# Brand name soap and labels



## scrubbie (Feb 15, 2012)

Are we allowed to say brand names on this board? I am asking because I want to get into a discussion on labeling. This company is a larger so company which is local but I believe they service organic stores nationwide. I think they started with bars and went to lotions and etc. I bought a fankinsence and myrrh soap. I want to share what I saw on the label and ask about it. I wont further comment unless a moderator says it is okay.


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## Sunny (Feb 15, 2012)

is it zum?!


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## scrubbie (Feb 15, 2012)

yes. It is. Okay I saw some threads about them in the search. SO I will add my argument or questions here. Label reads
Saponified 100%food grade olive, coconut,palm, & Castor Oils in a goat milk base, with herbs, pure essential oils, fragrance oils and aloe. 

Back of Bar reads Deep Sweet woodsy are wise to ways of stresed aging skin. 

Number one comment and question: Dont they have to list what oils they are and herbs in case someone has allergies? How would you know?
The fact that they mention stressed and aging skin, do they not have to list the INCI name in product label because this is inferring it is medicinal or cosmetic?
I am asking because I heard of a story of the FDA going to  craft fair and charging people with 1000 tickets for improper labeling.
A woman who purchased soap didnt like what she smelled can called the FDA. These people were ticketed for the INCI name thing.

There was a secondary issue with a woman who was allergic to cinnamon who purchased a cinnamonn oat meal soap and she got a rash and complained. SO given these variables and these sitautions is this legal or are they taking a risk?


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## Genny (Feb 15, 2012)

If you list one ingredient on your labels, then you do have to list all of them.

I honestly don't know if they have to list the specific eo or herb though, since if you use fo's, you don't have to say the specific one that you use.

But if they say that the soap does anything but clean, then it's a cosmetic.  So they would have to list the INCI names for ingredients then.


The allergy thing is the number one reason I don't buy things with out an ingredient label, but it sucks when people don't list *everything* in the product.  I had a nasty allergic reaction to aloe in a body butter when the person only listed the oils and then shea butter, not shealoe butter, which is what they put in there.


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## debbism (Feb 15, 2012)

As someone who buys for an allergic child, I would never purchase a product that was not labeled with all ingredients.  Allergies are strange things and there can always be a reaction to any ingredient so why the secrecy?

Hence I always put every ingredient on my soaps....I list each EO separately and do not list "EO Blend" like i have seen other places.


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## scrubbie (Feb 15, 2012)

There was one lady there who received a 1000 ticket ( cannot confirm read on other forum) for selling wine soap because the Inspector said she needed a liqour license. <---- not sure if true or not


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## Sunny (Feb 15, 2012)

I have asked this a thousand times! HOW do they get away with it?!

they list "saponified oils" - though I think this is legal?
"goat's milk base" what?
eo, herbs, colorants not listed
claims


there is a company local to me that uses only EO but lists "fragrance" in the INCI, followed by parentheses which state that the fragrance is made up of only eo - I think this must be the loophole to being able to use EO and not list them individually? they ARE tagging the eo blend as "fragrance."

so it says:

Lavender and Clary Sage Body Balm (name of product)

Ingredients: ingredient, ingredient, ingredient, fragrance (made of pure essential oils, including lavender and clary sage), ingredient, ingredient.


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## debbism (Feb 15, 2012)

as far as I know, as long as you are not claiming anything but a soap that cleans, you do not even have to list ingredients so "saponified oils of:" would be ok to use.  I have seen this many times on other soaps and I have not read anything to the contrary.

EDIT:  But to add again, listing the ingredients in SOME form is, to me, the right thing to do regardless of what the law says


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## green soap (Feb 15, 2012)

That's right, at least in the USA.  Soap needs to be labelled as:

Soap.  It has to say somewhere in there that it is soap.  Should be obvious?  

The weight should be listed. 

The manufacturer name or contact information.

If you do not make any health claims you do not need to list the ingredients, other than say it is soap.

This is as far as legalities.  As far as customer appeal, I think it is better to list the ingredients.  But is is not required if you just sell 'soap'.  Any health or cosmetic claim will classify the product as a cosmetic, then the labelling requirements become more complicated.


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## bombus (Feb 15, 2012)

Sorry to say that according to the HSMG, your home address also must be on the label unless your business is listed in the local phone book. 
I think that sucks. I don't want some meth manufacturer breaking in to steal lye for their product, and I don't really want my customers knocking on my door.


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## debbism (Feb 15, 2012)

For those that craft soap from home, putting your home address is dangerous and I cannot imagine the enforcement of that.  Using your website and listing your city & state would suffice since your contact information can be obtained on the website.


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## semplice (Feb 15, 2012)

bombus said:
			
		

> Sorry to say that according to the HSMG, your home address also must be on the label unless your business is listed in the local phone book.
> I think that sucks. I don't want some meth manufacturer breaking in to steal lye for their product, and I don't really want my customers knocking on my door.



A lady on another forum I'm on shared a story about a customer coming to her home to purchase products.  She got her address from the label and just showed up!  Luckily she was a nice lady and the soaper actually had products on hand to sell her!


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## fiddletree (Feb 16, 2012)

In the EU, we have to have a complete INCI, but essential oils can be clumped together as 'fragrance' or 'parfum'.  However, we do have to list ALL allergens present in the product on the ingredient list, which are usually from EOs.  It's a royal pain to do, but I think that it is good for the customers.  If they know they have a problem with linalool, for example, they can avoid it!  Although I doubt anyone in the world knows which specific allergens found in fragrances they have a problem with.

Whenever I have bought soap in the US, I am super cautious, as it is so unregulated.


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## green soap (Feb 16, 2012)

I recently had a customer show up at my house when DH and I were having dinner.  He is a facebook friend, so i had met him once.  I turns out he wanted the jams (we also sell jams and other food products).  It was fine, but I did remove my home address from my facebook business page, so folks have to call or email and let us know they are coming.  It did startle us a bit. 

I agree that forcing soapmakers to print their home address is dangerous and not enforceable.


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## SoapyStacy (Feb 16, 2012)

Here is a post from someone on another board (regarding a post about a different well-known brand of soap):

"...my understanding is that as long as you don't mention that your soap has some beneficial quality, i. e., good for acne, etc., it is not considered a "cosmetic", it is "soap", and therefore INCI nomenclature is not required. "

This was tested via our US distributor and the FDA officer concerned
had a different spin on things, and INCI nomenclature was required. We
do not make any claims on our packaging. The response from FDA (the
exact written words from the FDA officer) was:

Soaps that do not contain any cosmetic ingredients such as fragrance
and colors and are purely made of saponified fatty acids are not in
FDA’s jurisdiction.

The only soaps that are not regulated by the FDA are solid bars of
basic unscented soap that have no cosmetic ingredients or claims.

In other words, if you add a fragrance then it becomes a cosmetic.


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## Healinya (Feb 16, 2012)

hmm... I'm being a downer, but this is my opinion. The fda requires that the manufacturer produce a safe product, and they assume they do until they are told otherwise... So, if a company can profit $100,000 a year and only have two or three minor lawsuits that settle out of court for $10,000... then they still make a profit and can choose to take their chances... that's why they have insurance.


*That* is a big part of why I make soap, and the people who enjoy my soap all love the fact that they know exactly what they are getting.


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## debbism (Feb 16, 2012)

SoapyStacy said:
			
		

> Here is a post from someone on another board (regarding a post about a different well-known brand of soap):
> 
> "...my understanding is that as long as you don't mention that your soap has some beneficial quality, i. e., good for acne, etc., it is not considered a "cosmetic", it is "soap", and therefore INCI nomenclature is not required. "
> 
> ...



This is good to know.  I do think the FDA officer was being a hard-ass since the FDA site specifically says this:

*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 you follow them to a T, it says nothing about fragrance and color.  I find it particularly disturbing that they can publish one thing and act upon something else.


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## Deda (Feb 16, 2012)

The owner of IndigoWild is a member here, she doesn't post, but she can still see what's written.

I believe that the way she labels her soap is within the guidelines for the CPSC.  They are the ones who regulate soap, not the FDA.  Now if you make claims about your soap then you're stepping over lines and it becomes a cosmetic.  Simply adding a fragrance doesn't affect this status.

Also, dangerous or not, it's REQUIRED that you list your address if your business is not listed in the local phonebook. If you're worried about someone knowing your address then get a PO Box.


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## SoapyStacy (Feb 16, 2012)

I'd like to know if it is allowed to label a product "dish soap" or "hand soap", or is that going too far?


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## PippiL (Feb 16, 2012)

you really have to list your address, if you sell regular non cosmetic claiming soap?


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## debbism (Feb 16, 2012)

I would suggest just getting a PO box under your business name - or any mailbox/postal type store.  Then you can list that without security issues.


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## PippiL (Feb 16, 2012)

I will do that,I have to deal with the post office anyways.They have my parcel stuck at JFK airport since December and the post office people have no clue what to do ?????


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## debbism (Feb 16, 2012)

PippiL said:
			
		

> .....and the post office people have no clue what to do ?????


+
Oh boy....don't get me started!


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## dirrdee (Feb 16, 2012)

you can rent a PO box at some UPS stores and then they give you their actual street address to use....this will make you more credible as some people will not consider you so with a PO box.  Personally I am relunctant to do business with people who only have a PO box...its a matter of trust.


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## Deda (Feb 16, 2012)

My home address is a matter of public record, it's on my business license, my home occupation permit, my business name registration and it's listed with the state corporation commission.


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## bombus (Feb 16, 2012)

Yes- it must be the home address. The address is supposed to be where you as a manufacturer can be found. You are legally responsible for the safety of your product, and if there was
a problem, the world needs to know where to deliver the legal papers.

I asked at the post office, and the clerk said that they would not give out your home address if anyone came looking for you with court papers- 
so I don't think that would satisify the government as a legitimate address. I don't know about the places that rent out mail boxes that allow you to use their street address such as:

Clean Soap Co.
(Suite number)
(street address of the post box store) 
AnyTown, AnyState

I asked Marie Gale (the expert at the HSMG about labeling law) about putting the address of the retail store where I have my soap for salein order to avoid putting my home address on the label.
 She said the address should be of the person who is legally responsible for the product, and that would make the store responsible.

I finally gave up and have my home address in pretty small font followed by my phone number in large font along with my web address.


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## scrubbie (Feb 16, 2012)

Oh no I am not saying anything about the company, I purchased a soap of frankinese and myrrh and cant stop sniffing it. HAHHAH I was just wondering about labeling from all I have studied and read and looked at. How precise the labeling has to be. I am studying for my soap guild certification and I just found it curious.


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## carebear (Feb 16, 2012)

i have yet to understand the benefit of a guild certification.  what will you then be certified to do?
does the education include not selling until you know what you are doing and why and  can consistently make good soap??


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## Deda (Feb 16, 2012)

carebear said:
			
		

> i have yet to understand the benefit of a guild certification.  what will you then be certified to do?
> does the education include not selling until you know what you are doing and why and  can consistently make good soap??



Ayep.


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## scrubbie (Feb 16, 2012)

Certification makes me feel better.  Even if it means nothing. I at least feel like I can accomplish something at this time. Because of using oxygen at this time when I go out, cant go to college. Cant go alot of places. 
It means that I could achieve something. Anything. Plus you send them samples of your stuff. I sat on a couch and stared at a wall for 2 years, when I was told the Phen Fen I took in 1997, came and took most of my life away.


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## carebear (Feb 16, 2012)

ah.


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## Sunny (Feb 16, 2012)

I don't disagree with listing the eo's together, especially when you think about the fact that no one has to list each component of a fragrance oil (you don't even know what they are in most cases). but as far as the colorants and herbs being grouped all together, I thought they would have to be listed separately.


I thought I read somewhere that you specifically could not get a P.O. box for your business address... That it had to be a physical address. (don't ask me where I read that, and I could be wrong about it, I just remembered it because I was thinking it would be weird/dangerous to have a home address listed on a label)


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## PippiL (Feb 16, 2012)

yes, I don't like to give my home away like that either,having children etc.
I understand the reason, but I think there must be another way...
DON"T LIKE IT !


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## Deda (Feb 16, 2012)

Lease or buy business property.  

This might be THE year.  I hope.


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