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The labeling requirements for soap depend on the ingredients and the claims made about the product. If the soap is made primarily of oils and lye, with no cosmetic claims, it is considered true soap and is exempt from FDA cosmetic regulations. In this case, the label must include the name of the product, the net weight, and the name and address of the manufacturer, distributor, or packager. The ingredient list is not required but may be included to meet consumer expectations. However, if the soap contains detergents or other ingredients, or if cosmetic claims are made, it is classified as a cosmetic and must comply with FDA labeling requirements. This includes listing all ingredients in descending order of predominance, using common names or INCI names, and declaring the percentage of each ingredient. For colorants, the individual components of the colorant must be listed, even if the colorant is only present in small amounts. Fragrance oils can be listed simply as fragrance, without disclosing the specific ingredients. Ultimately, soap makers should carefully research the regulations that apply to their specific products and consult experts in the field to ensure accurate and compliant labeling.
Characteristics | Values |
---|---|
Whether or not the ingredient declaration is required | Depends on what the soap is in the eyes of the law, what the ingredients are, and what claims are made about it |
If the ingredient declaration is required | Depends on whether the soap is a consumer commodity, a cosmetic, an insecticide, or a drug |
If the soap is a consumer commodity | The name of the product, the net weight, and the name and address of the manufacturer, distributor, or packager are required on the label; the ingredient declaration is not required |
If the soap is a cosmetic | The label requires the name of the product, what it is, the net weight, the name and address of the manufacturer, and a declaration of the ingredients |
If the soap is an insecticide | It is governed by the EPA's labeling requirements |
If the soap is a drug | It is subject to the FDA drug approval and labeling regulations |
If the ingredient declaration is not required but the manufacturer still wants to list the ingredients | The ingredients don't necessarily have to be in descending order of predominance; they don't even have to all be included |
If the manufacturer decides 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 |
If the manufacturer does not want to put all the ingredients on the list | It is probably better to put it as marketing information, rather than an actual "ingredient declaration" |
If the soap is a cosmetic | The ingredient declaration must be in descending order of predominance, except that ingredients at less than 1% can be listed in any order after the ingredients at more than 1%. There are some other exceptions for FDA-approved colorants and multi-product packages |
If the manufacturer wants to use the "what comes out of the pot" method | They need to know exactly how much water, glycerin, and any unsaponified oils are still in the soap, so they can put them in the right order |
If the manufacturer wants to use the "what goes into the pot" method | They can list the ingredients however they want |
What You'll Learn
- Whether or not the ingredient declaration is required on a soap depends on what it is in the eyes of the law, what the ingredients are, and what claims are made about it
- If the soap is a cosmetic, then the cosmetic ingredient declaration is always required
- The ingredient declaration must be in descending order of predominance, except that ingredients at less than 1% can be listed in any order after the ingredients at more than 1%
- The ingredients need to use the INCI name or the common name if no INCI name is assigned
- For botanicals, the common name is required; the Latin name may be included
Whether or not the ingredient declaration is required on a soap depends on what it is in the eyes of the law, what the ingredients are, and what claims are made about it
Whether or not the ingredient declaration is required on a soap label depends on what it is in the eyes of the law, what the ingredients are, and what claims are made about it.
In the US, the Food and Drug Administration (FDA) does not require soap to be labelled with its ingredients, but it is mandatory in Canada. However, the FDA does require the following information to be included on the label:
- Identity of the product (e.g. "soap")
- Net weight
- Name and address of the manufacturer
If a soap is labelled as something other than "soap", it may be classified as a cosmetic, insecticide, or drug, and therefore require an ingredient declaration.
In the US, if a soap is marketed as having cosmetic benefits (e.g. "moisturising"), it is classified as a cosmetic and must include an ingredient declaration. The ingredient list must be in descending order of predominance, except for ingredients that make up less than 1% of the product, which can be listed in any order at the end. The common name of the ingredient must be used, and the International Nomenclature of Cosmetic Ingredients (INCI) name can optionally be included in parentheses.
If a soap is marketed as having drug-like benefits (e.g. "anti-bacterial"), it is classified as a drug and is subject to FDA drug approval and labelling regulations. If a soap is marketed as an insect repellent, it is classified as an insecticide and is governed by the Environmental Protection Agency's (EPA) labelling requirements.
If a soapmaker chooses to include an ingredient declaration, even when it is not required by law, they should be careful not to present it in a way that could be misleading or confusing for consumers. For example, it should be made clear if the list includes only some of the ingredients, or if it includes the ingredients that went into the soap pot, rather than the ingredients that came out (which will be chemically different due to saponification).
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If the soap is a cosmetic, then the cosmetic ingredient declaration is always required
The ingredients need to use the INCI name or the common name if no INCI name is assigned. For botanicals, the common name is required; the Latin name may be included. It's important to note that the "saponified oil of ____" is not a valid ingredient name.
An ingredient declaration can state what goes into the soap pot or what comes out of the soap pot. Since making soap has a resultant chemical reaction, that gives you two different ways to present the ingredients.
What Goes Into The Soap Pot
In a typical example soap, what goes into the pot is oil, lye, water and additives. Therefore, a valid ingredient declaration would be "Water, palm oil, coconut oil, olive oil, sodium hydroxide, lavender essential oil, and mica."
The oils could also include the Latin name of the plant.
What Comes Out Of The Soap Pot
Using the correct INCI names, what comes out of the soap pot is mostly sodium palmate, sodium coocate, sodium olivate, lavender essential oil and mica. However, there are also water, glycerin and any unsaponified oils.
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 oil, coconut oil, and olive oils are still in the soap—so you can't put them in the right order.
It is possible to calculate the amounts, though.
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The ingredient declaration must be in descending order of predominance, except that ingredients at less than 1% can be listed in any order after the ingredients at more than 1%
When creating a label for a product, it is important to list the ingredients in descending order of predominance. This means that the ingredient with the highest percentage by weight is listed first, followed by the next highest, and so on. This is true for both food and cosmetic products.
However, there is an exception to this rule. Ingredients that are present at less than 1% can be listed in any order after the ingredients that are present at more than 1%. This means that you have more flexibility in how you list these minor ingredients.
For example, let's say you are making a batch of soap and want to list the ingredients on the label. You would first list the ingredients that make up the majority of the soap, such as palm oil, water, and olive oil, in descending order of predominance. Then, you can list any ingredients that are present at less than 1%, such as fragrance or colorants, in any order you choose.
This labelling practice helps consumers understand what is in a product and make informed purchasing decisions. It also allows them to easily identify any ingredients they may be allergic to.
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The ingredients need to use the INCI name or the common name if no INCI name is assigned
When creating a label for your soap, you must list the ingredients in descending order of predominance. The ingredients need to use the International Nomenclature of Cosmetic Ingredients (INCI) name or the common name if no INCI name is assigned. INCI names are based on scientific names, Latin names, and English words. For example, the INCI name and the common name for lye are both "sodium hydroxide."
If you are in the US, INCI names are not required. You only need the common name. However, you can list both to be extra careful. It's also a good idea to list both if you are selling internationally, as the INCI names are global. If you like, you can just list INCI names. However, the common names in parentheses are helpful for people who aren't familiar with INCI names.
- Cedarwood = Cedrus Atlantica (Cedarwood) Bark Oil
- Clove = Eugenia Caryophyllus (Clove) Flower Oil
- Cornmint = Mentha Arvensis (Cornmint) Oil
- Eucalyptus = Eucalyptus Globulus (Eucalyptus) Leaf Oil
- Fir Needle = Abies Sibiricia Oil
- Geranium = Pelargonium Graveolens (Geranium) Oil
- Lavender = Lavandula Angustifolia (Lavender) Oil
- Lemongrass = Cymbopogon Schoenanthus Oil
- Orange = Citrus Aurantium Dulcis (Orange) Oil
- Patchouli = Pogostemon Cablin Oil
- Peppermint = Mentha Piperita (Peppermint) Oil
- Avocado Oil = Persea Gratissima (Avocado) Oil
- Coconut Oil = Cocos Nucifera (Coconut) Oil
- Hemp Oil = Cannabis Sativa (Hemp) Seed Oil
- Jojoba = Simmondsia Chinensis (Jojoba) Seed Oil
- Olive Oil = Olea Europaea (Olive) Fruit Oil
- Palm Kernel Oil = Elaeis Guineensis (Palm) Kernel Oil
- Palm Oil = Elaeis Guineensis (Palm) Oil
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For botanicals, the common name is required; the Latin name may be included
When creating a label for soap, the requirements vary depending on the nature of the product and the claims made about it. If the soap is a "true soap" as defined by the FDA, it is exempt from FDA cosmetic regulations, and its labelling requirements are governed by the Fair Packaging and Labeling Act. This means that an ingredient declaration is not required. However, if the soap is marketed as a cosmetic, drug, or insect repellent, different regulations apply.
In the United States, when listing botanical ingredients on a soap label, the common name is required, and the Latin name may be included. This is because the Fair Packaging and Labeling Act (FPLA) specifies that when ingredients must be listed, the common or usual name is used. The FPLA directs the Federal Trade Commission and the Food and Drug Administration to issue regulations to implement these requirements. The FDA is responsible for the regulations applying to foods, drugs, and cosmetics.
According to the FPLA, for botanicals, the name should be either as identified in the CTFA Cosmetic Ingredient Dictionary, Second Edition (1977), which listed botanicals by their common English name, or if not listed there, the name generally recognised by consumers. The CTFA (now called the Personal Care Products Council) has since published several editions of the Cosmetic Ingredient Dictionary, using different nomenclature for botanicals. However, the FDA has made it clear that they want the common name as the primary name for botanical ingredients, with the option to include the Latin name as a secondary name in parentheses.
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Frequently asked questions
Technically, you do not need to list the ingredients on your soap label. However, it is recommended to do so as consumers often want to know what is in the product they are buying.
You can simply list "fragrance" on your soap label.
You should list the common name of the colorant on your soap label. For example, mica or titanium dioxide.