDonald's over hot coffee.

For an example FDA warning letter, check out: http://www.fda.gov/ICECI/EnforcementAct ... 076551.htm
This company manufactures all sorts of things, including soap, and it is definitely worth a look.

 

[Sunny]

Always curious to know: does this mean we can leave "water" off the label as well? I do use water in my soap but hopefully by the time I give it away there is not much left!

 

[CherryGardenGirl]

Anymore ideas???

 

[xyxoxy]

Legal or not I think it's misleading to use "Saponified oils of..." trying to hide the fact that you used lye to make it. I always list sodium hydroxide and I'm fully prepared to explain that true soap cannot be made without it... and properly made soap will not have any trace of it left in it.

The only shortcut I often take is to say "skin safe colorants and fragrances" which I believe is accurate and not a medical claim. If I use an essential oil I specify that but I don't list out each colorant or FO.

 

[smittenheart]

I mention it all too..

distilled water(or whatever liquid that I use) and all the oils and butters as well as the sodium hydroxide and lastly fragrance and color(if I use them)

I post them from greatest to least amounts..

 

[carebear]

Legal or not I think it's misleading to use "Saponified oils of..." trying to hide the fact that you used lye to make it. I always list sodium hydroxide and I'm fully prepared to explain that true soap cannot be made without it... and properly made soap will not have any trace of it left in it.

The only shortcut I often take is to say "skin safe colorants and fragrances" which I believe is accurate and not a medical claim. If I use an essential oil I specify that but I don't list out each colorant or FO.

if you list any ingredients you need to follow the rules for all. the inci for fragrance is "fragrance" so that's fine, but the colorants need to be spelled out.

 

[CherryGardenGirl]

Carebear . . . even though soap isn't a cosmetic, is it still good to use INCI's labeling? And sodium hydroxide does need to be listed? Would that be located in the middle to end of the ingredient list?

I definitely think all EO's, additives, and herbals should be listed! There's a local soap company that sells logs of soap to health food stores. They don't have ingredient labels on their soap and the facial bar that I bought ended up making my hands break out just as bad as with detergents :shock: Imagine how upsetting it was paying over 3 dollars for a teeny bar of soap that I couldn't even use!

Thanks so much everyone!!!

 

[rubyslippers]

I mention it all too..

distilled water(or whatever liquid that I use) and all the oils and butters as well as the sodium hydroxide and lastly fragrance and color(if I use them)

I post them from greatest to least amounts..

That's exactly how I list my ingredients.

 

[ewenique]

It's usually a good idea to follow the rules, even if others don't.

 

[carebear]

Carebear . . . even though soap isn't a cosmetic, is it still good to use INCI's labeling? And sodium hydroxide does need to be listed? Would that be located in the middle to end of the ingredient list?

I definitely think all EO's, additives, and herbals should be listed! There's a local soap company that sells logs of soap to health food stores. They don't have ingredient labels on their soap and the facial bar that I bought ended up making my hands break out just as bad as with detergents :shock: Imagine how upsetting it was paying over 3 dollars for a teeny bar of soap that I couldn't even use!

Thanks so much everyone!!!

If you are labeling with ingredients you should use INCI. As for the sodium hydroxide, some believe they can skip it if they describe the oils as saponified but this is NOT the case. Realistically, the gov't doesn't give a flying rat's patootie about your labels (sad but true) but that doesn't remove the responsibility from the soapers' shoulders to do it right. Unless you are calculating and analyzing all the products of the chemical reactions (including the glycerine, how much water is left, etc., plus anything you don't know is being produced because of additives and what not), and unless you know how much unsaponified oils are left of each type (you really cannot unless you have your soaps analyzed and even then it can shift with time, you need to list the ingredients as you put them in. Commercial soap manufacturers list the saponified fatty acids BECAUSE THAT'S WHAT THEY MAKE THEIR PRDOUCTS WITH. They either purchase or produce and purify those fatty acid salts and add them as such. So unless you are compounding with like materials you simply cannot do that. Your soap is not just saponified oils - it's also free oil (remember your superfat).

I could go on and on.

Think of soap like a cake. Do they list the products of the reactions? Or do they list the ingredients (yes, reactions happen - baking powder, for example)?

Where the NaOH goes depends on where it falls in the order of amounts. List them from greatest to least, tho once you get to 1% or less you can put them in any order you like as long as they all are at the end of the list.

Technically any fragrance material, including EOs, can be grouped as "fragrance" but since FOs have strict limitations to their formulations and usage, but EOs don't - I suggest listing EOs out (I put fragrance, then list the EOs in parens).

 

[Best Natural Soap]

soap labeling

Found some more info on labeling soap:
If your product is truly a soap, and not a cosmetic (see FDA website for the difference), you don't need to list ingredients at all. !!! No kidding. Just the word "SOAP", your business name and address. That's it.

For cosmetic soaps, we may have a choice of whether to list the ingredients before saponification, or the ingredients after saponification.

My family and I are on vacation right now in the Blackhills of South Dakota, and went into Wall Drug Store's Apothecary. They sell LOTS of handmade soaps. The labeling was all over the board- None of them seemed to follow any one particular standard. That just goes to show that there is a lot of confusion over what we're supposed to do.

I just wrote a note to the FDA uaing their "contact us" page, asking for clarification. If I get a response- I'll share it.

 

[CherryGardenGirl]

Re: soap labeling

I just wrote a note to the FDA uaing their "contact us" page, asking for clarification. If I get a response- I'll share it.

Please do share . . . that would be interesting to see what they say!

 

[Best Natural Soap]

Nothing yet- but I'm still waiting. If they really cared a rat's patootie (love that, CareBear), you'd think they'd respond!