# question about EO



## hozhed (Jul 6, 2015)

I am just getting to the point of selling my soaps and buy all my EO from the local health food store. My question is, how should I describe these natural oils? Are they "food grade"? therapeutic grade"  ?  what?  I want  to get it right. Thanks, Steve


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## IrishLass (Jul 6, 2015)

I could be wrong, but I believe they can just be labeled as 'fragrance' or 'essential oils of...' (at least in the US). Hopefully, someone who sells will chime in to confirm or deny that. 

RE: 'Therapeutic Grade'- seeing as how there is no such officially recognized/sanctioned grade as 'Therapeutic Grade' in the trade, I would definitely steer clear of using that one. From all I've read on the subject, the term originates from a company called YoungLiving Oils, who have been sued by the government for different offenses.


IrishLass


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## not_ally (Jul 6, 2015)

Agreed.  Definitely neither therapeutic grade or food grade.  Former is meaningless (and makes it sound like the seller is misleading) and food grade is just plain scary.

ETA: v. useful labeling summary from the guru of interpreting FDA labeling requirements, Marie Gale:

http://mariegale.com/soap-and-cosmetic-labeling/labeling-faq.html


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## shunt2011 (Jul 6, 2015)

I agree with the others. Label either fragrance or essential oil is all I put


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## hozhed (Jul 6, 2015)

IrishLass said:


> I could be wrong, but I believe they can just be labeled as 'fragrance' or 'essential oils of...' (at least in the US). Hopefully, someone who sells will chime in to confirm or deny that.
> 
> RE: 'Therapeutic Grade'- seeing as how there is no such officially recognized/sanctioned grade as 'Therapeutic Grade' in the trade, I would definitely steer clear of using that one. From all I've read on the subject, the term originates from a company called YoungLiving Oils, who have been sued by the government for different offenses.
> 
> ...


 
Good enough. can I assume EO are "all natural" or are there artificial ones??


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## DeeAnna (Jul 6, 2015)

Ditto the others -- fugeddabout the meaningless "therapeutic grade" and "food grade" hooey. 

If you want to be more specific than just "fragrance", you can list the common and Latin names for each EO -- lavender for example would be "lavender (Lavendula angustifolia)".


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## xoticsoaps (Jul 6, 2015)

In the U.S. all ingredients must be listed using the INCI (International Nomenclature of Cosmetic Ingredients) name. You are allowed to put the common name/term for that ingredient in parenthesis if necessary, but the FDA requires the INCI names for any and all ingredients. Most cosmetic ingredient suppliers will list the INCI names on product pages for your convenience.

Ingredients are also required to be listed in descending order from most to least used. Fragrance & colorants don't count and can be placed at the very end of the ingredient list in any order.


Example: If I use 3oz Olive oil, 1oz apricot kernel oil, .50oz babassu oil, 3.5oz water, .25oz cedarwood essential oil, 2oz gold mica (contains titanium dioxide and iron oxide)... the label would read:
---
Water (Aqua), Olea Europaea (Olive) Fruit Oil, Prunus Armeniaca (Apricot) Kernel Oil, Orbignya Oleifera (Babassu) Seed Oil, Cedrus Atlantica (Cedarwood) Bark Oil, Mica, titanium dioxide, iron oxide

I believe you can describe them as pure essential oils in your item listings as long as your oil didn't come pre-mixed with any sort of carrier oil or extra ingredients. Just be sure not to make any sort of drug or treatment claims.



Resources: http://www.fda.gov/cosmetics/resourcesforyou/industry/ucm388736.htm

http://www.fda.gov/cosmetics/productsingredients/products/ucm127054.htm

http://www.soapqueen.com/bath-and-body-tutorials/lip-products/labeling-your-products-lip-balm/


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## hozhed (Jul 6, 2015)

xoticsoaps said:


> In the U.S. all ingredients must be listed using the INCI (International Nomenclature of Cosmetic Ingredients) name. You are allowed to put the common name/term for that ingredient in parenthesis if necessary, but the FDA requires the INCI names for any and all ingredients. Most cosmetic ingredient suppliers will list the INCI names on product pages for your convenience.
> 
> Ingredients are also required to be listed in descending order from most to least used. Fragrance & colorants don't count and can be placed at the very end of the ingredient list in any order.
> 
> ...


 

Excellent! You guys are awesome.. thanks!


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## commoncenz (Jul 6, 2015)

I thought that as long as you weren't making any claims as far as health and/or cosmetic, soap didn't have specific labeling requirements. And that if you did label your soap, you could just list ingredients in descending order? So confusing ... glad I don't sell now


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## Dorymae (Jul 6, 2015)

xoticsoaps said:


> In the U.S. all ingredients must be listed using the INCI (International Nomenclature of Cosmetic Ingredients) name. You are allowed to put the common name/term for that ingredient in parenthesis if necessary, but the FDA requires the INCI names for any and all ingredients. Most cosmetic ingredient suppliers will list the INCI names on product pages   [/url]



I'm sorry but this information is WRONG. Very wrong. In the US all ingredients MUST use the common name. If you want to include the INCI you may do so in parentheses after the common name. 

I'm on my way out but when I come back I will give you the exact wording from the FDA.


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## Dorymae (Jul 6, 2015)

commoncenz said:


> I thought that as long as you weren't making any claims as far as health and/or cosmetic, soap didn't have specific labeling requirements. And that if you did label your soap, you could just list ingredients in descending order? So confusing ... glad I don't sell now



True but if you label, you must label correctly.


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## not_ally (Jul 6, 2015)

I REALLY recommend you click on the Marie Gale link.  I am a lawyer, and still hate/d reading those FDA regs.  I found her info very clear and easy to follow, her book (where things are set out at greater length) is well worth getting if you want to get into the nitty gritty of things, but the link sets out a great summary/outline of what you need.


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## DeeAnna (Jul 6, 2015)

"...In the U.S. all ingredients must be listed using the INCI (International Nomenclature of Cosmetic Ingredients) name. You are allowed to put the common name/term for that ingredient in parenthesis if necessary,..."

Nope. Dorymae is correct. In the USA, COMMON names are required, not INCI. Read the regs. Or read Marie Gale -- Not_ally gave a helpful link to Marie's summary of the regs: http://mariegale.com/soap-and-cosmet...eling-faq.html. Either one will set you straight.


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## hmlove1218 (Jul 6, 2015)

xoticsoaps said:


> In the U.S. all ingredients must be listed using the INCI (International Nomenclature of Cosmetic Ingredients) name. You are allowed to put the common name/term for that ingredient in parenthesis if necessary, but the FDA requires the INCI names for any and all ingredients.



I agree with Dorymae. This is completely false information. The FDA only requires common names. INCI is optional, but if it's included, it should follow the common name and be in parenthesis ex. Lavender oil (Lavendula angustifolia)

If it is labeled simply as soap, no ingredient list is required, but if one is presented, it must be in descending order.

I also highly recommend reading the Marie Gale link that was posted as she makes understanding all the legal mumbo jumbo quite easy.


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## Dorymae (Jul 6, 2015)

Okay here you go:

*Identification of Ingredients by Name*


*The name established by the commissioner as specified in § 701.30.*
*The name adopted for the ingredient as listed in:
*
*     (a) CTFA Cosmetic Ingredient Dictionary
     (b) United States Pharmacopeia
     (c) National Formulary
     (d) Food Chemical Codex
     (e) USAN and the USP Dictionary of Drug Names
*
*The name generally recognized by consumers*
*The chemical or technical name or description*
 *21 CFR 701.3(c) *
 Section  701.3(c) requires that an ingredient be identified by the name   established by the Commissioner for the purpose of cosmetic ingredient   labeling or, in the absence of a name  established by the Commissioner,  the name adopted for that ingredient  in the editions and supplements of  the compendia listed below.
 The Commissioner may establish a name  as petitioned or propose such a  name on his own initiative. See section  701.3(e). The names specified  by the Commissioner are listed in section  701.30.
 The currently recognized edition of the CTFA (Cosmetic,  Toiletry and Fragrance Association, Inc.) *Cosmetic Ingredient Dictionary  is the second edition published in 1977*. This edition is recognized  only in part, i.e., not all names listed in the second edition have been  adopted.
 The third edition of the CTFA Cosmetic Ingredient  Dictionary published  in 1982 and the Supplement published in 1985 have  not yet been  recognized. However, FDA has informed the CTFA that the  agency will not  take regulatory action against products labeled in  accordance with  these editions while their review is in progress.
 The  compendia are listed in the descending order by which they must be  utilized for identification of an ingredient name.* If none lists a name  for an ingredient, the name generally recognized by consumers, or the  chemical or technical name or description, must be used.

*For those who want a look at the dictionary you can find it here: (note the names are common names)
*https*://*law*.*resource*.*org*/*pub*/*us*/*cfr*/ibr/003/cfta.cos*metic*.*1977*.*pdf

*Oh before I forget, you may list EO's either as fragrance or as the name such as, Tea Tree oil.  You may Not put in additional words such as Pure, Natural, therapeutic grade, or any other description.  I can find the regulation that prohibits that if anyone needs to see it.


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## xoticsoaps (Jul 7, 2015)

Here are some previous forum threads that discuss this matter:

U.S. Cosmetic Labeling Manual - http://www.soapmakingforum.com/showthread.php?t=33325

About INCI names - http://www.soapmakingforum.com/showthread.php?t=33326

Do I have to use INCI names on my soap label? - http://www.soapmakingforum.com/showthread.php?t=3583

Labeling - http://www.soapmakingforum.com/showthread.php?t=39371&highlight=inci+names


Although I have serious doubts that hozhed is only going to market soap only for cleansing purposes and never make a single claim that it's moisturizing or something else that would move it to being in the category of both a soap and cosmetic, a simple statement in the 'Labeling' thread above stood out:

"..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."


More info can be dug up by searching in the Labels and Packaging section of this forum. Also my reference to using "pure essential oils" was for the "item listing" *not* the label.


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## Dorymae (Jul 7, 2015)

xoticsoaps said:


> Here are some previous forum threads that discuss this matter:
> 
> U.S. Cosmetic Labeling Manual - http://www.soapmakingforum.com/showthread.php?t=33325
> 
> ...




Please note the dates of those threads, 2008 and two from 2013. Prior to 2014, the FDA was not clear about the name they wished used in cosmetic labeling. It was only when they clarified what they want, common names, that most of us realized we were labeling incorrectly.  Prior to this most of us believed INCI names were needed. We now know this to be false and in fact they should not be used unless in parentheses after the common name. 

Even Marie Gale had to put out a updated addition of her book. 

It is no longer even a question on how to label - the FDA has made it very clear when labeling cosmetics common name is to be used.

Here the FDA put out a video telling what they require. The part we are dealing with is covered at 10:13 - 12:23. 
[ame]https://m.youtube.com/watch?v=akPq1tsbze0[/ame]


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## xoticsoaps (Jul 7, 2015)

Dorymae said:


> Please note the dates of those threads, 2008 and two from 2013. Prior to 2014, the FDA was not clear about the name they wished used in cosmetic labeling. It was only when they clarified what they want, common names, that most of us realized we were labeling incorrectly.  Prior to this most of us believed INCI names were needed. We now know this to be false and in fact they should not be used unless in parentheses after the common name.
> 
> Even Marie Gale had to put out a updated addition of her book.
> 
> ...




^^^This information was helpful. Saying that "this information was WRONG. Very wrong." was not. If the info was outdated by 2011 and there were clarifications made in 2014, fine. Say that, with or without the dates. But you don't have to make it sound like I pulled the information out of thin air or something. Thanks for the info update.


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## Dorymae (Jul 7, 2015)

xoticsoaps said:


> ^^^This information was helpful. Saying that "this information was WRONG. Very wrong." was not. If the info was outdated by 2011 and there were clarifications made in 2014, fine. Say that, with or without the dates. But you don't have to make it sound like I pulled the information out of thin air or something. Thanks for the info update.



I'm sorry if it came off harshly. ( looking back I can see that it did. )

As I said most of us did find out we were labeling incorrectly, and had to research and 'find out'.  I did not intend to sound so mean, with such important information, I simply did not want anyone else to follow the advice and not know the truth. 

Sorry again, and I feel for you. I know the pain of having to relabel all my soaps - not a fun job.


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## xoticsoaps (Jul 7, 2015)

Dorymae said:


> I'm sorry if it came off harshly. ( looking back I can see that it did. )
> 
> As I said most of us did find out we were labeling incorrectly, and had to research and 'find out'.  I did not intend to sound so mean, with such important information, I simply did not want anyone else to follow the advice and not know the truth.
> 
> Sorry again.




Yeah, after your last post I was starting to think that's how you meant it and you just wanted to get that in before she took that advice. It's just how strongly you objected before that kinda took me by surprise. I wasn't a member of this forum back when these changes were circulated among you guys, so I really do appreciate the video. No hard feelings. You're just and avid truth lover. Lol


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## new12soap (Jul 7, 2015)

hozhed said:


> Good enough. can I assume EO are "all natural" or are there artificial ones??



There is no legal definition of "natural". A synthetic fragrance is a fragrance oil. Essential oils are derived from plants, BUT some are pressed, others are extracted with solvents, so it would really depend on knowing exactly how each oil was sourced (assuming you could trust your supplier's information) and what one's personal feelings about "natural" are.

I wouldn't use the term.


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