# Shampoo soap FDA classification



## juliab86 (Oct 30, 2013)

Want to start out by saying I am not selling, but I was wondering about one of the FDA labeling regs.

Without getting into labeling or advertising (I've read enough posts to know that open a whole different can of worms), I was wondering if shampoo soap, just by the fact that it's a shampoo, automatically puts it into the category of cosmetic? The below link seems to indicate that shampoos are cosmetics, but since shampoo soaps aren't really shampoos in the tradition sense, can they still be treated and labeled as soaps as long as you are not making any cosmetic claims?

Thanks!

http://www.fda.gov/cosmetics/guidancecomplianceregulatoryinformation/ucm074201.htm


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## dagmar88 (Oct 30, 2013)

As soon as you label your soap as anything other than just soap, it'll be either a cosmetic or drug, depending on the claims you decide to make.


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## juliab86 (Oct 30, 2013)

Thanks, dagmar!

So just to clarify, once you have the intended use of a product as for hair, it moves it from a soap to a cosmetic and the label has to follow INCI regulations


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## Paintguru (Oct 30, 2013)

From my interpretation of the linked reference (pages 62-63), "shampoo" is another acceptable term for soap, so shampoo bars of soap is still considered soap and can be labeled as such as long as the composition of the bar meets the definition of a "soap".

http://books.google.com/books?id=5F...wAA#v=onepage&q=labeling shampoo soap&f=false


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## grayceworks (Oct 30, 2013)

That's what I understood also. 1- it has to be made of soap. 2- can't have added cleansers, only soap for cleaning. 3- a rose by any other name, etc...

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My tablet has a wonky on-screen keyboard with a mind of its own -- ignore the typos :-/


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## juliab86 (Oct 30, 2013)

Thank you both! I love shampoo bars and hope to sell my own in a few years when I perfect a recipe (three different bars so far). Already tearing my hair out over regulations 

Any words such as "softening" or "volumizing" would push it into cosmetic territory though. It's funny how the same product can change with a few adjectives


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## lsg (Oct 30, 2013)

If your shampoo contains detergent-type surfactants, I don't think you can label it as soap.


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## juliab86 (Oct 30, 2013)

The shampoo bars I've been making is CP soap.

According to the link from Paintguru, that company lost the case because they did add a detergent.


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## dagmar88 (Oct 31, 2013)

*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].




I'd contact the FDA with your question.


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