Soap Labeling Laws

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Kamahido

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When I was doing research for how to properly label my soaps I found in numerous places that regulations state with products (like soap) which undergo a chemical reaction you can either label the ingredients as they went into the pot (i.e. Olive Oil) or as they came out of the pot (i.e. Sodium Olivate). Reason being, I was talking to a long term soap maker who labels oils as "saponified etc" and says that is acceptable. Can anyone give me a link to a .gov website where it definitively says that you can't have ingredient names like "Saponified Olive Oil"?
 

cmzaha

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No, saponified does not work. Sorry I do not have the link, but I found it on FDA's site, stating they do not recognize the word saponified. If using out of the pot you use what comes out of the pot such as Tallowate, Olivate, etc
 

Kamahido

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Yes, I found that as well. I want to find it again so I can print it up to show her next week at the market.
 

penelopejane

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Yes, I found that as well. I want to find it again so I can print it up to show her next week at the market.
There is a lot of handmade soap sold in bricks and mortar shops in the US (in just about every town) that does not list the ingredients. I don't know why anyone would buy soap without ingredients listed.
At least this person is listing them.

I think using "saponified OO" is to avoid mentioning "sodium hydroxide" to prevent a reaction from some customers who say "that's caustic soda I'm not putting that on my skin".

There are stickies with the info you need (depending on country) in the business section of this forum. This is the general one:
http://www.soapmakingforum.com/showthread.php?t=3583
 
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earlene

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This all pertains to the USA only, just to clarify in advance.

I would start here for the US: http://www.fda.gov/Cosmetics/ProductsIngredients/Products/ucm115449.htm

Eventually that takes you here to the Consumer Product Safety Commission, if it is ONLY soap.

I still cannot find anything that specifies how to label soap that is only soap (making no claims and not a cosmetic).

I believe that's because the FDA does not require specific labeling for soap.

If you look here on the Soap Queen's site, you see that plain soap (not a cosmetic) has no labeling requirement by the FDA, and that is true. (see section 701.20)

I DO label my soap, not for sale as I am a hobbiest, and I DO use the words 'Saponified Oils of', then list the oils as I put them into the pot. I do not list lye because that is implied by the word 'saponified'. Since there are no regulations by the FDA, I know I would not be in violation of the FDA. But I do not sell, either.

As far as labeling regulations for soaps that do meet the definition of being a cosmetic, I did not search the labeling regs on that. If you search the FDA website, you should find those regulations here I believe.
 

earlene

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Labeling Requirements for True Soap in the US

I finally found the link I was looking for. It was not easy!

Labeling requirements for True Soap (not a cosmetic or drug) are regulated by the Fair Packaging and Labeling Act. It does not address specifics of nomenclature for ingredients, because ingreadients are not required to be listed for plain (non-cosmetic and non-drug) soap.

See this for Cosmetic Labeling Requirements. It might have what you were looking for regarding nomenclature of ingredients as related to soap claiming cosmetic benefits, but soap without such claims are exempt. Still I do not find the word 'saponified' anywhere in that document, so I don't think it is what you were looking for either.

So I am suggesting that the other vendor may be correct as long as she is not making any cosmetic or drug claims about her soap.

If anyone does or did find a reference that indicates the US gov. disallows the use of the word 'saponified' on soap labels, please let me know. I would certainly like to see it if it exists. Even though I do not sell my soaps, (so this may not really pertain to me) I do give them to friends and family and the main reason I started labeling them was so that they would know what was in them, especially as it relates to ingredients they may cause an allergic reaction.
 

shunt2011

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I thought the same thing. Either you don't label anything or you label everything and saponified is not acceptable. Funny thing, I had a show a couple weeks ago and my mom stopped by to give me a break, she went and checked everything out and stopped by another soapmaker that was making all kinds of claims. She asked if their soap was made with lye and they told her no, they use sodium hydroxide.....ha ha.. My mom didn't know they were the same thing. I really dislike, dishonest people.
 

cmzaha

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I finally found the link I was looking for. It was not easy!

Labeling requirements for True Soap (not a cosmetic or drug) are regulated by the Fair Packaging and Labeling Act. It does not address specifics of nomenclature for ingredients, because ingreadients are not required to be listed for plain (non-cosmetic and non-drug) soap.

See this for Cosmetic Labeling Requirements. It might have what you were looking for regarding nomenclature of ingredients as related to soap claiming cosmetic benefits, but soap without such claims are exempt. Still I do not find the word 'saponified' anywhere in that document, so I don't think it is what you were looking for either.

So I am suggesting that the other vendor may be correct as long as she is not making any cosmetic or drug claims about her soap.

If anyone does or did find a reference that indicates the US gov. disallows the use of the word 'saponified' on soap labels, please let me know. I would certainly like to see it if it exists. Even though I do not sell my soaps, (so this may not really pertain to me) I do give them to friends and family and the main reason I started labeling them was so that they would know what was in them, especially as it relates to ingredients they may cause an allergic reaction.
If you do enough digging through labeling laws you will find that FDA dose not recognize the word "Saponified". Sorry I do not have a link for it but I found it several years ago
 

Cosmo

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According to Marie Gale if a product is sold as just soap and does not make any cosmetic or drug claims you can write the label any way you want. The FDA has no authority over true soap or how it is labeled, so FDA regulation is not a concern in this case.

"Sometimes (often, actually) a soapmaker has a true soap for which no cosmetic claims have been made, but still wants to tell their customers what is in the soap. Since it’s not a cosmetic, the FDA regulations don’t apply, so there is considerably more freedom in what you say.

In this case, you could use “saponified oils of ___”. The ingredients don’t necessarily have to be in descending order of predominance – they don’t even have to all be included."


Link to Marie's site
 

kchaystack

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But it is VERY easy to find your products considered a cosmetic. One mention of moisturizing, conditioning, or nurturing, by you or someone leaving a review on your website or social media and you fall into the new category.
 

Spice

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But it is VERY easy to find your products considered a cosmetic. One mention of moisturizing, conditioning, or nurturing, by you or someone leaving a review on your website or social media and you fall into the new category.
Sounds like taxes, we don't have to pay them; only if you use the roads and sit on park benches; then its tax time.
So might as well get used to making labels. Know the dos and donts that are more important, and.......... the rest.:mrgreen:
 

maya

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You can't just label true soap, only soap any old way you want. The size of the company name, distance from edge of label, placement on package, font size, weights and measures, legibility and readability are all VERY important and legally mandated on labels. I cannot more highly recommend Marie Gale's book about labeling soaps.
 

TeresaT

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You can't just label true soap, only soap any old way you want. The size of the company name, distance from edge of label, placement on package, font size, weights and measures, legibility and readability are all VERY important and legally mandated on labels. I cannot more highly recommend Marie Gale's book about labeling soaps.
It is like watching C-SPAN. Oh my gosh! Just shoot me!! Inner, immediate & outer containers...principle display panel...label vs labeling... I can go on, but I'll spare you the torture. BUY THE BOOK. Marie Gale has listened to those morons drone on and on on C-SPAN and has given us the Cliff's Notes. I purchased the 3rd edition which was updated in 2015.

I cannot imagine watching C-SPAN for more than the 3 seconds it takes to change the channel, and reading government regulations are just as bad. Marie Gale has muddled through regulations and put them into plain ordinary everyday English. She has simplified the rules and regulations so that we can not only make sense of them, but actually follow them. I think I spent about $25-ish on the book. It is worth every penny. She's definitely high on my "hero" list.
 

earlene

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Okay, I found A link, although it is NOT on the FDA website (which regulates cosmetics & drugs), nor on the CPSC website (for true soap), nor any other government site (that I could find as yet). It is on the American Herbal Products Association (AHPA) site. It includes an excerpt from a written response they received from Mr. Lark Lambert of the FDA in which he says, "Neither of the terms "soap" nor "saponified oil" are included in the INCI dictionary."

So if this 7-year old document is still considered current, my guess would be that using the word 'saponified' on 'true soap' would be allowed, but not so on soap that falls into the category of a cosmetic or a drug. Notwithstanding all the other labeling requirements, which as pointed out previously include other detail when the soaps are being sold.

Not that I am selling soap, nor do I ever plan to sell soap. I just like to understand the laws and regulations because that's the way I am. Plus in my former life as a nurse educator, I used to have to wade through federal & state regulations, as well as Joint Commission standards all the time because I was responsible for training our staff to comply with said standards & regulations. Then after retiring as a nurse, my son talked me into opening a restaurant and I had to learn Food Safety and Public Health Safety Regulations and assure that our restaurant complied, which we did and always got 100% on our inspections, btw. But as a result of all that in my past, I have no desire to deal with any of it again on a business level. I want to know and understand it, but that's as far as it goes.


~ ~ ~ ~

ETA: And yes Marie Gale does say that true soaps can be labeled using the word 'saponified'.

Quote from http://www.mariegale.com/ingredient-labels-soap/

Ingredient List When It’s Not Required

Sometimes (often, actually) a soapmaker has a true soap for which no cosmetic claims have been made, but still wants to tell their customers what is in the soap. Since it’s not a cosmetic, the FDA regulations don’t apply, so there is considerably more freedom in what you say.
In this case, you could use “saponified oils of ___”. The ingredients don’t necessarily have to be in descending order of predominance – they don’t even have to all be included.

A Note of Advice

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.


End quote.
 
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Kamahido

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Wow! Thank you all for the responses. This has been quite an informative thread for me. Just goes to show, you think you know something and it turns out wrong. I will continue to label my soaps as I always have, informatively and truthfully and let the chips fall where they may. :neutral:
 

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