# how to put lard on labels



## oh2bejoy

Hi Everyone--someone whose shop and business sense I admire on another forum puts this on her label:  

Ingredients:  Raw goat milk; Saponified natural fats, coconut oil, olive oil, soybean oil; Fragrance; Natural color.

I am assuming that the "natural fats" refer to lard or tallow and I like the way she phrased it because here in Los Angeles a lot of people (well, my friends, anyway!) see the words "lard" or "tallow" and go "yuck"  and move on.  I love lard in my soaps because of the creaminess.  What do you think?  Is this legal/ethical?  I don't want to get in trouble when at the holiday fairs this month and next....  

Thanks in advance....

Joy


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## TessC

Just from the ethical side of it, I definitely wouldn't skate around listing exactly which oils are in your soap. People may need or want to avoid certain oils, be it for health, ethical, or religious reasons and your labels should make it easy for them to see exactly what's in your soap. I personally love lard in soaps, I think it adds a really nice something to the lather and I have no qualms about using it. The next person may be vegan or Muslim, and "sneaking" a lard soap in on them just isn't cool at all. 

There are also allergies to take into consideration, listing "saponified natural fats" doesn't allow a person to check for things that they're allergic to, which gives me the heebie jeebies personally. I'd hate for someone to have an allergic reaction to my soap if it could easily be avoided by a full ingredient list on the label, y'know?


Legally, I'm no lawyer but no, you can't play fast and loose with your labels. It's my understanding that the FDA does not require you to label your soap as long as it's just soap, but if you opt to do any label at all then you're obligated to label fully and properly, if that makes any sense. (It's early, not nearly enough caffeine yet to be articulate.)


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## dagmar88

The inci of lard = Lard, and it should be put on your label just like that. 
Not having lard on your inci when the soap does contain lards is in my opinion both unethical and illegal.
For example, someone could be allergic, have religious concerns or  lifestyles that do not include the use of pig/animal fats 

There's plenty of people who do not get their ingrediënt lists right and I wouldn't take this one as an example.  :?

The way she lists them now would mean she buys pre-saponified 'natural fats' (that term doesn't say anything, but lets assume it's animal fat, then it should be listed as tallow, lard, emu oil etc in particular), throws in coconut oil, soybean oil olive oil and goatsmilk and some fragrance/colorants.


This is how I'd list it, of course I do not know the order of her ingredients or the exact 'natural' colorant, so I picked calendula petals as an example:

Goat Milk, Cocos Nucifera Oil, Olea Europaea, Sodium Hydroxide, Glycine soja Oil, Calendula Officinalis Flower


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## agriffin

I agree with both above.  I think it's wrong and would not purchase soap from them even though I love lard soap.


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## velitasyjaboncitos

half percent of the time I use lard, it is awesome. I was thinking about this this same week as soon as I sell them, how can I put it in the label...

A lot of people/ existing customers love your products, and they'll trust you with your products. 

I have no problems labeling my soaps with lard.


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## carebear

I don't play the "mystery ingredients" game.

But I suspect that more so than labeling that way to avoid saying lard (aka pork tallow LOL), using a generic term like "natural fats" and "natural color" means she doesn't have to change her label or her web site text for various recipes.

But really, the whole thing is tacky.  That ingredient list is so useless it's laughable.


"natural fats" means nothing.  as opposed to what?  UNnatural fats?
"saponified" makes me twitch.  not all the oils are saponified, as she well knows.
"natural color"???  Kitten Love does that mean?


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## agriffin

"natural color"??? Kitten Love does that mean?"

When I want a "natural" chocolate brown...natural dog poop works perfectly.


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## Sunny

oh2bejoy said:
			
		

> Hi Everyone--someone whose shop and business sense I admire on another forum puts this on her label:
> 
> Ingredients:  Raw goat milk; Saponified natural fats, coconut oil, olive oil, soybean oil; Fragrance; Natural color.
> 
> I am assuming that the "natural fats" refer to lard or tallow and I like the way she phrased it because here in Los Angeles a lot of people (well, my friends, anyway!) see the words "lard" or "tallow" and go "yuck"  and move on.  I love lard in my soaps because of the creaminess.  What do you think?  Is this legal/ethical?  I don't want to get in trouble when at the holiday fairs this month and next....
> 
> Thanks in advance....
> 
> Joy



It's too tricky for me. If I saw those ingredients listed on a label, I wouldn't buy anyway, who knows what else the seller is putting in there that I don't know about (natural color?). Why would you want to trick your buyers into getting something they don't want. Like you mentioned above, selling to customers who wouldn't normally buy lard soap, so you trick them into buying it instead.

This is not a personal insult to you or your friend, just thinking out loud kinda.


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## tespring

carebear said:
			
		

> "natural fats" means nothing.  as opposed to what?  UNnatural fats?
> "saponified" makes me twitch.  not all the oils are saponified, as she well knows.
> "natural color"???  Kitten Love does that mean?




We have discovered the cause of unnatural fats right here in this forum.  It is from washing too much with soaps that have fats and this is the cause of the "soapers flab"!

The way I see it, is if they can claim tennis elbow from swinging a racket, I can claim "soapers flab" from trying out the soaps that I make daily.  


 

Yes, I agree, Lard should be on the label.


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## orangeblossom

I also want to respectfully agree.  

I am a vegetarian, and a Muslim and I avoid animal fat soap, especially lard.  There is a market for people who do not want animal fats, and a market for those who do.  There are plenty of people, many whom I know, who prefer to use locally made ingredients (including the rendered fats), or old fashioned ingredients, and who love lard and tallow soaps.  I live near a lot of Amish people, and they all make their soap with animal fats, and the sell like hotcakes.

I would never buy soap (or anything really) that I did not know the ingredients too.

I understand your concern, (wanting to sell soap) but I mentioned what I said earlier to let you know that there are plenty of folks who would want a lard soap (or at least, not mind it), but also many who don't.


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## kaelily

"natural fats" seems more gross than seeing "lard" on a label...to me, anyway.  

Speaking of labeling, I heard that a gift shop owner in town also makes soap.  I had the impression it was MP but when I went there to check it out, it was CP.   She didn't have an ingredient list on any of her soaps...and it did give me the heebie jeebies a little, lol.  The soaps looked nice, but still...I wouldn't buy any if I didn't know what was in it.


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## IrishLass

Ditto all the points that everyone else have mentioned.   

I love lard in soap and use it frequently. I list it as 'Lard' on the back of my label in my ingredients list, and I also proudly advertise 'Lard' right on the front of my label so people know exactly what they are getting.

I believe  1) that soapers need to know the reason why they use what they do in their soap, 2) that they need label 100% honestly, and 3) that they need be able to confidently explain their ingredients to their customers. If a soaper loves to use lard in soap for the special qualities it brings to their bar, then she/he should proudly label it as such and be able to confidently explain to others why they make soap with it. 

Sneaking around and hiding ingredients is never a good thing. It'll bite you in the end.

If your friend is so concerned about losing veggie customers by labeling 'Lard', why doesn't she just formulate and also offer a non-lard soap? That's what I do (and I'm sure many other lard soapers do, too).  

IrishLass


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## carebear

Keep in mind the use of "natural fats" or whatever is not necessarily a euphemism for Lard.  that was just supposition on the part of the OP.

I still believe it's listed that way for convenience - so that the wording on the site or labels doesn't have to be updated or changed.  Wrong, but not necessarily with intent to deceive.


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## oh2bejoy

THANK YOU, ALL!!!

I am grateful for all the responses.  I also list EVERYTHING on my labels for the same reasons so many of you have listed:  allergies, religious reasons, and just plain aversion to animal by-products.  However, I do find that the word "lard" is a turn-off for a lot of my friends and I was trying to see if I could get around it.  But, as I've seen, honesty is the best policy and so I will continue to list lard in plain language on my ingredient lists.

My web person suggested I list my ingredients this way:

Ingredients:  Goat's Milk.  Distilled water.  Saponified oils of Olive, Lard, Coconut, Sweet Almond, Castor, Apricot Kernal, and Babassu.  Shea Butter. Scented with Fragrance Oils and Lavender Buds.

I add about 8% shea butter so it come before the castor oil, but I don't include it in the oils because its a butter.  Is that okay?  and what do you think about the term "saponified oils of..."?

In the past, I have listed it this way:  

Ingredients:  Goat's Milk.  Distilled water. Olive oil, Lard, Coconut oil, Sodium Hydroxide, Sweet Almond oil, Shea Butter, Castor oil, Apricot Kernal oil, and Babassu oil.  Dragon's Blood fragrance (or whatever fragrance or essential oil I have used), and Lavender buds (or whatever botanicals like chamomile, etc).

Which would you recommend?

Thanks for all of your help!!!

Joy


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## rubyslippers

Am I missing something here or am I looking at the wrong INCI tables???? I've seen lard noted as sodium lardate.


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## agriffin

rubyslippers said:
			
		

> Am I missing something here or am I looking at the wrong INCI tables???? I've seen lard noted as sodium lardate.



That is saponified lard.

INCI for lard is lard.


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## rubyslippers

agriffin said:
			
		

> [That is saponified lard.
> 
> INCI for lard is lard.



Gotcha...thanks!


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## agriffin

Your label should look something like this.

Goat Milk, Water, Olea Europaea (Olive) Oil, Lard, Cocos Nucifera (Coconut) Oil, Prunus Amygdalus Dulcis (Sweet Almond) Oil, Butyrospermum Parkii (Shea Butter) Fruit, Ricinus Communis (Castor) Seed Oil, Prunus Armeniaca (Apricot) Kernel Oil, Orbignya Oleifera (Babassu) Seed Oil,  Fragrance and Lavandula Angustifolia (Lavender) Flower

You need Sodium Hydroxide in there also...in order of use.  So if you have more of that than they Babassu...it needs to go there.  I just took from your sample but everything should be listed in order of use.

In my opinion...no it is not okay to say "saponified oils of"...

Does your soap have a superfat?  If so, how do you know what oils were completely saponified and which were not.  

If you list the saponified name of the oil such as Sodium Cocoate...you are saying that there is no free coconut oil in your soap.  If you superfat...then this is a non truth.


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## BakingNana

agriffin said:
			
		

> Your label should look something like this.
> 
> Goat Milk, Water, Olea Europaea (Olive) Oil, Lard, Cocos Nucifera (Coconut) Oil, Prunus Amygdalus Dulcis (Sweet Almond) Oil, Butyrospermum Parkii (Shea Butter) Fruit, Ricinus Communis (Castor) Seed Oil, Prunus Armeniaca (Apricot) Kernel Oil, Orbignya Oleifera (Babassu) Seed Oil,  Fragrance and Lavandula Angustifolia (Lavender) Flower
> 
> You need Sodium Hydroxide in there also...in order of use.  So if you have more of that than they Babassu...it needs to go there.  I just took from your sample but everything should be listed in order of use.
> 
> In my opinion...no it is not okay to say "saponified oils of"...
> 
> Does your soap have a superfat?  If so, how do you know what oils were completely saponified and which were not.
> 
> If you list the saponified name of the oil such as Sodium Cocoate...you are saying that there is no free coconut oil in your soap.  If you superfat...then this is a non truth.



....which brings me to a question that had not occurred to me until now.  The above sample is how I list my ingredients on products, but on sugar scrubs I have been listing the shredded soap ingredient on the label as: saponified oils of cocos nucifera (coconut) oil, ...and so on.  Considering the soap I use is 5% SF, just how picky do I need to get?

And thanks for the laughs you guys!  Stressed out getting ready for a big show, and I needed to laugh today!!


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## agriffin

Ya know...this is how I do it. 

Brown Sugar, Water, Cocos Nucifera (Coconut) Oil, Liquid Soap (water, Olea Europaea (Olive) Fruit Oil, Cocos Nucifera (Coconut) Oil, Simmondsia Chinensis (Jojoba) Seed Oil, Potassium Hydroxide*), Stearic Acid, Emulsifying Wax NF, Butyrospermum Parkii (Shea Butter) Fruit, Theobroma Cacao (Cocoa) Seed Butter, Simmondsia Chinensis (Jojoba) Seed Oil, Optiphen Preservative (Phenoxyethanol (and) Caprylyl Glycol (and) Sorbic Acid), Fragrance

Which I guess is technically wrong.  I would want to break the ingredients out from the liquid soap and list them in order used as well.  What a headache.


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## SudsyKat

I'm not an expert by any means, but just my 2 cents - when I buy a product, I want the ingredient list to be as short as possible. We have a popular soap shop out here (Soaptopia). They list the ingredients more simply, like Palm Oil, Coconut Oil, etc. I would be hesitant to buy a soap that had a lot of scientific sounding ingredients in it (even if they are harmless). So, from a marketing standpoint, I vote for the simpler terms.

As for the lard thing - I'd definitely want to know if there's lard in the soap because I lean toward vegan, though I'm a bit loose with it. Then again, take everything I say with a grain of salt because I come from the land of fruits and nuts - California. I live in L.A., where everything and everyone is totally natural ( :roll:  ).


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## agriffin

Oh boy...Soaptopia.  I have issues with them.  Let's look at an ingredient listing from their website.

Our soap is all natural and handmade in small batches with lots of love and only the finest ingredients consisting of:  Italian Olive oil, wildcrafted Shea butter, Coconut oil, Palm oil, Avocado oil, Organic Hempseed oil, plant infusions, Sweet Orange Blossom, Eucalytpus and Aloe Vera Essential Oils, Agave Root Extract and LOVE!.


Three things...aloe vera essential oils?  And made with love?  and they don't list lye.  To me this is just deceptive.

I do love the look of their soaps though.  Packaging, website...looks great.


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## SudsyKat

I totally see your point - especially about the lye. I guess I was (foolishly) assuming that if a legitimate business (they have a couple of brick and mortar stores in addition to the website) felt it was within the bounds of the law to list their ingredients that way, then perhaps it is? Honestly, I don't know. I do know that an ingredient list like that is much more appealing to me than one with lots of scientific names on it. Just sayin...


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## agriffin

SudsyKat said:
			
		

> I totally see your point - especially about the lye. I guess I was (foolishly) assuming that if a legitimate business (they have a couple of brick and mortar stores in addition to the website) felt it was within the bounds of the law to list their ingredients that way, then perhaps it is? Honestly, I don't know. I do know that an ingredient list like that is much more appealing to me than one with lots of scientific names on it. Just sayin...



I do hear what you're saying.  Simpler is easier and less scarry to the consumer.


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## American Valkyrie

IrishLass said:
			
		

> If your friend is so concerned about losing veggie customers by labeling 'Lard', why doesn't she just formulate and also offer a non-lard soap? That's what I do (and I'm sure many other lard soapers do, too).
> 
> IrishLass



Finding out that a company had reworded an ingredient to "hide" something that was against my belief system would repel me much faster than wondering if a supplier had a vegan option.  Taking consideration for someone else's beliefs/choices, whether or not you agree with or understand them, relays a willingness to work with and care for your clientele.  Though pork isn't one of them, I also have religious dietary/usage restrictions, and when someone takes a moment to consider my choices (not putting alcohol in the fondue) it means a lot to me.  

Once I went to (a major coffee chain) and ordered steamed milk for my kids.  The barista didn't even stop to clarify that I did NOT want coffee.  My 11-year-old had consumed half of his beverage before his sister remarked that it tasted funny.  That was the beginning of a long night.  We go to a different store now for our steamed milks.

Since a lot of vegetarians/vegans use natural soaps, having that consideration is going to draw more customers than hedging around them.  Having a clearly labeled vegan option is going to go far.


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## dagmar88

oh2bejoy said:
			
		

> THANK YOU, ALL!!!
> 
> My web person suggested I list my ingredients this way:
> 
> Ingredients:  Goat's Milk.  Distilled water.  Saponified oils of Olive, Lard, Coconut, Sweet Almond, Castor, Apricot Kernal, and Babassu.  Shea Butter. Scented with Fragrance Oils and Lavender Buds.
> 
> If you want to do it this way, where you put on the label what is in there instead of what GOES in there, you should also list glycerine  and use the correct terms. To much of a hassle for me; yet another math problem
> 
> I add about 8% shea butter so it come before the castor oil, but I don't include it in the oils because its a butter.  Is that okay?  and what do you think about the term "saponified oils of..."?
> 
> No, just list it in the right order; from biggest to smallest. It doesn't matter if it's an oil or butter at all.
> I personally wouldn't use that term; it's most often used by big companies that buy pre-saponified oils and butters. And as said, what would you do with the superfat? List everything twice?
> 
> In the past, I have listed it this way:
> 
> Ingredients:  Goat's Milk.  Distilled water. Olive oil, Lard, Coconut oil, Sodium Hydroxide, Sweet Almond oil, Shea Butter, Castor oil, Apricot Kernal oil, and Babassu oil.  Dragon's Blood fragrance (or whatever fragrance or essential oil I have used), and Lavender buds (or whatever botanicals like chamomile, etc).
> 
> Which would you recommend?
> 
> Thanks for all of your help!!!
> 
> Joy



I'd reccomand: Goat Milk, Aqua, Olea Europaea Oil, Lard, Cocos Nucifera Oil, Sodium Hydroxide, Prunus Amygdalus Dulcis Oil, Butyrospermum Parkii Butter, Ricinus Communis Oil, Prunus Armeniaca Kernel Oil, Orbignya Oleifera Oil, Fragrance*, Lavandula Angustifolia.

*In the USA you can just use the word fragrance for every kind of fragrance if I'm right; but most peope use Fragrance for fragrance oils and list the Inci name when using essential oils.
In Europe however, you'd have to list Fragrance, or the Inci of the essential oil and include the exact substances in there that are known to cause allergies.



			
				agriffin said:
			
		

> Ya know...this is how I do it.
> 
> Brown Sugar, Water, Cocos Nucifera (Coconut) Oil, Liquid Soap (water, Olea Europaea (Olive) Fruit Oil, Cocos Nucifera (Coconut) Oil, Simmondsia Chinensis (Jojoba) Seed Oil, Potassium Hydroxide*), Stearic Acid, Emulsifying Wax NF, Butyrospermum Parkii (Shea Butter) Fruit, Theobroma Cacao (Cocoa) Seed Butter, Simmondsia Chinensis (Jojoba) Seed Oil, Optiphen Preservative (Phenoxyethanol (and) Caprylyl Glycol (and) Sorbic Acid), Fragrance
> 
> Which I guess is technically wrong. I would want to break the ingredients out from the liquid soap and list them in order used as well. What a headache.



Yup...but making inci's does give you a huge headache period   Looks really good though!
(BTW, haven't you seen that soap made with prayer yet? I pray for my soap to come out halfway decent all the time, but I guess He has a lot of more important things on His mind )

@SudsyKat, if you'd like to put anything aside from just soap on your label, the INCI should be used; it's just what the FDA has come up with. In Europe soap that is mend to use on the body is seen as a cosmetic and we should use the INCI always.
I wouldn't buy from a company with an ingredient list like that; I think it's very unprofessional. 
Plus I'm not sure they're allowed to put wildcrafted or organic in their list...
However, if I'll ever menage to own a shop, I would put up a little card with the ingredients in Dutch in front of every row of soap.


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## SudsyKat

I guess the big scientific names wouldn't scare me as long as they were listed with the simple name in parentheses (like others have suggested). And of course, if it's required by the FDA, then I'd adhere to whatever standards they have.

I'm nowhere near selling my soap yet - I'm a total newbie and just having a blast with it. But I do dream about being able to make money from doing something I love and have a passion for, so it's interesting to see these discussions. Thanks to all for contributing to my knowledge base!


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## BakingNana

Is there such a thing as wildcrafted Shea Butter?  In the reading I've done, it sounds like all shea could be deemed "wildcrafted."  Some labels seem to be more marketing ploys than ethical labeling.

@agriffin...Back to the sugar scrubs.  If you did break out all the ingredients used in the soap shreds, I would assume you would just leave out the word "liquid soap" or "soap" and list the ingredients in volume order.  And ya, what a headache.  As it is when a customer is looking at the label on a sugar scrub, I always jump in and say something like "there are only 4 ingredients in the solid sugar scrubs," which sort of gives me an opening to go on to explain INCI and FDA info.  Education is power, as they say.  I figure a customer who understands INCI is more likely to appreciate what is and isn't in my stuff.


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## carebear

dagmar88 said:
			
		

> oh2bejoy said:
> 
> 
> 
> 
> THANK YOU, ALL!!!
> 
> My web person suggested I list my ingredients this way:
> 
> Ingredients:  Goat's Milk.  Distilled water.  Saponified oils of Olive, Lard, Coconut, Sweet Almond, Castor, Apricot Kernal, and Babassu.  Shea Butter. Scented with Fragrance Oils and Lavender Buds.
> 
> If you want to do it this way, where you put on the label what is in there instead of what GOES in there, you should also list glycerine  and use the correct terms. To much of a hassle for me; yet another math problem
Click to expand...


still not correct.  there are unsaponified oils as well - remember, you have a lye discount (or superfat).  do you have any idea of the proportions or amounts of each oil is left unsaponified?  would you actually need to list them as the individual fatty acids?  THAT is to much of a hassle for me.

LIST YOUR INGREDIENTS, ALL YOUR INGREDIENTS.  Unless your web person has a degree in law and a background in such things, just follow the rules and don't try to hide your sodium hydroxide.


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## agriffin

BakingNana said:
			
		

> Is there such a thing as wildcrafted Shea Butter?  In the reading I've done, it sounds like all shea could be deemed "wildcrafted."  Some labels seem to be more marketing ploys than ethical labeling.
> 
> @agriffin...Back to the sugar scrubs.  If you did break out all the ingredients used in the soap shreds, I would assume you would just leave out the word "liquid soap" or "soap" and list the ingredients in volume order.  And ya, what a headache.  As it is when a customer is looking at the label on a sugar scrub, I always jump in and say something like "there are only 4 ingredients in the solid sugar scrubs," which sort of gives me an opening to go on to explain INCI and FDA info.  Education is power, as they say.  I figure a customer who understands INCI is more likely to appreciate what is and isn't in my stuff.



Yes, you would want to omit soap or liquid soap and list the ingredients in volume order.


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## KD

*labeling*

Wow!  This a hot topic!  Just a quick word from a Canadian soaper.  On top of the proper listing of ingredients, we must also make sure that we are aware that, in Canada, soap is a cosmetic.  Non-cosmetic colors, which are becoming increasingly popular in the States, may not be legal for use in Canadian soaps.  Please make sure you check with Health Canada.  Incidentally, I have had an experience with a fellow soaper here who refuses to label her soap with ingredients.  She thinks that we are all out there trying to steal her recipe  She has her soap in several shops, and I have to wonder why none of them seem to have an issue with the missing ingredient listing.


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## c.a.p.

I agree that ingredients should be listed, in order of % weight used, most to least.  And I, too, wouldn't buy soap where sodium hydroxide was missing or concealed in sodium lardate, etc especially if it were handcrafted.  However, I don't believe it is against FDA regs.  Soap doesn't have to have an ingredients list.  And, someone correct me if I am wrong, by law, just because you DO add an ingredients list, you do not have to use the INCI names.  Am I wrong here?  I'm talking about US law, not what someone WANTS to see.

I list my ingredients, including sodium hydroxide, in the proper order, but I don't include the INCI names as I believe they are not required.

Comments?


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## carebear

*Re: labeling*



			
				KD said:
			
		

> She thinks that we are all out there trying to steal her recipe


she must be one freaking marvelous soaper...

hell if I thought I could buy something superior to mine, I'd not bother making it.


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## igbabygirl

c.a.p. said:
			
		

> I agree that ingredients should be listed, in order of % weight used, most to least.  And I, too, wouldn't buy soap where sodium hydroxide was missing or concealed in sodium lardate, etc especially if it were handcrafted.  However, I don't believe it is against FDA regs.  Soap doesn't have to have an ingredients list.  And, someone correct me if I am wrong, by law, just because you DO add an ingredients list, you do not have to use the INCI names.  Am I wrong here?  I'm talking about US law, not what someone WANTS to see.
> 
> I list my ingredients, including sodium hydroxide, in the proper order, but I don't include the INCI names as I believe they are not required.
> 
> Comments?



That is how I list my ingredients.  I want people to know what is in my soap, but I do not use INCI names.  I have used the word sapnofied, but see where you are coming from, so I will change that on my ingredients list.  Very insightful topic here.


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## MBZ

oh2bejoy said:


> Hi Everyone--someone whose shop and business sense I admire on another forum puts this on her label:
> 
> Ingredients:  Raw goat milk; Saponified natural fats, coconut oil, olive oil, soybean oil; Fragrance; Natural color.
> 
> I am assuming that the "natural fats" refer to lard or tallow and I like the way she phrased it because here in Los Angeles a lot of people (well, my friends, anyway!) see the words "lard" or "tallow" and go "yuck"  and move on.  I love lard in my soaps because of the creaminess.  What do you think?  Is this legal/ethical?  I don't want to get in trouble when at the holiday fairs this month and next....
> 
> Thanks in advance....
> 
> Joy


If your product is "SOAP" (lye-sodium hydroxide) You don't even need to list the ingredients unless you want to or it's marketed as a children's soap and for that you must have the certification. The FDA doesn't regulate soap, unless it's marketed as organic, moisturizing, or something else that could be considered "cosmetic." Granted California likely has some other laws, but as far as the FDA or the CPSC you don't NEED to list them. 
You can read the entire FDA regulation at 21 CFR 701.20.


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