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Teach Soap • View topic - US/CDN Label Question

Teach Soap

Soap Making Recipes, Tips and Tutorials
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 Post subject: US/CDN Label Question
PostPosted: Thu Mar 03, 2011 4:31 pm 

Joined: Sat Jan 30, 2010 6:56 pm
Posts: 140
If your a US manufacturer, is it up to you to comply with Cdn label requirements when shipping to Canada? Or the Canadian distributer? Or the reseller, which in this case is me? I just received an order from California with the ingredient list as follows:

“Pure vegetable glycerine soap, fragrance oil and natural mineral pigments”. I know this does not comply with Cdn requirements. And from what I have read here doesn't comply with US regulation either. Don't you have to list what's in the base in the US and the particular fragrance used?

Thanks for any help with this.


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PostPosted: Thu Mar 03, 2011 4:40 pm 
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I do not know Canadian law, but in the US, Soap does not need to be labeled if it is simply soap, and is labeled as such, making no beautifying or conditioning claims. It must also be made of "primarily an alkali salt of fatty acids, and the product's detergent properties are due to the alkali-fatty acid compounds, and the product is labeled, sold, and represented solely as soap." Additionally, customers cannot have the expectation that the soap will do more than clean. Assuming these are met, the soap does not fall under the cosmetic or drug guidelines. See this page for more details; http://www.fda.gov/Cosmetics/GuidanceCo ... 074201.htm and this one too;
http://www.fda.gov/Cosmetics/CosmeticLa ... efault.htm

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PostPosted: Thu Mar 03, 2011 4:55 pm 
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PostPosted: Thu Mar 03, 2011 5:12 pm 

Joined: Sat Jan 30, 2010 6:56 pm
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Thanks!!!

It's actually a large soap making co, not an individual. I "assumed" that they would have the required Cdn requirements when I placed an order recently at the Toronto Gift and Table Trade show.


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PostPosted: Thu Mar 03, 2011 5:25 pm 
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Irena
Closed minds are like faulty parachutes; they refuse to open.


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PostPosted: Thu Mar 03, 2011 5:30 pm 

Joined: Sat Jan 30, 2010 6:56 pm
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I will contact them in the morning. Thanks!

In the meantime I tried to PM you, but I'm computer illiterate and dont know if it went through.


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PostPosted: Thu Mar 03, 2011 5:41 pm 
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Oh no! , for some company who is wholesaling to you for resale, and not for your personal use, they definitely should have a working knowledge of your country's regs., morally for sure. Whether or not it is their legal responsibility to label for your country or theirs, I would think that an attorney should answer, or maybe you could find that out by reading some import regs.

I do not check into the labeling regs of countries that I send my products too since I am bound by the laws where the products are produced. I do have to verify that my products can be imported, and I do that with the USPS. However, if I were to sell items wholesale, I would definitely check into the legalities of this a bit more. Sometimes it is the buyer who has to beware, and sometimes it is the seller, and what is true in the US is not necessarily true in CA. If I were you, I would definitely check with an attorney.

If, however, the attorney says that the seller is liable and should provide the correct Canadian labeling, I would contact the company immediately, and demand that they live up to that or refund your money. While I would like to think that a larger company, especially one participating in a Canadian trade show, would know their legal obligations, sad to say, it doesn't always work that way.

Good luck!

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PostPosted: Thu Mar 03, 2011 6:08 pm 
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PostPosted: Thu Mar 03, 2011 6:30 pm 

Joined: Sat Jan 30, 2010 6:56 pm
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Got the PM Soapbuddy, thanks!

LavenderLady, I did get a hold of my insurance broker, and he said as long as it was a "reputable" company for the US, not to worry. They already are selling across Canada.

I think I read too many forums and get my knickers in a knot :)

I do appreciate all your help.


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PostPosted: Thu Mar 03, 2011 6:39 pm 
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You're welcome Margo.

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PostPosted: Fri Mar 04, 2011 4:31 am 
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PostPosted: Fri Mar 04, 2011 1:49 pm 
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YW and I am glad that you found out for sure! Like I said before, it never hurts to question and seek answers, so no worries about getting too paranoid or reading too much. It could just have easily gone the other way, then where would you have been if you had not checked?
Much luck in selling the soap!

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