# More labelling questions (INCI, in pot/out of pot)



## Karri (Sep 28, 2011)

Two questions:

*1)* How do you list infusions/teas per INCI standards? (I'm in Canada.) e.g. alkanet infused olive oil used at x% of the recipe (along with "regular" olive oil and other oils/butters). Or rosehip "tea" used for the water.

*2)* Marie Gale (in Soap & Cosmetic Labeling) recommends using OUT of the pot names ONLY if you know/can test for exactly how much free fat/glycerin is remaining in the finished product, that kind of thing. Otherwise she says to use in-the-pot names which means listing sodium hydroxide and the "un" saponified names of your oils/butters.

In Canada I believe the idea is to list the *out-of-the-pot ingredients* (e.g. sodium cocoate, sodium olivate, etc) and chemicals used "in the manufacture" of the product but not actually in the finished product (i.e. sodium hydroxide) are not to be listed. 

Soooo ... this to me looks like two very different labeling protocols. Which feels like two different labels required if you're exporting to the US?

???

Karri


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## debbism (Sep 28, 2011)

It is my understanding that if you are selling it as true soap with nothing more or less and not claiming anything other than it being soap, labeling is not even required.

http://www.fda.gov/cosmetics/productand ... 115449.htm


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## Karri (Sep 28, 2011)

Actually in Canada soap is considered a cosmetic so it's the law to list ingredients per very specific guidelines set out by Health Canada (including using INCI terms).

In the U.S. it's optional but many soapers still prefer to list their ingredients as a courtesy to the consumer who increasingly wants to know what is in their bath and body products.


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## honor435 (Sep 28, 2011)

interesting, I still think those label readers would like to know what oils are used?


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## Karri (Sep 28, 2011)

Yes and I would be willing to bet that within a few years the FDA will require a full ingredient list. 

In the meantime though it would sure be nice if there was a CLEAR standard for North American labeling of soap. Every time I think I have it figured out I find another inconsistency or gap in the guidelines... it's making me nutso.

Karri


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## debbism (Sep 28, 2011)

I was not suggesting to NOT list ingredients....My point was that whichever method you are using now would be fine for the US.

Personally, I like to list what goes into the pot.


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## Soapy Gurl (Sep 28, 2011)

From the consumer side, I like the plain wording.  Olive oil, coconut oil, etc.  I think people like to understand what they are reading.  I would list the tea instead of water.  People know tea is made with water, or I really hope so.  For alkanet I would list it at the end, based on the order of how much you think was used.   :wink:


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## Karri (Sep 28, 2011)

Thanks for the input everyone.

Still hoping someone knows the _regulations_ or guidelines pertaining to my labeling questions? And the INCI names for teas/infusions?

Karri


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## Sunny (Sep 28, 2011)

Karri said:
			
		

> Thanks for the input everyone.
> 
> Still hoping someone knows the _regulations_ or guidelines pertaining to my labeling questions? And the INCI names for teas/infusions?
> 
> Karri



I'd like to know this as well. What is the proper way to do it.


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## Soapy Gurl (Sep 28, 2011)

Here is a professional product that contains African Red Tea.  They have a whole line of stuff.  You can look through the ingredients and maybe get your question answered.  It is the best idea I came up with.

http://sephora.com/browse/product.jhtml ... goryId=B70


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## Lotsofsuds (Sep 29, 2011)

I think this is why some people in the US who buy homemade soap think lye is not always used in some of the soaps  because of the way the seller chooses to label Out of the pot instead of In the pot.


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## agriffin (Sep 29, 2011)

I would think that you would list the infused material last.  I know when I infuse alkanet I use about 2 tablspoons per 8 oz of oil and I seive out.  I can the assume it is the least used ingredient.  So I would list it last as it's going to be the smallest ingredient.


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## fiddletree (Sep 30, 2011)

I am trying to figure out the same thing for the EU.  The regs say that I need to list the INCI ingredients, but I have seen soaps with the names of the actual ingredients (i.e. olive oil, water, sodium hydroxide, etc), and others with the saponified ingredients listed.  Not really sure which one I need to follow....


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