# Labeling



## elmtree (Oct 19, 2013)

So hubby and I went to a craft fair to check out the local soap/bath and body tables and I was really surprised. None of the four soap/bath and body makers correctly labeled their products. No incl nomenclature and fragrance oils were labeled as "natural fragrance". The preservatives were all labeled as what they were like 'germaben plus", etc. Also, things like "all natural" when obviously fragrance was used. What do you make if this?? Is this typical? 


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## eyeroll (Oct 19, 2013)

"Natural" as a marketing term isn't legally defined in the US (assuming that's where you are), so no, i'm not surprised by that. I basically blow off anything labelled natural as the term is so meaningless. And I think misuse of that term is common across all kinds of industries, not just b&b products. 


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## elmtree (Oct 20, 2013)

Yes, I know that 'natural' is thrown around and put on pretty much whatever companies want. I'm just worried that their ( the other soapers/body product makers)'water, olive oil, cocoa butter, (no one listed sodium hydroxide for soaps) natural fragrance, emulsifying wax, germaben II, etc will look much more 'natural' than my list of ingredients; Aqua, simmondsia chinensis (jojoba) seed oil, butyrospermum parkii (shea) seed oil, steric acid, emulsifying wax, behentrimonium methosulfate (and) cetyl alcohol (and) butylene glycol, tocopherols, phenoxyethanol (and) caprylyl glycol. I thought that legally this was the required labeling format??


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## pamielynn (Oct 20, 2013)

You can only worry about YOUR own products; even though these things bother me too. I sell next to two women who do melt and pour soap - claiming "natural, handmade" and don't list those tell-tale ingredients of MP. I've developed a nice little brochure for myself that is not biased, but does list the differences between the types of soap. I try to explain to anyone who will listen why there are different ingredients in my soap (sodium hydroxide) and why I'd never buy an unpreserved lotion. Try your best to educate your customers and if you have a better product and your ingredients have legit reason for being there - they will appreciate your honesty and quality.


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## FGOriold (Oct 20, 2013)

Don't forget that if a product is labeled only as "soap" without making any cosmetic or drug claims (only that it is soap and that it cleans) you do not even need to disclose your ingredients.  Once you make any claims about what your soap does other than cleanse, you need to follow the labeling requirements.


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## elmtree (Oct 20, 2013)

Thanks, Pamielynn. I was thinking of a nice brochure that explains simply and cleverly about the soap chemical process. I also want to add info cleverly explained about the qualities/benefits  of the most used oils and a short but informative explanation of preservatives and why they are so important. 


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## MaitriBB (Oct 22, 2013)

FGOriold said:


> Don't forget that if a product is labeled only as "soap" without making any cosmetic or drug claims (only that it is soap and that it cleans) you do not even need to disclose your ingredients. Once you make any claims about what your soap does other than cleanse, you need to follow the labeling requirements.


 
This.  And if someone does decide to label ingredients, they're not required to follow INCI regulations.  It's only once something crosses into cosmetic claims ("Moisturizing," etc.) that you need to use INCI.


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## ShayShay (Oct 22, 2013)

> And if someone does decide to label ingredients, they're not required to  follow INCI regulations.  It's only once something crosses into  cosmetic claims ("Moisturizing," etc.) that you need to use INCI.


 As a handmade soap purchaser long before I became a soapmaker and learned about INCI, I would not have bought a soap that listed INCI ingredients. In my mind, it was exactly what I was getting away from with store bought soap. I want to see the ingredients as I know them - Olive Oil, Avocado Oil, etc. Olea europaea and Persea Gratissima would have meant nothing to me (even if Olive and Avocado where listed in parenthesis – I would have stopped reading before that) and I would have put it back down in favor of a soapmaker who listed ingredients that I understood. I don’t sell yet, but I plan on labeling my soap with the ingredient names that most consumers understand. If I ever venture into other products besides soap, I will do what is legally required, but for soap I prefer the common names. 

 Just some perspective from a longtime soap consumer.


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## elmtree (Oct 22, 2013)

I do understand that if you are labeling 'soap', that you can just put the net weight, etc., and keep it very simple if you are not making any claims. However, many soaps I saw listed ingredients (just the regular names), but not sodium hydroxide. If you list ingredients, don't you have to list them all? I'm not asking to be snotty or anything, just trying to understand and I want to be sure I am following the law. I've never labeled any of my lotions or bath products (I'm somewhat new at soaps though) before, just wrote a decorative label out with a name and that's because they were gifts or whatever. So a quote from the FDA states that anything that doesn't fall under the following two conditions is a cosmetic, and therefore requires INCI labeling; 
(1) The bulk of the nonvolatile matter in the product consists of an alkali salt of fatty acids and the detergent properties of the article are due to the alkali-fatty acid compounds; and
(2) The product is labeled, sold, and represented only as soap.

Lotions, scrubs etc. obviously don't fall under the soap category. So listing "optiphen" or "colorants" or "natural fragrance" on a cosmetics ingredient list is accepted? So my question was/is, is this typical (I did find that I don't have to put the "and" in between words though)? Do you think that a brochure explaining common ingredients and listing their Latin name in quotes on the brochure with their benefits will be welcomed? I know that I would read something like that and I would also like to put up pretty, laminated table signs with statements about the products. DO you think this would be welcomed?


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## renata (Oct 23, 2013)

As far as I know...you can avoid listing sodium hydroxide by using the word saponified. Saponified olive, palm, coconut oil etc.
And if you want people to understand you ingredients list, bold the words they undrstand for example: *Saponified olive oil *(olea europaea), *shea butter* (butyrospermum parkii seed oil) etc.


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## elmtree (Oct 23, 2013)

Thats great advice Renata!! Thank you so much. 


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## dagmar88 (Oct 23, 2013)

elmtree said:


> Lotions, scrubs etc. obviously don't fall under the soap category. So listing "optiphen" or "colorants" or "natural fragrance" on a cosmetics ingredient list is accepted?



Absolutely not, they should list the proper INCI names.


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## elmtree (Oct 23, 2013)

dagmar88 said:


> Absolutely not, they should list the proper INCI names.


 
I didn't think so Dagmar, but wanted to be sure. I think I will use Renata's advise and print the common name boldly and say "saponified" in place of sodium hydroxide. I think Dr. BRonners does that.


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## Mommysoaper (Oct 23, 2013)

According to Marie Gale's book, _Soap and Cosmetic Labeling_ some common names for oils are acceptable to use in the ingredient label.  The government recognizes these as correct because they only approved the 2nd edition (I believe, not looking at the book at the moment) of INCI names and that was decades ago.  As far as I know, they haven't approved any more updated versions.  You can use updated INCI, or the approved 2nd edition version of the names which is mostly common names.  Still need to use sodium hydroxide or lye if you're not using "saponified." I do use updated nomenclature on my ingredient labels because I like to be thorough.  It gets to be confusing, but reading Marie Gale's book was helpful and she also has a website where you can ask specific questions.  Don't have the link for that either, but I'm sure it can be googled!   Good luck!

I know it's frustrating when it feels like others soapers aren't following the letter of the law, but you just worry about doing what you need to do.  I worked at a Farmer's Market this summer where 2 other soapers sold their soaps in baggies with no visible labeling that I cold see.  Frustrating, but you can't police everyone!  I like what someone mentioned before about educating your customers.  I did, and it help me create a firm customer base for the season.


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## pamielynn (Oct 23, 2013)

I could be wrong, but "saponified" is inaccurate as you have no way of knowing what's actually BEEN saponified. If you are not going to list the lye, I believe you must use the salt terms: sodium cocoate, sodium palmate, etc.

You could totally make a sign that says "Our lotions are made with olive oil, meadowfoam oil, cocoa butter" etc, as along as the container itself has the ingredients (and preservatives) listed correctly.


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## renata (Oct 24, 2013)

elmtree said:


> Thats great advice Renata!! Thank you so much.



No problem :razz: but I written 'As far as I know' so check outher resources first if this listing is ok.



pamielynn said:


> I could be wrong, but "saponified" is inaccurate  as you have no way of knowing what's actually BEEN saponified. If you  are not going to list the lye, I believe you must use the salt terms:  sodium cocoate, sodium palmate, etc.



Well...it's the same problem here. If you discount lye, some of oils are not saponified. So which oil should one list as not saponified (without sodium..)?


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## dagmar88 (Oct 24, 2013)

pamielynn said:


> I could be wrong, *but "saponified" is inaccurate as you have no way of knowing what's actually BEEN saponified.* If you are not going to list the lye, I believe you must use the salt terms: sodium cocoate, sodium palmate, etc.



Yes. Also, if you're listing what is in there instead of what goes in, you'll need to list glycerin.
For me, educating buyers and listing what my soap is made with, makes a lot more sense.


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## elmtree (Oct 28, 2013)

Yes, that is what I meant by saying "saponified" sorry for the confusion. So you think "sodium cocoate" will sound better than "sodium hydroxide"? Or just try to educate people and put the lye on the label? I was planning on putting the lye on the label. 


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## zieyara (Nov 4, 2013)

i think i like how some company like moogoo listed their ingredients. eg for their goat's milk soap they put ingredients as Goats Milk, Sodium Olivate (Saponified Olive Oil), Sodium Cocoate (Saponifed Coconut Oil), Sodium Palmate (Cert. Sustainable Source), Sodium Cocoa Butterate, Glycerin, Parfum (Phthlate Free).noticed that they opted to use "saponified" and also glycerin as the byproduct. they also tried to educate their customer about what saponification is and how glycerin came by in their product (u cud refer to http://www.moogoo.my/milk-soap/goat-s-milk-soap.html ).


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## elmtree (Nov 6, 2013)

zieyara said:


> i think i like how some company like moogoo listed their ingredients. eg for their goat's milk soap they put ingredients as Goats Milk, Sodium Olivate (Saponified Olive Oil), Sodium Cocoate (Saponifed Coconut Oil), Sodium Palmate (Cert. Sustainable Source), Sodium Cocoa Butterate, Glycerin, Parfum (Phthlate Free).noticed that they opted to use "saponified" and also glycerin as the byproduct. they also tried to educate their customer about what saponification is and how glycerin came by in their product (u cud refer to http://www.moogoo.my/milk-soap/goat-s-milk-soap.html ).



I like that way of labeling as well. We are going with this way ; Olive (olea europaea) oil, etc and we are listing sodium hydroxide but will also try to educate out customers. 


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## kikajess (Nov 6, 2013)

Could "lye" be listed as the ingredient, rather than "sodium hydroxide?" Lye sounds nice and old-fashioned.


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## elmtree (Nov 6, 2013)

kikajess said:


> Could "lye" be listed as the ingredient, rather than "sodium hydroxide?" Lye sounds nice and old-fashioned.



True in the sense that some people feel that lye is old fashioned, however, some people look for soap made without 'lye' lol and I think sodium hydroxide is better in that case (of course if they ask I will tell them what sodium hydroxide is lol).  but saying 'lye' is not inci proper I don't think. I'm just doing the absolute legal route the whole way since I sell lotions and stuff too. Want to keep it all the same label format. 


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