Discussion in 'Labels and Packaging' started by Kari Howie, Oct 12, 2019.
There are two ‘b’s in Babassu.
She had spelled it as Babbassu.
FWIW, at the farmers market in town here there are usually 3 soapers selling soap. Only one of them lists ingredients; one don't even package their bars, and the other one uses plain brown paper (no label).
If I did buy a soap, I would like it to have the precise ingredients listed, and would be avoiding much of the "blurbs". (Maybe because I have to read so much bs when grading... I'm a bit allergic to unnecessary writing even if it's nicely done.)
You still should not talk about "benefits" of your ingredients even on your website...you can still run into trouble for making claims this way
Who said I was making claims? One of the benefits of using an organic/unrefined Cocoa Butter is the lovely cocoa smell. One of the benefits of using RSPO Palm Oil is supporting the sustainable production instead of destruction thereof. I have two test batches curing...one with pumice sand and one with pumice powder. I have no doubts that the powder will offer a gentler exploitation than the sand.
I am aware of how some folks talk about their ingredients...how this ingredient is good for that and that ingredient is good for this and no doubt it is true, BUTT...this is soap. Not including the changes to the ingredients during the saponification process, it’s not a product that remains on your skin but maybe a few minutes between washing it on and rinsing it back off.
The way you worded what you said originally ("benefits of those ingredients") would lead many to believe you are making drug and cosmetic claims...This happens all of the time in this industry...
...And FWIW, exfoliation is a cosmetic claim.
In reviewing my wording..."I save my 'wiggle room" for my Ingredients List on my website. Since I don't want my soap to fall under stricter 'cosmetic' rules, I make no claims on my labels other than it is 'soap'. But on my Ingredients List, I can talk about the benefits of those ingredients."...I can see how you came to your conclusion...sometimes my fingers get to typing before my thought is fully formed or I've just realized what time it was and needed to get going.
That is a $64,000 question. The FDA defines a cosmetic as "a product (excluding pure soap) intended to be applied to the human body for cleansing, beautifying, promoting attractiveness, or altering the appearance." It also says: "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. "
When you exfoliate all you are doing is helping the body do what it is already doing...shedding dead skin cells. Technically you can do this with your fingernails or a washcloth, even a salted soap bar. Unless you look like a snake in the middle of shedding its skin, exfoliating isn't going to make you look better or alter your appearance.
Saying that Pumice Powder is more gentle than Pumice Sand isn't a claim, it's a simple fact. Saying that using Pumice Powder will leave you will glowing skin...that's a cosmetic claim.
Saying that Cocoa Butter contains natural antioxidants isn't a claim, it's a simple fact. Saying or implying that it keeps your skin from aging...that's a cosmetic/drug claim and a false one at that when it comes to its use in soap because soap is a wash on/rinse off products. Coconut Oil has antibacterial properties, but it's doesn't make your soap an 'antibacterial' soap.
Just to CMA, I am looking at submitting my Ingredients description to the FDA because it's all about the soap. I may be a small, making my soap on a dedicated rolling kitchen island in my kitchen, business right now, but my goal is to have a thriving business with a brick & mortar location with a half dozen employees in ten years, and having to hassle with the government in any form at any stage is not in the plan. So do it right now and you won't have to do it right later.
Okay...off to work.
Doncha just luv auto-correct?!
I was wondering when someone was going to comment on that! LOL
@Kari Howie - I would probably change the order of the last two descriptors to"...spa-like and special." Only because I think it flows off the tongue better, and ends the sentence a bit more neatly.
Separate names with a comma.