Teach Soap

Hi All
Would this description classify this as a soap or a cosmetic and would it make a difference if it were called a creme?

"This scent is all about happiness and light. It contains a lot of fresh orange notes, with additional notes of Apple, Grapefruit, Peach and Strawberry with just a touch of Loganberry.

Wonderfully thick, fluffy and moisturizing whipped body butter soap. Absorbs quickly into the skin and does not leave you feeling greasy. Just super soft, moisturized, and smelling yummy.

Made with a blend of wonderfully nourishing oils. This is definitely a must have treat. Your skin will thank you..."
einnoc

_________________
"Soap is to the body what laughter is to the soul!"

Soap does not absorb into your skin. I think they are walking a very fine line with the word "moisturizing". Technically, as soon as any product changes the skin's structure it's an OTC (over the counter) drug.

http://www.fda.gov/cosmetics/guidanceco ... 074201.htm

_________________
Irena
Closed minds are like faulty parachutes; they refuse to open.

Hi Soapbuddy,
I'm trying to write descriptions for my soaps; so I'm reading a lot of soap descriptions.
This is really difficult for me. I'm trying to be creative, but not cross that line into cosmetics or drugs.
This one was interesting to me because of the word moisturizing.
It does seem to be crossing the line.
Thanks,
einnoc

_________________
"Soap is to the body what laughter is to the soul!"

Moisturizing is an okay word to keep it out of the "drug" category. But once you say it does anything but cleansing, then it becomes a cosmetic. Which is fine really as long as you list all the ingredients on your soap.
I was recently in another forum where we recently had a discussion about words that can be used and all of the FDA stuff.

If you'd like I can go hunt for that list and post it here.

_________________
Please visit my blog

Hi Wintermoon,
So you think this description is okay?
"This scent is all about happiness and light. It contains a lot of fresh orange notes, with additional notes of Apple, Grapefruit, Peach and Strawberry with just a touch of Loganberry.

Wonderfully thick, fluffy and moisturizing whipped body butter soap. Absorbs quickly into the skin and does not leave you feeling greasy. Just super soft, moisturized, and smelling yummy.

Made with a blend of wonderfully nourishing oils. This is definitely a must have treat. Your skin will thank you..."

I would love to have that list posted if you can find it. This would be wonderful. I would love to look at it.
Thank you so much! Writing these descriptions is more difficult than making soap!
einnoc

_________________
"Soap is to the body what laughter is to the soul!"

I didn't realize that it's a body butter soap. So it would be considered a cosmetic anyway because it's not really soap.
I was wondering how soap was absorbing into the skin LOL
Here's the types of words and descriptions you cannot use when talking about a cosmetic:
-Protects/relieves or soothes abrasions/bites/insect bites/cuts/nicks/irritated skin/inflamed skin/rashes
-Therapeutic effect
- Heals
- Removes/reduces scars
- Works on/from the inside
- Skin lightening/whitening (unless concealer/pigmented product)
- De-pigmentation
- Reduces the appearance of veins, capillaries, etc. (unless concealer/pigmented product)
- Repairs the skin's moisture barrier(replenishes is okay,though)
- Thins hair/hair is finer
- Reduces the appearance of hair (unless by bleaching)

Here's the types of words you can use when you're talking about a cosmetic
- Relieves/alleviates dry skin (do not use the word irritated)
- Soothes (when qualified in a cosmetic sense)
- Softens skin
- Moisturizes/hydrates/ lubricates
- Promotes elasticity
- Protects skin against the abuse of the elements
- Prevents damage caused by drying/dryness
- Protects against and alleviates chapping, cracking and roughness due to dryness
-Moisturizes the skin
-Tones skin by moisturizing
- Firms skin (from an appearance perspective)
- Replenishes/protects the skin's moisture barrier

Now if you are just talking about regular soap and you don't want it regulated as a cosmetic, then you can only talk about it's great cleaning abilities.

_________________
Please visit my blog

Thanks Wintermoon! This is wonderful!
I think I will just say, "This is soap to clean yourself with!"
einnoc

_________________
"Soap is to the body what laughter is to the soul!"

Well if it's a body butter soap, it's not actually soap. It would be cosmetic.
How FDA defines "soap"
http://www.fda.gov/Cosmetics/GuidanceCo ... 074201.htm
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].

So, if you are calling it body butter soap and it's intended use is to clean and help moisturize, then it's a cosmetic. The only other special thing that is required for you to do when making cosmetics is that you list all ingredients on your labels. So, if you were already listing all ingredients, then really there's nothing for you to change

Remember that drug and cosmetic are completely different things. A lot of us sell cosmetics (lip balms, lotions, bath salts, bath bombs, etc.). Drugs are something that you cannot sell without registering with the FDA.

_________________
Please visit my blog

I forgot to add that when/if you're using mp bases, check to see if they're cosmetic or soap. Some are soap and some are considered cosmetics. That way you know exactly how to label them.

_________________
Please visit my blog

Hi Wintermoon,
Thank you. I didn't know this about the MP bases.

How about including a letter about my soap's ingredients, liability with an order?
When I first started making soaps, I bought a lot of handmade soaps online.
Some people did not label their soaps but sent a letter with their soaps about ingredients, suggesting a patch test be done
before the soap was used just in case of an allergic reaction occured from the "natural" ingredients, stating that they could not possibly be liable for every ingredient in the soap.
I must say this creeped me out at first, but the soaps were lovely after I bravely used them!
einnoc

_________________
"Soap is to the body what laughter is to the soul!"

"stating that they could not possibly be liable for every ingredient in the soap."

Legally I don't think that would stand up in court. But now, if you are listing all the ingredients, who's going to use something that they know they are allergic to? But I guess that's another reason why insurance is so important.

Also, I may be wrong, but I believe that the ingredient list does need to be connected to the product in some way. Because otherwise the letter could get misplaced when someone buys the soap to give as a gift for someone else.

I'm going to ask this question and try not to make it sound rude or judgemental LOL
Do you not usually list ingredients when labeling your products?
Even with actual soap, they must have a label stating that it is soap, the weight and where and who it is made by.

_________________
Please visit my blog

Hi Wintermoon,
You do not sound rude or judgemental in any way. You sound helpful! Thank you.
I am just at the beginning stages of setting up my ETSY shop & this summer I am planning on doing Farmer Markets in the town where I live. I am still writing descriptions!

I have made labels and I do include weight & that it is an actual soap and my company name (which changes every day!).
I am hesitant to state my location, but plan to state my ETSY address & future website.

I guess I will have to put a separate label with ingredients on the back.

There are so many things I want to make now! I am making body butters & lotion bars now & some body creams.
WOW! This soap making is catchy and addictive! and NOT cheap, especially to produce quality products which is what I want to do!

Thank you.
einnoc

_________________
"Soap is to the body what laughter is to the soul!"

_________________
Just living is not enough. One must have sunshine, freedom, and a little flower.
Hans Christian Andersen
www.etsy.com/shop/AngieLady
Sunshine Bath & Body

Hi Angielady,
I thought I read somewhere that a P.O. Box could not be used as an address. It had to be a physical address.
I'm not sure where I saw this. I must be wrong.

I agree. It is better to be careful and the customer is always right - even when they aren't!

einnoc

_________________
"Soap is to the body what laughter is to the soul!"

Yep, it's good to get in the habit of doing everything right, right from the beginning.
It's a lot of work to get everything all figured out and done right, but in the long run it's worth it.

_________________
Please visit my blog