# weighing soap for sale



## jessicammorton (Apr 19, 2010)

To all of you who sell soap...my question is, when do you weigh the soap to determine the package weight?  Do you weigh it right after trimming (when it would be heaviest) or at the end of curing (lighter from water evaporation)?  I suppose it would be better to error on the side of caution and weigh at the "finished bar weight," but does anyone know the legal answer to this?

Thank you!


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## Tabitha (Apr 19, 2010)

You weigh it when you sell it. If you weigh it now & it's 4oz & you label it as such, them sell it later and it's less you are not in complaince w/ the FDA not to mention committing fraud by claiming to sell 4oz of soap & giving your buy "less" than you advertised.


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## carebear (Apr 19, 2010)

the weight on your product needs to be the weight of the product sold.


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## Healinya (Apr 19, 2010)

So that means you can't go over either? I cut my bars around 4.5 - 5 ounces so that I can safetly assume they are over four ounces. I guess I had assumed that as long as they aren't under weight they are fine. Actually, are you required to put the weight on the bar or is it just an option?


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## jessicammorton (Apr 19, 2010)

*weighing*

Yes, for sure I am aware of FDA regs - but wasn't sure when they specified that the soap was finished.  I doubt there is any harm in going over in weight...but does anyone know the tolerable range that the FDA has for soap weight?  There are acceptable deviations for both above and under weight, and I assume you need to ensure that within that range, your average product weight is at least at or above the target weight.


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## Deda (Apr 19, 2010)

Bureau of Weights and measures comes to our market and weighs products every few weeks. 

Why try to pull a fast one on your customers?  Weigh your soap after a full cure.  If you're using full water wait 6 to 8 weeks.  Test weigh again after 6 months, and again at the 1 year mark.  Keep notes, you'll figure it out.


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## Healinya (Apr 19, 2010)

I definately agree that bars should never be underweight. But what would happen if Bureau of Weights and measures weighed a bar that was a half ounce over? Would you face penalties/fines for it? It's yet another angle to this business that I hadn't though of yet lol. I do keep proper notes of all my batch weight which is good. Sorry to hi-jack the thread with my own question lol, but you got me curious.


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## bombus (Apr 20, 2010)

The problem is, it changes as the soap ages.

I just purchased Marie Gale's "Soap & Cosmetic Labeling, How to Follow
The Rules and Regs Explained in Plain English", 2nd edition.
Here is what she says-

"It is the responsibility of the label-er to accurately calculate the net contents of a bar of soap as the least amount it could be when sold. 
The quantity of contents declaration on a bar of soap must not be stated as "approx. 4 oz" or "not less than 4 oz.
For "true soap" (made with lye and oils) calculating the weight of the ingredients in the soap less the water content will give the weight of 
the soap with all the water evaporated out; the least possible weight of the soap."

That means you couldn't print it as part of your label- I guess you would have to use a sticker so it could be changed as the bar loses weight.


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## theBrewMeister (Apr 20, 2010)

You can go over all you want. In the brewing industry we shoot for filling the bottles to inside the neck. Where the neck meets the shoulder of the bottle is 12 ounces. But how many times have you seen a beer filled that low? never. You're usually getting closer to 13 ounces.


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## bodybym (Apr 20, 2010)

You will never get in trouble by giving your customer more than what it says on the label.


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## jessicammorton (Apr 20, 2010)

This is all very helpful...thank you!


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## Cheirenya (Apr 20, 2010)

bodybym said:
			
		

> You will never get in trouble by giving your customer more than what it says on the label.



I agree


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## dcornett (Apr 26, 2010)

Healinya said:
			
		

> So that means you can't go over either? I cut my bars around 4.5 - 5 ounces so that I can safetly assume they are over four ounces. I guess I had assumed that as long as they aren't under weight they are fine. Actually, are you required to put the weight on the bar or is it just an option?


I'm with Healinya. Are you required to put the weight on the bar, or is it an option?


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## abigtroutt (Apr 27, 2010)

We always put the net weight on the lables.  As for our state inspector more is always better then less.


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## Tabitha (Apr 27, 2010)

This statement is taken from the Federal Trade Commission's Fair Packaging and Labeling Act.

"The FPLA requires each package of household "consumer commodities" that is included in the coverage of the FPLA to bear a label on which there is: 

* a statement identifying the commodity, e.g., detergent, sponges, etc.; 
* the name and place of business of the manufacturer, packer, or distributor; 
* and the net quantity of contents in terms of weight, measure, or numerical count (measurement must be in both metric and inch/pound units)."

Reda more here: http://www.ftc.gov/os/statutes/fpla/outline.html


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## dcornett (Apr 28, 2010)

See, I just learned something new. My bars are a really nice size, they start out approx. 6-6.5 oz, so even after drying they are good sized bars, but I didn't know I had to put all these things on a label. What about the list of ingredients? I list mine, but do they have to follow the same guidelines as say...food items that are required to list in order according to the amount of each ingredient used (starting with the highest and ending with the least)? Because I didn't see that in this link.


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## Tabitha (Apr 28, 2010)

If it is just soap you do not have to list ingredients. If it contains  adetergent it becomes a cosmetic, if you make a claim such as 'moisturising' it becomes a cosmeric, if you make a claim such as 'helps acne' it become s drug. There are 3 different sets of labeling requirments depending on if you are marketing your soap as a Soap vs cosmetic vs drug.

Check out these links.:

http://www.cfsan.fda.gov/~dms/cos-218.html 
Is It a Cosmetic, a Drug, or Both? 
(or Is It Soap?) 

http://www.cfsan.fda.gov/~dms/cos-lab1.html 
Summary of Regulatory Requirements for Labeling of Cosmetics Marketed in the United States. 

Cosmetic Labeling Regulations as Published in Title 21, Code of Federal Regulations, Sections 701, 740 and Other Pertinent Sections. 

Cosmetic Labeling Guide.


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## dcornett (Apr 29, 2010)

Thanks!!!!!


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## Deda (Apr 29, 2010)

According to the FDA compliance I spoke with, if you list one ingredient on the label you must list them all.  That includes the product name.  If your label says "Lavender Soap" then lavender is an ingredient and all ingredients must be listed.


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## jessicammorton (Apr 29, 2010)

Tabitha said:
			
		

> If it is just soap you do not have to list ingredients. If it contains  adetergent it becomes a cosmetic, if you make a claim such as 'moisturising' it becomes a cosmeric, if you make a claim such as 'helps acne' it become s drug. There are 3 different sets of labeling requirments depending on if you are marketing your soap as a Soap vs cosmetic vs drug.
> 
> Check out these links.:
> 
> ...



This was great info - thank you!  For small businesses that don't have the resources yet for printing (and reprinting) numerous back labels, it's great to know that at least the ingredient statement doesn't have to be permanently affixed (i.e. stickered-on) to the container.  Great FDA resource


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## Tabitha (Apr 30, 2010)

> food items that are required to list in order according to the amount of each ingredient used (starting with the highest and ending with the least)? Because I didn't see that in this link.



Sorry, I did not see that quetsion before. Yes, if you list them it's from most to least. I believe anything that is at 2% or less can be listed at the end in no particular order.


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## Tabitha (Apr 30, 2010)

> This was great info - thank you! For small businesses that don't have the resources yet for printing (and reprinting) numerous back labels,



It's perrty simple & very inexpensive to print on return address label blanks.


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## jessicammorton (May 1, 2010)

Tabitha said:
			
		

> > This was great info - thank you! For small businesses that don't have the resources yet for printing (and reprinting) numerous back labels,
> 
> 
> 
> It's perrty simple & very inexpensive to print on return address label blanks.



That would be great - my concern with Avery labels and the like being their pervious nature to water and oil.  Have you experienced problems with that?  Does it really matter to have oil and waterproof labels?


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## ewenique (May 1, 2010)

This info is from a Weights & Measures table which lists the acceptable variation in listed weight: NIST Handbook 133
Checking the Net Contents of Packaged Goods
as adopted by the 89th National Conference on Weights and Measures 2004

More than 81 g to 117 g
More than 0.18 lb to 0.26 lb
*More than 2.88 oz to 4.16 oz*7.2 g
0.016 lb
*¼ oz*
More than 117 g to 154 g
More than 0.26 lb to 0.34 lb
*More than 4.16 oz to 5.44 oz*9.0 g
0.020 lb
*5/16 oz*


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