# Labeling Your Soap



## RedBeanBear (Mar 12, 2011)

Hello all ~ I currently put ALL ingredients on my soap label, as I thought was mandatory and necessary for soap that is sold to consumers. Recently I came across a ZUM Bar soap, and their ingredients on their labels are vague. They do not list every ingredient used. I am curious as to what is MANDATORY to list on my soap labels, as I do not want to involve every ingredient I use (for copyright/infringment matters). Any comments would greatly help, Thanks!!


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## soapbuddy (Mar 12, 2011)

If it's in the US, just as long as it's real soap, you don't need to list your ingredients. With that said, if you do list them, you need to list all.


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## RedBeanBear (Mar 13, 2011)

soapbuddy said:
			
		

> If it's in the US, just as long as it's real soap, you don't need to list your ingredients. With that said, if you do list them, you need to list all.



Thanks, soapbuddy ~ I wonder why Zum Bar can list some, but not all? 

appreciate it


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## soapbuddy (Mar 13, 2011)

RedBeanBear said:
			
		

> soapbuddy said:
> 
> 
> 
> ...


You're welcome. I have no idea how they can list only a partial list. I guess because they can get away with it, but that's not right.


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## kelleyaynn (Mar 13, 2011)

Do you need to list the sodium hydroxide, since by the time it is soap there isn't any left?   I'm guessing yes, but ...


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## Dremma (Mar 14, 2011)

As soapbuddy said, in the US ingredient lists are not required on the label if it qualifies as a 'soap' and is only sold as a soap.   If you do this, it does have to be labeled correctly as a soap - for example, it has to have the actual word 'soap' in the main product name, your company address in a specific way on the front, etc. 

If you make any cosmetic claims about the soap then you must go by the cosmetic label guidelines.  For that you are required to list the ingredients, in INCI form, as well as meet other requirements.  Again...everything has to be done in the correct way for that specific type of label.

There is also a drug classification.  I never did get into that or the labeling and don't know anything about it but you need to do that correctly if you claim that something treats acne, dandruff, etc.  Anything that is considered a health condition gets into drug classification.

I don't know why they would use partial ingredient lists.  Or is the wording perhaps just making it appear that way?  Some things, like 'fragrance' are very vague but it's correct labeling.  Or is it a description, rather than an actual ingredient list?  

As for the lye question, there is no lye in finished soap.  If you are listing your ingredients on a cosmetic label, then it has to have the correct INCI names.  So for example, a coconut oil soap you would list as 'Sodium Cocoate' which is the INCI name for coconut soap - that is _already saponified_ coconut oil - lye does not exist in it anymore.


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## Genny (Mar 14, 2011)

I find it so annoying when businesses do partial lists, usually only listing the things that they think are the "good things."

Personally, I don't buy soap without knowing what's in it.


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## dagmar88 (Mar 14, 2011)

Dremma said:
			
		

> As for the lye question, there is no lye in finished soap.  If you are listing your ingredients on a cosmetic label, then it has to have the correct INCI names.  So for example, a coconut oil soap you would list as 'Sodium Cocoate' which is the INCI name for coconut soap - that is _already saponified_ coconut oil - lye does not exist in it anymore.



Well.... you can list what is in there. And you'll run into a couple of problems. 
How much glycerine to list.
how much water is still in there by the time you sell
You'll have to list unsaponified oils separately but each oil behaves differently so you won't know how much of it hasn't reacted with the lye.

So I list what goes in there instead of what is in there. Including naoh & koh.

Aside from that, companies that use 'sodium cocoate' propbably buy pre saponified oils. So they list what goes in too.

_Zum bar ingredients:
What's inside? Ingredients you can pronounce.
Saponified 100% food grade olive, coconut, palm & castor oils, in a goat's milk base, with pure essential oils and mineral pigments.

cut>We start from scratch with goat's milk because its pH balance is a near twin to your skin, so it leaves your skin feeling ultra moisturized<cut_

And what if it's "soap"?

FDA info:

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].

If a cleanser does not meet all of these criteria...

If a product intended to cleanse the human body does not meet all the criteria for soap, as listed above, it is either a cosmetic or a drug. For example:

If a product --

    * consists of detergents or
    * primarily of alkali salts of fatty acids and
    * is intended not only for cleansing but also for other cosmetic uses, such as beautifying or moisturizing,

it is regulated as a cosmetic.


IMO their labeling is not just vague, it is incorrect. I know you see a lot of people selling online that do not meet up the the FDA guidelines and regulations.
I know that can hurt when you are working your a** off to do so. 
But in the end, their insurance does not cover malpractices. Now I really don't hope for anyone to get hurt, nor lose everything in court, but I'd much rather be on the safe side.


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## ironbrewer (Mar 16, 2011)

dagmar88 said:
			
		

> Well.... you can list what is in there. And you'll run into a couple of problems.
> How much glycerine to list.
> how much water is still in there by the time you sell
> You'll have to list unsaponified oils separately but each oil behaves differently so you won't know how much of it hasn't reacted with the lye.
> ...




This is the big thing I have been wondering about. The soaps I plan on selling are cream soaps, which use a combination of KOH and NaOH. I figured I would list the ingredients that I actually put into the soap rather than try to guess how the chemical reactions happened.


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## Healinya (Mar 16, 2011)

This may seem off topic, but I think it's relevant.... There is an outdoor restaurant nearby that has bands playing most nights... they are open until midnight, which is a problem for the neighbors who want to sleep... The cops were called every night because of the noise violation... The owners were given a $60 citation every night... After a brief phone call with an attorney, they realized that there options were to close at 9pm and avoid the fine... or keep their hours and receive a $60 fine every day, while making an extra $2000 or so a night...


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## Tabitha (Mar 16, 2011)

Healinya said:
			
		

> This may seem off topic, but I think it's relevant.... There is an outdoor restaurant nearby that has bands playing most nights... they are open until midnight, which is a problem for the neighbors who want to sleep... The cops were called every night because of the noise violation... The owners were given a $60 citation every night... After a brief phone call with an attorney, they realized that there options were to close at 9pm and avoid the fine... or keep their hours and receive a $60 fine every day, while making an extra $2000 or so a night...



Bingo!


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## Genny (Mar 16, 2011)

That's the same reason that one of our local, but very well known,  manufacturers chooses to continue in illegally dumping their waste instead of legally and safely disposing of it.  The fine is way less than the cost of disposal.


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## Tabitha (Mar 16, 2011)

Genny said:
			
		

> That's the same reason that one of our local, but very well known,  manufacturers chooses to continue in illegally dumping their waste instead of legally and safely disposing of it.  The fine is way less than the cost of disposal.



That is so wrong! I think the fine should proportional to the crime. If it takes $1000 for the city to clean it up they should be fines 3x that amount, etc. The larger the dump. the larger the fine.


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## Lindy (Mar 23, 2011)

Just a note on the labelling.  If you are using INCI then you are able to list Olive Oil as Sodium Olivate or Potassiumn Olivate depending on which lye you are using.  If you are using both then you would list it as both and then depending whether you have more NOH or KOaH would determine the placement.  EG:  NOH:KOaH = 1:3 then you would list it as Potassium Olivate, Potassium Cocoate, Sodium Olivate, Potassium Olivate.

The understanding is that when it becomes soap it changes and the INCI covers that change.

HTH


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## Fullamoon (Mar 27, 2011)

*Labeling*

I'm not following. I keep reading that as long as your product is "soap" then you don't have to list the ingredients? I use MP "soap" I purchased at a craft store. The container says "soap". Does that mean I don't have to list anything that's in the soap? I've read many blogs about labeling and none are very clear.

There are so many ingredients between the melt and pour, the fragrance and the coloring that for my small bar of soap I'd need a label bigger than the whole bar of soap! Am I not understanding correctly?


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## soapbuddy (Mar 27, 2011)

*Re: Labeling*



			
				Fullamoon said:
			
		

> I'm not following. I keep reading that as long as your product is "soap" then you don't have to list the ingredients? I use MP "soap" I purchased at a craft store. The container says "soap". Does that mean I don't have to list anything that's in the soap? I've read many blogs about labeling and none are very clear.
> 
> There are so many ingredients between the melt and pour, the fragrance and the coloring that for my small bar of soap I'd need a label bigger than the whole bar of soap! Am I not understanding correctly?


Craft store MP soap is most likely a syndet based MP. It's no longer true soap and you do need to list the ingredients.


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## dagmar88 (Mar 27, 2011)

*Re: Labeling*



			
				Fullamoon said:
			
		

> I'm not following. I keep reading that as long as your product is "soap" then you don't have to list the ingredients? I use MP "soap" I purchased at a craft store. The container says "soap". Does that mean I don't have to list anything that's in the soap? I've read many blogs about labeling and none are very clear.
> 
> There are so many ingredients between the melt and pour, the fragrance and the coloring that for my small bar of soap I'd need a label bigger than the whole bar of soap! Am I not understanding correctly?



http://www.fda.gov/cosmetics/guidanceco ... 074201.htm
_
And what if it's "soap"?

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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## BBrandDesign (Oct 3, 2011)

*labeling your soaps*

Properly labeling your soaps can be very helpful in selling.  It can even be a real selling point if you have a lovely label, and the right label can give a gift a very special touch.  I've had many customers who had purchased handmade soaps from other companies in the past. Labels also keep your company name in the customers mind. It can even be a real selling point if you have a lovely label, and the right label can give a gift a very special touch.


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## Tabitha (Oct 4, 2011)

RedBeanBear said:
			
		

> soapbuddy said:
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> 
> 
> ...



Some companies can afford to pay the fine if they are slapped with a fee. Not saying this is the case with Zum, but it is tyhe case for some.  

Some companies find it is cheaper to illegally dump waste or polute the air & pay the fine rather than install proper enviornmental equipment. :?


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## Iris Reola (Oct 11, 2011)

ZUM probably got their "trade secret" ingredients passed by the FDA. If you have ingredients that you don't want stolen from you on a product where ingredients HAVE to be labeled, you can get approval from the FDA to not list it.

If you know the chemistry and the mathematics behind it, go ahead and list the end product. However, it is perfectly okay to list soap ingredients as what went into the pot before the reaction.

And lastly, as you've been told already, if it's considered soap, no ingredient list is necessary. However, my soap is just soap and I decided I wanted to list my ingredients anyways.


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## Lindy (Oct 12, 2011)

Iris Reola said:
			
		

> ZUM probably got their "trade secret" ingredients passed by the FDA. If you have ingredients that you don't want stolen from you on a product where ingredients HAVE to be labeled, you can get approval from the FDA to not list it.
> 
> If you know the chemistry and the mathematics behind it, go ahead and list the end product. However, it is perfectly okay to list soap ingredients as what went into the pot before the reaction.
> 
> And lastly, as you've been told already, if it's considered soap, no ingredient list is necessary. However, my soap is just soap and I decided I wanted to list my ingredients anyways.



Iris it is only in the USA that soap ingredients do not need to be listed.  I know that most members here are American but for other nationalities you do have to list your ingredients and you need to use INCI....


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