Was reading a thread on a forum site where someone had asked if anyone listed ingredients on the soap they sell. Most soap makers do list ingredients so the consumer knows exactly what they are buying; but how they labeled varied greatly. One gal even stated she never listed lard on her list (even though it was part of the recipe) because she had a few folks that wouldn’t buy soap that contained lard.
Here are the basic rules that need to be followed and hope will remove a lot of the confusion out there.
The FDA describes soap as ‘A product which the non-volatile portion consists principally of an alkali salt of fatty acids’. This means the combining of an alkali –usually sodium or potassium hydroxide, with fatty acids which are animal or vegetable fats or oils. Additives may be included such as scent, herbs, colors, etc., as long as the additives do not significantly change or violate the FDA’s definition of soap.
From there soap can be considered a consumer commodity-meaning it is sold strictly as a product that will clean & nothing more. So selling soap that just cleans exempts the product from the FDA regulations of labeling ingredients-does not exempts a seller from the FTC Fair Labeling & Packaging Act of providing contact information along with weight of the products and such.
Now, if the seller claims – soothing, moisturizing, beautifying, or any other type of cosmetic claim, the product no longer a consumer commodity but a cosmetic and now falls under the FDA regulations of labeling ingredients -all ingredients must be listed along with FTC guidelines.
Listing ingredients in descending order –the highest percentages ingredient listed first, next highest percentage and so on will always be considered correct.
Many of us make the mistake of labeling ingredients as Saponified Coconut Oil, Palm Oil, etc., thus omitting the listing of sodium or potassium hydroxide in the ingredient label since it is implied with the term ‘Saponified’. I have done this in the past thinking it was proper; but it isn’t. The type of lye used must be listed as a separate item in its proper place within the ingredient list.
If you have an ingredient list that looks like it is complete; but leave something out intentionally, you are now doing deceptive labeling under FTC-the Fair Trade Commission. One could be held liable if those with allergies to the omitted ingredient bought and used your product thinking it was safe for them based on your ingredient listing.
Using terms on labels such as ‘Repels Insects’ now makes the product fall under EPA labeling requirements & usually must be approved by the EPA before marketing-unless made only using ingredients from their pre-approved list.
If you label your soap as something that cures, treats, or prevents a disease or any function of the body now drop kicks your product into the drug category and requires FDA approval before being marketed.