Speaking of Ms Gale, she also says this: The problem with declaring the ingredients based on what comes OUT of the pot is that you don’t (normally) know exactly how much water, glycerin, and unsaponified palm, coconut and olive oils are still in the soap – so you can’t put them in the right order.As for wordsmithing labels in an attempt to hide something, I don't think that's what anyone here intends to do. Using phrases like 'saponified oils of...' is so commonly used on artisan soap labels, that lots of new (as well as old) soap makers see it as an acceptable practice. Why even Marie Gale does not condemn the phrase for soap, which does not require a label (reference).
She also says: If you do decide to put the ingredients on a true soap, be aware that consumers expect that if you say “Ingredients: ____”, you are stating all of the ingredients in descending order of predominance. To withhold ingredients isn’t in violation of the FDA regulations, but it might be considered “deceptive”.
A better way to do it, if you are using non-standard ingredient names (such as “saponified oils of ___”, or are not putting all the ingredients on the list (ie saying “essential oil blend” instead of listing them out), it’s probably better to put it as information, rather than an actual “ingredient declaration.”
Something like “We make our soaps with saponified oils of ___ and scent them with only pure essential oils, including much-loved lavender and patchouli oils.” That makes it more informative, and the consumer can see that it’s not a true ingredient declaration as they normally expect on cosmetics.
As a side note, Ms Gale needs to update her website. Labeling for True Soap is no longer governed by the Fair Packaging and Labeling Act, but by the Consumer Product Safety Commission. CPSC and Soap