From what I understand:
you are only selling soap as a cosmetic IF you are making claims about the soap -- in which case, you have to have had clinical trials and be approved by the FDA.
Soap itself does not have to be labelled if being sold as "soap" with no claims. It doesn't even have to be wrapped.
I sell my soap by the ounce at time of purchase. There is no weight on it because it gets weighed when it is bought. I label it with all the ingredients in decending order and my address is the very last item on the label.
I don't know what others choose to do, but I don't expect any issues.
For those of you who print on Avery type labels -- Office Max is having a 20% sale off of most stuff in the store. The Avery brand is actually less expensive than the Office Max Brand and I got 2730 labels printed and bought 2500 of the labels (2x4) all for $107 (about 4 cents per label!) for my bags. How great is that!
The sale is until Saturday April 27th.
Here's the actual info from the US Food & Drug Admin website:
Most body cleansers on the market today are actually synthetic detergent products and come under the jurisdiction of FDA. These detergent cleansers are popular because they make suds easily in water and don't form gummy deposits. Some of these detergent products are actually marketed as "soap" but are not true soap in the common and legal definition of the word.
If a cosmetic claim is made on the label of a "true" soap or cleanser, such as moisturizing or deodorizing, the product must meet all FDA requirements for a cosmetic, and the label must list all ingredients. If a drug claim is made on a cleanser or soap, such as antibacterial, antiperspirant, or anti acne, the product is a drug, and the label must list all active ingredients, as is required for all drug products
Our ancestors often made their own soap for laundering, cleaning, and bathing from animal fats and wood ashes. Today's soap may contain perfumes, colors, and oils, but if it is represented only as soap it's out of FDA's regulatory bailiwick.
Ordinary soap is regulated by the Consumer Product Safety Commission under authority of the Hazardous Substances Act. CPSC's jurisdiction covers most noncosmetic, nondrug substances used in the home.