# Ingredients Descriptions



## Catscankim (Jan 5, 2021)

This might be more of looking for a loophole...well, its definitely looking for a loophole lol.

I know we cannot make claims about our soaps. Is it legal/acceptable to have a page on your sales website that gives information factoids about individual ingredients, without referencing its use in soap?

_"Lavender is known for ..... People like Shea Butter because...

Please note, these pages are for informational purposes only. No medical claims are implied, nor meant to diagnose or treat..."_

I know that is very generic LOL. Just giving you an idea where my mind is going. Or would this be asking for trouble?


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## soapmaker (Jan 5, 2021)

Marketing,  marketing


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## lsg (Jan 5, 2021)

I have never promoted EOs or the qualities ascribed to them for my soap, lotions, creams, etc.  You have to be very careful with marketing and promoting the ingredients in a product because of FDA rules.


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## Catscankim (Jan 6, 2021)

It was just a fleeting thought really. I probably won't give it much real estate in my brain, at least for now. I am turning out to be a not-so-good web designer to begin with, let alone trying to figure this out.

I woke up with the idea, so I must have been having some soapy dreams, or rather website nightmares LOL. I was thinking a whole section dedicated to ingredients, or maybe an ingredient spotlight of the week and write about it...the history, folklore, why people love it. Maybe that could work for a blog?


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## earlene (Jan 14, 2021)

No, is the short answer.  Refer to Marie Gale's books and her blog.  There are also several articles online around the soapmaking sites that report on problems soapmakers have had when the FDA came calling after seeing just what you describe on the soapmaker's webstore.

Here is one such:  A Surprise Visit from the FDA - Soap Queen

See also: 








						Claims and Intended Use
					

When describing your product, keep in mind that the whole point of “claims” is that they are providing information to the consumer about the intended use. Technically it’s not the claim, but what the consumer perceives to be the intended use of the product that determines whether it is a drug or...




					www.mariegale.com
				











						FDA Cracking Down On Cosmetic Product Claims
					

Based on the warning letters the FDA sent to cosmetic manufacturersin the last year the FDA is starting to crack down on product claims




					www.mariegale.com


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## KiwiMoose (Jan 14, 2021)

Oh how I'm so glad I don't live in the US with problems such as these.
Though I do love my American friends very much


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## Peachy Clean Soap (Jan 14, 2021)

Can be touchy' as ive read above' but then again I read it all the time info pertaining to products attributes.


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## Zany_in_CO (Jan 15, 2021)

Catscankim said:


> I know we cannot make claims about our soaps. Is it legal/acceptable to have a page on your sales website that gives information factoids about individual ingredients, without referencing its use in soap?
> 
> _Please note, these pages are for informational purposes only. No medical claims are implied, nor meant to diagnose or treat..."_


*Chagrin Valley* has a separate place to list ingredients and what they bring to the products they offer. As a consumer, I find it helpful. I'm not sure whether Marie Gale would approve or not.

I put _*"Formulated for Denver's dry Alpine desert climate"*_ on my labels.

Regarding the "Soap vs. Cosmetic/Drug" issue, I believe there's a gray area where you can write descriptions that mention the beneficial qualities of an ingredient without mentioning a specific "cure" or application for the product.


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## Marsi (Jan 17, 2021)

this is the definition of labeling (with my bold) according to your Federal Food, Drug and Cosmetic Act (*)

_(m) The term “labeling” means all labels and other written, printed, or graphic matter (1) upon any article or any of its containers or wrappers, or (2) *accompanying such article*._​
i looked at some business websites from the FDA warning letters list and those appear to have removed claims from the entire website
_








						Warning Letters Address Drug Claims Made for Cosmertics
					

Warning Letters citing drug claims associated with topical skin care, hair care, and eyelash/eyebrow preparations, on both product labeling and Web sites.




					www.fda.gov
				



_​​further reading
_








						Is It a Cosmetic, a Drug, or Both? (Or Is It Soap?)
					

An overview of the legal differences between cosmetics and drugs, and whether a cosmetic can be both or just a soap.




					www.fda.gov
				



_​
(*) Federal Food, Drug and Cosmetic Act, as published by the Legal Information Institute
_








						21 U.S. Code § 321 -  Definitions; generally
					






					www.law.cornell.edu
				



_​


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## Zany_in_CO (Jan 18, 2021)

FWIW: Under the heading _*"Is it a Cosmetic, a Drug, or Both? (Or is it Soap?)*_

*QUOTE: 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._* END QUOTE.*


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## Marsi (Jan 18, 2021)

apologies for the confusion, in Australia soap is a cosmetic

examples of warning letters for soap products making drug claims can be found here:
https://www.fda.gov/inspections-com...liance-actions-and-activities/warning-letters
(and here, but not so relevant to small soap businesses):
https://www.fda.gov/drugs/enforceme...ce-violation-letters-pharmaceutical-companies


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## SideDoorSoaps (Jan 20, 2021)

“Soap” is generally regulated under the CPSC as long as it is only soap that cleans but the whole “intended use” consumer perception could push you into cosmetic / drug territory if you try to put supporting evidence of ingredients of your soap. Like Zany pointed out, soap that cleans is exempt from FDA regulations. Makes me think of when people say “laundry soap” or “dish soap”, I rarely see ingredients on commercial cleansing products.


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## TheGecko (Jan 20, 2021)

No.

That’s the short answer.

The long answer is...sure. You’ll find the information to get you started here: Frequently Asked Questions on Soap

Registration is voluntary on the cosmetic end, though it is encouraged.  The FDA doesn’t need to approve your soap, but they will approve the colorants.  Your will need to start adhering to stricter manufacturing process.  Labeling is a little more involved.  If you need to make any ‘drug’...well then you will need to register your company and submit a list of your products for evaluation.


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