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Teach Soap • View topic - FDA labeling for soap, don't have to list ingredients?

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PostPosted: Fri Jan 17, 2014 3:15 am 

Joined: Sat May 18, 2013 10:37 am
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http://www.fda.gov/Cosmetics/GuidanceCo ... 074201.htm

So as I read and understand it, MP that would have say these as the main ingredients: Coconut Oil, Palm Oil, Safflower Oil, Glycerin (kosher, of vegetable origin), Aloe Vera Gel, Purified Water, Sodium Hydroxide (saponifying agent), Sorbitol (moisturizer), Sorbitan oleate (emulsifier), Soy bean protein (conditioner) Would fall under the classification of soap and not need the ingredients listed? As would CP, and HP soaps? Not trying to hide ingredients from anyone, just curious. Plus let's be honest it makes the label harder to do at times lol

From their site:
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.

How FDA defines "soap"

Not every product marketed as soap meets FDA's definition of the term. FDA interprets the term "soap" to apply only when

the bulk of the nonvolatile matter in the product consists of 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 [21 CFR 701.20].


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PostPosted: Fri Jan 17, 2014 5:38 am 
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You are correct, true soap as defined by the FDA, does not need to list ingredients on their labels. What that also means is that you can not make any claims of your soap or any ingredients in the soap, except that the fact that it cleans. You can not say moisturizing, conditioning, makes you smell good, etc. If you do that, then you would to follow the FDA's cosmetic labeling guidelines.

Although I prefer to list the ingredients in my soap so people know what's in it. People with allergies really appreciate that.

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PostPosted: Fri Jan 17, 2014 12:33 pm 
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I list everything due to possibility of people's allergies.

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PostPosted: Fri Jan 17, 2014 1:19 pm 
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Yeah is say it's too risky to not label ingredients! Imagine if someone had a skin sensitivity or an allergy. They wouldn't know and that could cause trouble. Some people don't even know they can have reactions to certain stuff. It's a little bit of extra work but I think it could save a lot of potential headaches. You wouldn't want to be at a craft fair and every single person that comes to the table asking for the full ingredients! :lol:

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PostPosted: Sun Jan 19, 2014 11:22 am 

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I believe that by FDA standards M&P is not considered soap. I believe only CP soap is considered soap. Even still, you can also get in labeling problems if people assume certain characteristics, such as moisturizing, exfoliating. It doesn't really matter what you say about your soap, but what people think about your soap that matters. Due to that, it is simpler to just list all of the ingredients. The FDA website can be very useful.


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PostPosted: Mon Jan 20, 2014 7:48 am 

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PostPosted: Mon Jan 20, 2014 8:01 am 
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PostPosted: Sun Jan 26, 2014 6:50 pm 
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I don't sell M&P, so this question is academic: you buy M&P, add... let's say shredded loofah, green oxide, and a fragrance oil. How do you know where to list those ingredients? After all, you don't know how much sorbitol (or whatever) is in the M&P, so how can you list them in the correct order?

Same goes for any pre-made base, I guess.

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PostPosted: Mon Jan 27, 2014 7:17 am 
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From what I learned Melt & Pour is actually considered a cosmetic, which means you would have to label it anyway. As far as listing the ingredients of the base, and using additives. I'm not quite sure about it, but you may be able to list the name of the base and then in parenthesis list the base's ingredients then go on listing the rest of your additives. Like I said I'm not sure, so you'll need to do some more research.

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PostPosted: Mon Jan 27, 2014 7:30 am 
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You don't need to list the name of the base just the ingredients.

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PostPosted: Mon Jan 27, 2014 8:11 am 
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Mine look like this:

Glycerin soap base [ingredients], essential oil [botanical names], colour [mica, iron oxide etc (I list them all)].

If I use additives I put them in in the proper place, generally right after the base. I list them using proper scientific nomenclature; ei: "Butryospermium parkii (shea) butter".

***As an aside, proper scientific nomenclature is usually my breaking point :lol: If I go to buy someones' soap and it is done wrong, my inner scientist screams and I refuse to buy it. A lot of folks try to look professional and use the binomial name (like above) but neglect to understand that capitalization is important. Butryospermium Parkii is listing shea as belonging to two genera and no species. For some reason I see this all of the time, and it drives me completely bonkers! :lol: End of nerdy rant now.. :P ***

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PostPosted: Mon Jan 27, 2014 1:04 pm 
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PostPosted: Tue Jan 28, 2014 5:50 pm 
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PostPosted: Tue Jan 28, 2014 7:03 pm 
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PostPosted: Tue Jan 28, 2014 9:15 pm 
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The FDA can deem the product mislabeled/misbranded and either seize it or make your take it off store shelves.

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