# My recent market analysis



## Carl (Oct 27, 2019)

I've been doing a lot of analysis of the soap business lately.  I have purchased multiple bars from local craft shows/soap shops and from Etsy.  Because I was just curious about what other people are doing and how they go about doing it.  I've compared my knowledge of soaping (things I've learned from this site, reading several books, and personal experience) to what I see and the real world.

And my conclusion is: There are a lot of sellers that are just flat out liars.

Let me start


Not 1 bar that I had purchased weighed what it said on the label.  NOT ONE!  The 5.0 oz bar weighted 4.3 ounces.  All the 4.5 oz bars were in the high 3's with exception to 1 which was 4.1.
People sell their soap labeled as "All Natural" when it contains Fragrance Oils and Mica powders.  This is very common.

Most people don't list out the entire ingredient list like they should.  They just put Mica on the label, but they don't break it down into "Polyerster-3, Tin Dioxide, etc."
People make medicinal claims about their soap all the time; cures dry skin; cures eczema, and everything else.  They even call it dry skin soap.

I spoke to one girl who sells only hot process.  Her reasoning is that there is no cure time, so she can put it up for sale immediately.  

And these are people that are selling a lot of soap at the top of the Etsy search results etc.  

Of all the bars that I tested as a "Competitive Analysis," I must admit that they were all really nice bars of soap.  It's just the misleading marketing that gets me!

There's my rant, LOL.

Thanks for listening


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## cmzaha (Oct 27, 2019)

Guess you need to come to my booth sometime, except I am in CA. I weight each bar after approx 3 month cure before packaging and labeling then deduct 10%. I label all ingredients in order and make no claims. I hate vendors that do anything less, but many many do


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## Carl (Oct 27, 2019)

cmzaha said:


> Guess you need to come to my booth sometime, except I am in CA. I weight each bar after approx 3 month cure before packaging and labeling then deduct 10%. I label all ingredients in order and make no claims. I hate vendors that do anything less, but many many do



Too bad everyone cannot be like that.  Your 3 months is 8 weeks for me.  I want to label my bars as 4.5 ounces and anything less goes into the discount pile.

It's hard to compete and make a marketable listing when everyone else is flat out lying.  The weight doesn't bother me as much as the "Natural" claims or the medicinal claims.  At least with the weight you could adjust your bar size, etc and still be honest.  But when someone is selling "Banana Mango Strawberry" with fragrance oil in the ingredient list and calling it All Natural, nothing you can do about that.  
Only way you can compete with that person is to lie yourself (which I don't want to do).


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## Cellador (Oct 27, 2019)

I went to a market recently & sniffed around the soap booth. She told me the bars were all natural and they only used EOs. I smiled as I sniffed, because I know that the sandalwood or vanilla I'm smelling is not from an EO. I even asked her about the vanilla,"I didn't think there was a vanilla essential oil..." and she continued to claim there was an EO but it was hard to find. Anyway, I thanked her and, of course, didn't buy anything.
I cannot stand liars!


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## shunt2011 (Oct 28, 2019)

I've come to the conclusion that there's nothing you can do about the liars and cheaters.  I no longer worry about others.   I focus on my products and keep my integrity with honesty.  I weigh all my soaps before packaging and round down.  My soaps start at about 5.5 oz.  I list 5 oz and if they are below that I put them in my discount bin.   I see it all the time with people making claims.   Even when customers come in asking for poison ivy soap or other skin specific soaps I tell them right up front that it's all a marketing scam and soap is soap.  It washes off and gets you clean.  Then I tell them why my soap is good.  It's well formulated, doesn't strip all the natural oils from your skin and is just a darn good soap.


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## Marilyn Norgart (Oct 28, 2019)

I round my bars down to the nearest whole number--most of the bars I sell for 4oz are closer to 4.5 or higher. but to be honest I am the only one I have seen around here that even bothers to put a weight on the soap, that includes the handmade in the stores.  it bothers me somewhat but I can only make sure I do what I am supposed to.  the one craft fair I was at this summer though I was kinda ticked--I was busy setting up and this lady was walking around with sample of GM lotion telling people it cures psoriasis and so does her soaps--she stopped and asked if I wanted to try it and said it would cure my psoriasis--and when I told her it would not she saw a burn mark on my arm and said well it will heal that right away.  then she proceeded to tell me she would sell me her products including her soap and I could sell them as my own,  I bit my tongue and just told her I thought that was a good idea and I would have to get ahold of her (what a twit)  unfortunately her booth was before mine and I spent some time explaining to people that stopped wanting to see "my" soap that cures psoriasis that soap or lotion would not cure it etc etc etc


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## cmzaha (Oct 28, 2019)

shunt2011 said:


> I've come to the conclusion that there's nothing you can do about the liars and cheaters.  I no longer worry about others.   I focus on my products and keep my integrity with honesty.  I weigh all my soaps before packaging and round down.  My soaps start at about 5.5 oz.  I list 5 oz and if they are below that I put them in my discount bin.   I see it all the time with people making claims.   Even when customers come in asking for poison ivy soap or other skin specific soaps I tell them right up front that it's all a marketing scam and soap is soap.  It washes off and gets you clean.  Then I tell them why my soap is good.  It's well formulated, doesn't strip all the natural oils from your skin and is just a darn good soap.


I do exactly as you do other than my weight labeling. All my soaps will weigh as my labels are maked or more in a year. I periodically do checks.


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## SoaperForLife (Oct 29, 2019)

shunt2011 said:


> I weigh all my soaps before packaging and round down. My soaps start at about 5.5 oz. I list 5 oz and if they are below that I put them in my discount bin. I see it all the time with people making claims. Even when customers come in asking for poison ivy soap or other skin specific soaps I tell them right up front that it's all a marketing scam and soap is soap. It washes off and gets you clean. Then I tell them why my soap is good. It's well formulated, doesn't strip all the natural oils from your skin and is just a darn good soap.


I also round down my soaps - most are 4.5 oz. when I wrap and I mark them at 4 oz.  to allow for shrinkage.  And yeah, I've had the poison ivy soap requests before as well as the soap for kitchens (odor eliminator).  I've also had requests for other types of soap that have led me on quests which is always fun.  My all time most hated request is from the people who ask me if my soaps are made with goat's milk (and I'm sorry if you are reading this and make goat's milk soap).


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## Lin19687 (Oct 29, 2019)

My soaps are about 5.5 oz after cure, I label as 5 oz

FYI, I list on my label 'Mica ' and Fragrance as I think most here do.


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## amd (Oct 29, 2019)

Last night I was relabeling some of my older soaps, so out of curiosity I weighed them as I went. For the most part most of mine were  20g over the label weight, but there were a few that were only 5g over... but still all were older and many of those soaps are 2+ years old.



Carl said:


> Most people don't list out the entire ingredient list like they should. They just put Mica on the label, but they don't break it down into "Polyerster-3, Tin Dioxide, etc."


is this a requirement? I label mine "Skin Safe Color". I wouldn't know where to start if I had to label my soaps as stated above.


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## LilyJo (Oct 29, 2019)

amd said:


> Last night I was relabeling some of my older soaps, so out of curiosity I weighed them as I went. For the most part most of mine were  20g over the label weight, but there were a few that were only 5g over... but still all were older and many of those soaps are 2+ years old.
> 
> 
> is this a requirement? I label mine "Skin Safe Color". I wouldn't know where to start if I had to label my soaps as stated above.



Not sure about the US but we have to use an approved CI colour number name which in think already incorporates the various mica components


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## amd (Oct 29, 2019)

@LilyJo, I suspected as much for EU. Out of curiosity (and OT, my apologies) do colors sold in EU provide the color number name or is that something you find out on your own, by assessment... or other? The OP is stateside, which is what made me curious. I can't remember coming across that specific labeling criteria - but I will admit that I have forgotten a lot in 4 years and am constantly having to refresh my memory.


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## TheGecko (Oct 30, 2019)

Carl said:


> Let me start:
> 
> Not 1 bar that I had purchased weighed what it said on the label.  NOT ONE!  The 5.0 oz bar weighted 4.3 ounces.  All the 4.5 oz bars were in the high 3's with exception to 1 which was 4.1.
> People sell their soap labeled as "All Natural" when it contains Fragrance Oils and Mica powders.  This is very common.
> ...




1.  It could be that their soap is so old that they didn't bother to reweigh it or they just assumed that xx size bar should weigh xx oz.  I just printed out labels for all my products for the craft fair except that I left the "oz/gram" blank and will hand write it after I weigh everything.  The majority of the soap I am selling has been curing for 8 to 16 weeks so I will round down.  

2.  The broadest definition of a *natural product* is anything that is produced by life, and that includes biotic materials (e.g. wood, silk), bio-based materials (e.g. bioplastics, cornstarch), bodily fluids (e.g. milk, plant exudates), and other materials that were once found in living organisms (e.g. soil, coal).  

3.  Actually...if it's a true soap, you don't have to list your ingredients because it falls under the _Fair Packaging and Label Act_ and not the FDA.  It would fall under the FDA if you made a *cosmetic* claim (e.g. moisturizing) or *drug* claim (e.g. treats  skin conditions such as acne or eczema).  With that said, folks in the US have been condition to expect to see a list of Ingredients on the label and so that is what I do, but since I make no claims other than it is 'soap', I don't get into detail with regards to the exact scents and colors I use and instead use a 'may contain' statement.  I will note additives like Walnut Shells, Pumice, Coffee Grounds, etc.

4.  According to the FDA website: _ If it’s a* cosmetic,* it’s regulated by FDA. Neither the product nor its ingredients need approval by FDA, except for any color additives it contains. It is your responsibility to make sure your product is safe for consumers when it is used as intended, and to make sure it is properly labeled. You don’t need to register your company or file your product formulations with FDA, although we do encourage you to participate in our Voluntary Cosmetic Registration Program.  If it’s a *drug*, it’s regulated by FDA. It must comply with the regulations (called “monographs”) for certain categories of non-prescription drugs or requirements for new drug approval or. You will need to register your firm and list your products with FDA.
_
5.  She's not wrong.  While it takes 24 to 48 hours for Hot Process soap to fully cool down and harden, once it does it can be used.  Technically you can use Cold Process soap once it has saponified and passed the zap test, but it will be a very soft soap and won't last very long.  What curing mainly does is to harden the bar by allowing more water to evaporate and the harder the bar, the longer it lasts (providing you let it dry between uses).


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## dixiedragon (Oct 30, 2019)

It does irritate me when people call their soap "natural" with scents like dragon's blood, red velvet cake and blue raspberry. 

Not that I sell much, maybe 1 show a year, but I just put "color" on mine.


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## MarnieSoapien (Oct 30, 2019)

amd said:


> @LilyJo, I suspected as much for EU. Out of curiosity (and OT, my apologies) do colors sold in EU provide the color number name or is that something you find out on your own, by assessment... or other? The OP is stateside, which is what made me curious. I can't remember coming across that specific labeling criteria - but I will admit that I have forgotten a lot in 4 years and am constantly having to refresh my memory.


The distributor supplies MSDS and it lists the INCI names. One of the colorants I use is Blackberry Mica and the full list of ingredients is Mica, Titanium Dioxide, Tin Oxide and Iron Oxide. I'm still a bit fuzzy on the labeling requirements for the EU. I don't know if a general listing like Mica is acceptable or if each ingredient needs to be listed. Same goes for FOs. If I have to list each thing out, I'm either going to need bigger labels or a smaller font.


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## LilyJo (Oct 30, 2019)

MarnieSoapien said:


> The distributor supplies MSDS and it lists the INCI names. One of the colorants I use is Blackberry Mica and the full list of ingredients is Mica, Titanium Dioxide, Tin Oxide and Iron Oxide. I'm still a bit fuzzy on the labeling requirements for the EU. I don't know if a general listing like Mica is acceptable or if each ingredient needs to be listed. Same goes for FOs. If I have to list each thing out, I'm either going to need bigger labels or a smaller font.



If you  are selling your cosmetic assessor will give you the labelling/ingredients list. As far as I know you have to list the CI colour number not each mica ingredient and with FO you have to list the allergens separately.


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## Lin19687 (Oct 30, 2019)

@TheGecko  IF you put Ingredients on your Label, then you MUST  use the rules for labeling.... all things in the order of weight used.
Anyone that thinks other wise is sorely mistaken.
 'may contain' is not allowed if you are listing ingredients.

I believe Mica/Color/Fragrance can be listed as such.


As for HP being able to use once cooled, sure, so can CP after a few days (so long as you KNOW for a fact that the Saponification process is truly done) But you will have one crappy soap that no one wants to use again... unless you already have alligator skin lol.  Oh and HP used before a good 8 week cure will not last long at all.  It really does need that time to get harder.


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## TheGecko (Oct 31, 2019)

Lin19687 said:


> @TheGecko  IF you put Ingredients on your Label, then you MUST  use the rules for labeling.... all things in the order of weight used.  Anyone that thinks other wise is sorely mistaken.



Since true soap is exempt you can legally list your ingredients any way you want them, BUTT, you would run the risk of deceptive labeling practices if because of the way you list your ingredients...folks think your soap is primarily made with Cocoa Butter because you listed it first, when in fact it only contains a small amount thereof.  So BEST practice for labeling in that instance is to list your ingredients in descending order of predominance.  In my case that would be Olive Oil, Water, Coconut Oil, Palm Oil (RSPO), Sodium Hydroxide, Cocoa Butter, Shea Butter, Castor Oil, Sodium Lactate and Kaolin Clay.  Technically I don't have to include the last two since they are less than 1%.  

A second way of labeling, since true soap is exempt and because folks can be naive when it comes to how soap is made and so freak out when they see 'Sodium Hydroxide' or that you have a LOT of 'water', you can use “Saponified oils of ___."  In my case that would be "Saponified oils of Olive Oil, Coconut Oil, Palm Oil (RSPO), Cocoa Butter, Shea Butter and Castor Oil."



> 'may contain' is not allowed if you are listing ingredients.  I believe Mica/Color/Fragrance can be listed as such.



I didn't say it was, I was clear to say:  _"I don't get into detail with regards to the exact scents and colors I use and instead use a 'may contain' statement."   _The reason for ME doing this is while I use the same recipe for all my regular soap (I also make a Goat Milk Soap), I don't always add scents and colors and so I can simple print out a box of labels all at once instead of having to customize both labels for each batch of soap.

I also said:  _"I will note additives like Walnut Shells, Pumice, Coffee Grounds, etc."_  And will go a step further to say that I think it's important to state your additive in case of allergies or sensitivities to those ingredients.



> As for HP being able to use once cooled, sure, so can CP after a few days (so long as you KNOW for a fact that the Saponification process is truly done) But you will have one crappy soap that no one wants to use again... unless you already have alligator skin lol.  Oh and HP used before a good 8 week cure will not last long at all.  It really does need that time to get harder.



Which is what I said.



dixiedragon said:


> It does irritate me when people call their soap "natural" with scents like dragon's blood, red velvet cake and blue raspberry.



Before you get too irritated, you should perhaps find out how those scents are made; whether they are made from synthetic compounds or from isolates (a single scent molecule).  While an Essential Oil is called after the plant it is extracted from, Fragrance Oils made from isolates can be called anything you want it to...and still be 'natural'.


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## shunt2011 (Oct 31, 2019)

If you list any ingredients on your label you must list them all in descending order.  I list everything as many folks these days are allergic to just about anything.   I do however, just list fragrance and mica or oxides etc....


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## LilyJo (Oct 31, 2019)

Whilst I understand what you are saying @TheGecko you cant make definitive statements like that without some qualification. I would hate newbies to read this thinking that they can label how they want wherever they are in the world, you cant.

If you sell ( or even gift ) in the EU and in other countries, there are strict rules on labelling and soap is soap is soap. It is a cosmetic and labels are produced using a set standard and you are required to include all ingredients including mica, EOs and to state allergens.

I know the rules are somewhat different in the states I just hate to see such definitive statements handed out when the forum covers many other countries.


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## Lin19687 (Oct 31, 2019)

@TheGecko NO, you are wrong.  I will not argue it because it seems you are set.
IF you are saying it is JUST SOAP, you can choose to NOT LIST ANYTHING.  But the second you list any ingredient you need to list in order, period. You may want to read up on that subject. 

And there is more to curing then  'mainly hardening the bar'


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## Mobjack Bay (Oct 31, 2019)

It’s good to re-read the guidelines occasionally.  As I understand it, Marie Gale is a reliable authority for US soapmakers.

https://www.mariegale.com/ingredient-labels-soap/

Here’s what she states towards the bottom of the post:

“*A Note of Advice*
If you do decide to put the ingredients on a true soap, be aware that consumers expect that if you say “Ingredients: ____”, you are stating all of the ingredients in descending order of predominance. To withhold ingredients isn’t in violation of the FDA regulations, but it might be considered “deceptive”.

A better way to do it, if you are using non-standard ingredient names (such as “saponified oils of ___”, or are not putting all the ingredients on the list (ie saying “essential oil blend” instead of listing them out), it’s probably better to put it as information, rather than an actual “ingredient declaration.”

Something like “We make our soaps with saponified oils of ___ and scent them with only pure essential oils, including much-loved lavender and patchouli oils.”  That makes it more informative, and the consumer can see that it’s not a true ingredient declaration as they normally expect on cosmetics.”

Even though I am not selling my soaps, I am fully labeling them. I feel my family and friend testers should know if a soap has lard vs. palm, EOs vs. FOs, clays, micas, carrots, aloe, cucumber, madder, indigo, etc.


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## KiwiMoose (Oct 31, 2019)

It is very annoying when you are at a market and someone has just been told lies by the soap soap stall just five doors down from yours.  People really do want to believe the lies!  I always just quote my sister in law - who does have eczema - and how she has now ditched all soap that is commercially made, including liquid soap, in favour of _my_ soap.

Dove - with 1/4 moisturizing cream.  People still cite this as think it is gospel!  Actual ingredients list: *Ingredients*: Sodium Lauroyl Isethionate, Stearic Acid, Lauric Acid, Sodium Tallowate or Sodium Palmitate, Water (Aqua), Sodium Isethionate, Sodium Stearate, Cocoamidopropyl Betaine, Sodium Cocoate or Sodium Palm Kernelate, Glycerin, Sodium Chloride, Tetrasodium Etidronate, Tetrasodium EDTA, Titanium Dioxide (CI 77891).


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## TheGecko (Oct 31, 2019)

LilyJo said:


> Whilst I understand what you are saying @TheGecko you cant make definitive statements like that without some qualification. I would hate newbies to read this thinking that they can label how they want wherever they are in the world, you cant.
> 
> If you sell ( or even gift ) in the EU and in other countries, there are strict rules on labelling and soap is soap is soap. It is a cosmetic and labels are produced using a set standard and you are required to include all ingredients including mica, EOs and to state allergens.
> 
> I know the rules are somewhat different in the states I just hate to see such definitive statements handed out when the forum covers many other countries.



Here's the deal...I was responding to the original poster who is in the US and who was purchasing from local places.  I am also in the US and that is how I responded, as one US resident to another, even going so far as to mention the _Fair Packaging and Label Act_ and the FDA, and even quoting the FDA.  Had the poster been located in another country or not had a location listed, I would have responded differently as I do not know what the exact labeling requirements are in other countries, though I am learning.



KiwiMoose said:


> People really do want to believe the lies!



People want easy peasy miracles...weight loss, younger looking skin, six-pack, etc.


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## Lin19687 (Oct 31, 2019)

Marie Gale link you posted was written in Dec 17, 2012 so those that are reading it please be aware of that and thing might have changed since then.  

Please people, go read the ACTUAL LAWS that are Up to Date.  It can be hard to understand the way they write but it is there.  Soap is soap and need not have ingredients but if you list just ONE then you need to list them all in the order.  Beyond that you need to go look yourself.

I PM'd someone (that listed all the oils EXCEPT the Lye on her packaging) that her labels were not correct .  But she told me that since she had been doing this for 10 years and read the rules that she is correct.
Well, she is not correct but didn't want to listen to someone that pointed that out to her.


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## Mobjack Bay (Nov 1, 2019)

Okay, I fully agree that we should not rely on potentially out of date information.  I really don’t want to flare things up, but I do feel compelled to seek out additional information when something seems unclear to me or if I have it wrong. The information below was obtained a few minutes ago by creating a customized report on soap using the small business “regulatory robot“ available on the US Consumer Product Safety Commission website.  _ETA: when soap is “true” soap, it is regulated by the CPSC_.  The very last sentence of the relevant section states that the CPSC has no specific labeling requirements for true soaps, unless they are intended primarily for children 12 and under.  The word “no” is underlined in the report.
_
First, it is important to provide a brief overview of how the federal government regulates “soap,” and which federal agency has jurisdiction over which type of “soap.”

Traditional soaps made primarily from fats and alkalis are regulated by our agency, the CPSC. However, many items called “soaps” on the market today are in fact not actual soap; they are cleansers, detergents, or other types of products regulated as either a cosmetic or a drug by the Food and Drug Administration (FDA). 

So, how do you tell if you are making a soap (CPSC) or a cosmetic/drug (FDA)? The FDA’s website on Soap: FAQs helps to lay out the differences:

“To meet the definition of soap in FDA’s regulations, a product has to meet three conditions:_

_*What it’s made of:* To be regulated as “soap,” the product must be composed mainly of the “alkali salts of fatty acids,” that is, the material you get when you combine fats or oils with an alkali, such as lye._
_*What ingredients cause its cleaning action:* To be regulated as “soap,” those “alkali salts of fatty acids” must be the only material that results in the product’s cleaning action. If the product contains synthetic detergents, it’s a cosmetic, not a soap. You still can use the word “soap” on the label._
_*How it's intended to be used:* To be regulated as soap, it must be labeled and marketed only for use as soap. If it is intended for purposes such as moisturizing the skin, making the user smell nice, or deodorizing the user’s body, it’s a cosmetic. Or, if the product is intended to treat or prevent disease, such as by killing germs, or treating skin conditions, such as acne or eczema, it’s a drug. You still can use the word “soap” on the label._
_You can read the entire regulation at 21 CFR §701.20.”

CPSC staff recommends that you take a close look through the FDA’s guidance webpages, including “Is it a Cosmetic, a Drug, or Both? (Or Is It Soap?),” “Soap: FAQs,” and also “Soaps & Lotions” to determine if you are in fact making a soap, cosmetic, drug, or some combination thereof.

As stated above, the CPSC regulates true soaps (not cosmetics or drugs) that are made primarily of fats and alkalis and that are manufactured for consumer use. To that end, the CPSC has no specific labeling requirements for true soaps not primarily intended for use by children age 12 and under.
_
The information was obtained by creating a report, starting here:
_https://www.cpsc.gov/Business--Manufacturing/Regulatory-Robot/Safer-Products-Start-Here/_


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## TheGecko (Nov 1, 2019)

Lin19687 said:


> Please people, go read the ACTUAL LAWS that are Up to Date.  It can be hard to understand the way they write but it is there.  Soap is soap and need not have ingredients but if you list just ONE then you need to list them all in the order.  Beyond that you need to go look yourself.



The information I quote came directly from the FDA website (as I stated) this morning, so maybe you can tell that they are wrong.


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## Dahila (Nov 1, 2019)

I am selling my bars with correct weight,  No natural not claims,  and Everything is there is also on Label.  In Canada soap is a cosmetic and must be labelled accordingly.  There is another guy who not only claims but writes on the fliers ; healing soaps,  eczema, psoriasis and excetera.... I do not care ,  I care about my sticking with regulation.   I am like shunt and Cmzaha educating people that soap does not heal it washes.  Lotions especially made with calendula help for my itching but they do not heal.  Salves help also but do not heal .  Nothing will heal psoriasis or eczema.  Lotion can only relieve dry skin,  which somehow helps but that's all
BTW I would never buy a bar of soap without full list of ingredients,  with my allergies it is not joke


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## Carl (Nov 1, 2019)

Wow, I opened a can of worms here.

So what it all boils down to is this:  If you use a Mica powder with the following ingredients: "Fluorphlogopite, Titanium Dioxide, Tin Oxide, Iron Oxide"

And you decide to list out ingredients.

Can you just say:

"Mica"

or do you have to break it out:
"Fluorphlogopite, Titanium Dioxide, Tin Oxide, Iron Oxide"

So we have 1 of 2 choices:

Oil #1, Oil #2, Oil #3, Distilled Water, Sodium Hydroxide, Fragrance Oil, Mica
Oil #1, Oil #2, Oil #3, Distilled Water, Sodium Hydroxide, Fragrance Oil, Fluorphlogopite, Titanium Dioxide, Tin Oxide, Iron Oxide

I've been breaking it out.  But do I really need to?  In the U.S.


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## Rsapienza (Nov 1, 2019)

Carl said:


> Wow, I opened a can of worms here.
> 
> So what it all boils down to is this:  If you use a Mica powder with the following ingredients: "Fluorphlogopite, Titanium Dioxide, Tin Oxide, Iron Oxide"
> 
> ...



I do #2 and I have always thought that we did not have to label soap (in US), if only said to be soap, but that if we did label, ALL ingredients had to be included, along with weight in oz/g per the Fair Packaging and Label Act, and identified as soap. Oh, and that any ingredient under 2% (not sure on that number) did not have to be in order of predominance, while the rest does.


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## TheGecko (Nov 1, 2019)

Dahila said:


> I am selling my bars with correct weight,  No natural not claims,  and Everything is there is also on Label.  In Canada soap is a cosmetic and must be labelled accordingly.  There is another guy who not only claims but writes on the fliers ; healing soaps,  eczema, psoriasis and excetera.... I do not care ,  I care about my sticking with regulation.   I am like shunt and Cmzaha educating people that soap does not heal it washes.  Lotions especially made with calendula help for my itching but they do not heal.  Salves help also but do not heal .  Nothing will heal psoriasis or eczema.  Lotion can only relieve dry skin,  which somehow helps but that's all



My soap just says 'Soap' on the label.  I could, on my regular soap put 'vegan', but it drives me nuts that Cornstarch is labeled 'gluten free' so I won't.  I could, on my regular and goat milk soaps that are unscented and uncolored and/or are only scented with EOs and colored with plant-based powders put 'all natural', but I'm not into gimmicks so I won't.  I will tell folks that a well-balanced true soap is better for the skin than a commercial soap because it's not a detergent and therefore does not strip your skin of natural oils.  At my last craft night, I had someone who was hesitate to try my soap because glycerin wasn't listed as an ingredient and it was a must for her.  I explained to her that a true soap already contains glycerin...that because I don't take it out like they do with commercial soaps, I don't have to add [a portion of] it back it.



> BTW I would never buy a bar of soap without full list of ingredients,  with my allergies it is not joke



My sister has severe skin allergies.


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## Marilyn Norgart (Nov 1, 2019)

Rsapienza said:


> but that if we did label, ALL ingredients had to be included, along with weight in oz/g per the Fair Packaging and Label Act



I believe all soaps need to have weight on them whether you have an ingred list or not


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## TheGecko (Nov 1, 2019)

Carl said:


> Wow, I opened a can of worms here.



Sometimes cans need to be opened to see what is inside of them.  



> I've been breaking it out.  But do I really need to?  In the U.S.



Yes and no.  

Yes - Ingredients should be listed in descending order of predominance (based on their percentage, by weight, in the product).  So MY ingredient labels says (by weight): Olive Oil, Distilled Water, Coconut Oil, Palm Oil (RSPO), Sodium Hydroxide, Cocoa Butter, Shea Butter, Castor Oil, Sodium Lactate and Kaolin Clay.  

No - Because Fragrance Oils are proprietary, there is simply no way to list the ingredients contained within them.  When it comes colorants...whether it's an oxide, plant powder, pigment, mica...so long as you don't make any cosmetic or drug claims, you don't have to go into details.  I use a "May contain scents and/or color".

And I'm going to add a 'yes' to additives like seeds, pumice, coffee grounds, nut shells, etc because of allergies.  On my Snickerdoodle Soap, I added Walnut Shells and it says in bold red letters:  CONTAINS WALNUT SHELLS.



Lin19687 said:


> @TheGecko NO, you are wrong.  I will not argue it because it seems you are set.



What the heck is your problem?!?  Seems the only person who is 'set' here is you, because you obviously haven't read a word I wrote.  But let me help you out here.



> IF you are saying it is JUST SOAP, you can choose to NOT LIST ANYTHING.



What I said:  _3. Actually...if it's a true soap, you don't have to list your ingredients because it falls under the Fair Packaging and Label Act and not the FDA. 
_


> But the second you list any ingredient you need to list in order, period. You may want to read up on that subject.



What I said:  _Since true soap is exempt you can legally list your ingredients any way you want them, BUTT, you would run the risk of deceptive labeling practices if because of the way you list your ingredients...folks think your soap is primarily made with Cocoa Butter because you listed it first, when in fact it only contains a small amount thereof. *So BEST practice for labeling in that instance is to list your ingredients in descending order of predominance.*_



> And there is more to curing then 'mainly hardening the bar'



Now you're just nitpicking.  The main reason we cure our soaps is to produce a harder and longer-lasting bar...that is repeatedly emphasized in every article and/or book or website I have read about soap making.  Does curing your soap do anything else...maybe, maybe not.  Some folks say that the longer you allow your bar to cure, the better it lathers...that would be logical to the extent that you are reducing the water content, but at some point the water will have completely evaporated and it becomes moot.


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## jcandleattic (Nov 1, 2019)

TheGecko said:


> The main reason we cure our soaps is to produce a harder and longer-lasting bar


That's not the main reason I cure my soap. It's so I have a bar that is at it's best, regardless of how "hard" or "long-lasting" it is. A well cured soap will be so much milder than one that is not - even with my softer soaps, it will still need to be well cured, not to get harder, to get milder. 



TheGecko said:


> Does curing your soap do anything else...maybe, maybe not.


Absolutely it does. That is time tested actual physical difference that almost all soapmakers can agree on. 



TheGecko said:


> but at some point the water will have completely evaporated and it becomes moot.


I think if I remember correctly that after reading some scientific journals and a few other soapmaking books - Maybe it was Dunn's book? can't remember, but it takes years for all of the water to completely evaporate out of soap, not just a typical 4-6 week cure.


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## Mobjack Bay (Nov 1, 2019)

I’m still not finding a requirement that all ingredients must be listed for “true soap,” but there are words and phrases in the various sources that point to issues with deceptive practices if you list some, but not all, ingredients.  I would want to know more if I decided to sell my product. (ETA: the answer to the “if one, then all?” question is here: https://www.mariegale.com/if-one-then-all/)

This very recent post by Marie Gale (January 6, 2019) is an easy read.  In the sections pertaining to ingredient labeling, she specifically adds “cosmetics only”.  https://www.mariegale.com/new-years-resolutions-check-your-labels/, but watch out if you claim your soap is cleansing!

Marie is also an official “HSCG Expert” now and has her own page in the Handcrafted Soap and Cosmetic Guild How-To Library. (Posted January 19, 2019, here:https://www.mariegale.com/members-of-the-hscg/).

This government webpage discusses the FPLA: https://www.ftc.gov/enforcement/rul...eform-proceedings/fair-packaging-labeling-act

“Basic Requirements: The FPLA requires each package of household "consumer commodities" that is included in the coverage of the FPLA to bear a label on which there is:

a statement identifying the commodity, e.g., detergent, sponges, etc.;
the name and place of business of the manufacturer, packer, or distributor;
and the net quantity of contents in terms of weight, measure, or numerical count (measurement must be in both metric and inch/pound units).”
The actual language in the US Code (law) is here, and, yes, it painful to read:
https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title15-chapter39&edition=prelim

Marie Gale also provides information on what must be included on soap labels in a post from 2015. She mentions further regulations that affect soap makers, such as state requirements for scales to be certified, here:
https://www.mariegale.com/myth-soap-labels-arent-regulated/

For example,
“For consumer commodities generally (including soap), the FTC created regulations (Title 16, Commercial Practices, Part 500, Sections 500.1 to 500.29) which specifically detail what must go on the label of every product (including soap).  These regulations go into greater detail and specificity on how each of the three items required by law must be actually done.

These regulations include things like where the information must be placed, how to calculate the correct text size, when the street address may be omitted from the label, acceptable methods to identify the product, etc.

The regulations require that the net contents are presented in both inch/pound (i.e. ounces and fluid ounces) *and* in metric (i.e. grams, milliliters).”

She goes on to list other considerations for soap makers, including that some states require “certification of scales used to weigh products for commercial sale (generally at a state level; often under the Department of Agriculture).”


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## SideDoorSoaps (Nov 5, 2019)

I feel your rant, @Carl. I was just at a show this weekend with seven other soapers and three of them had jewelweed soap for poison ivy, two had goats milk - one said 100% goats milk (are there no other ingredients?) and one makes beard balm with goats milk (and I didn’t see a preservative, I know there’s no water but milk spoils).

I weigh my soaps when I cut them and when I pack them to make sure they meet my 4oz weight on my labels. And I make no claims with my soap and put all the ingredients on there, even the micas with tin oxide, etc. Someone asked me if my ingredients were organic and while some of them are, I don’t tout them as such.

I don’t believe that they are all blatant liars but a lot are underinformed, misinformed and ignorant. I almost want to make a brochure to pass out about true soaps, labeling and FDA regulations. I know one soaper who is a friend of mine who makes things that are insect repellants and that according to the FDA is a drug and then not being registered makes it an unregulated (illegal) drug. OH MY.

I just try to do my best and make sure I am compliant and constantly reading and learning alll that I can to ensure that.


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## Carl (Nov 6, 2019)

Yeah, I'll keep this going even more.

Now I know that this is not a labeling requirement, but I did notice that only about 1 out of 10 soapers puts a batch number on her/his label.  You know where you tie the batch number back to a spreadsheet on your computer that has the batch numbers of all the ingredients that you used.

Again I know it's not required, but a good practice that takes A LOT of time, that very few people do.


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## Dahila (Nov 6, 2019)

Carl it is for you to quickly identify Which product is a problem.  I do not use it, but have all dates and products with tags in Soapmaker


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## shunt2011 (Nov 6, 2019)

Carl said:


> Yeah, I'll keep this going even more.
> 
> Now I know that this is not a labeling requirement, but I did notice that only about 1 out of 10 soapers puts a batch number on her/his label.  You know where you tie the batch number back to a spreadsheet on your computer that has the batch numbers of all the ingredients that you used.
> 
> Again I know it's not required, but a good practice that takes A LOT of time, that very few people do.



That's actually just good manufacturing practice.   All my batches have number and are easily identified. Especially if running a business.


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## LilyJo (Nov 6, 2019)

Yep, it's a part GMP and key part of EU regs.


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## Nanette (Nov 6, 2019)

I weigh and label my soaps with the weight, I reweigh to make adjustments and relabel if the weight has dropped ...I always list all ingredients as what they are--rose kaolin clay, green chrome oxide...as opposed to "color" and I use eos as fragrance so easy to list. I wouldnt think of doing anything less.


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## MGM (Nov 6, 2019)

This is a FASCINATING read and a good cautionary tale:
*A Surprise Visit from the FDA*
Most interesting, perhaps, is what provoked the visit: not an adverse reaction, not someone reporting her, but the FDA noticing that she described a scent as "medicinal" and said that TTO had antibacterial properties (AFAIK, the first is a subjective perception and the second is true). Shows you how little it takes to get inspected, and what upheaval it causes!

ETA: Here's a more detailed version of the story. I think it's actually this one that I first read.


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## TheGecko (Nov 7, 2019)

Mobjack Bay said:


> This very recent post by Marie Gale (January 6, 2019) is an easy read. In the sections pertaining to ingredient labeling, she specifically adds “cosmetics only”. https://www.mariegale.com/new-years-resolutions-check-your-labels/, but watch out if you claim your soap is cleansing!



Good article, but first I've read about including zip code; I just used City ST since my physical address is publically available.

My front label has three lines of text:

Name of my company (I have a ABN registered with the State)
Name of my soap which includes the word 'soap'
City ST  oz/g

I don't use fancy fonts, though I do_ italicize_ the soap name.  I haven't physically measured the text size, but I am using a oval shaped label that covers most of the front of the soap and all the text can be easily be read from six feet away.  I just checked the conversion chart for my font and the minimum pt I would need for 1/8" is 9 and smallest pt I use is 11 so I'm good there.

I use an 'address label' for my Ingredients, standard font, 11 pt and they are listed in descending order of predominance, and I include Sodium Lactate and Kaolin Clay even though they are less than 1%; the label in place on the on the back at the bottom.  I have one label for my regular soap and another for my GMS.  I do have 'May contain scent and color" on my regular soap and 'May contain scent' on my GMS.

I will be having an Ingredients page on my website that will offer more detail about the ingredients I use, including the INCI name, for all my products.

I did have several people at the Craft Fair inquire if my soap was good for acne or eczema.  I was expecting this from many articles and comments I have read and I explained that I make NO cosmetic or drug claims about my soap other than that it cleans.

This is even more interesting...thank you so much for posting it.

I, admittedly, do not have a 'manufacturing process' yet, but I am working on it.  I do follow FIFO and write the date I purchased my oils on the container and I empty my Cocoa Butter and Shea Butter containers before refilling with new.  I bought a rolling kitchen island where all my ingredients and equipment is stored, and where I actually make my soap, but I am starting to run out of room.  My husband is going to put up a small shelf about the 'island' for my Mica, Clays, Oxides (dry stuff).  Eventually I will move out to the garage so knowing about the cages for lights is very helpful.


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## Mobjack Bay (Nov 7, 2019)

MGM said:


> This is a FASCINATING read and a good cautionary tale:
> *A Surprise Visit from the FDA*
> Most interesting, perhaps, is what provoked the visit: not an adverse reaction, not someone reporting her, but the FDA noticing that she described a scent as "medicinal" and said that TTO had antibacterial properties (AFAIK, the first is a subjective perception and the second is true). Shows you how little it takes to get inspected, and what upheaval it causes!
> 
> ETA: Here's a more detailed version of the story. I think it's actually this one that I first read.


Thank you so much for posting this! I’m saving the extended article for reference.


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## Zany_in_CO (Nov 7, 2019)

Carl said:


> And my conclusion is: There are a lot of sellers that are just flat out liars.






  That's the way to bottom line it, Carl. Well said!


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