# Labeling Beer soap....



## layserbrat (Apr 5, 2013)

I know I have to list all the ingredients that are in the beer that I use in my beer soap.....BUT Can I, in my marketing material, say what brand of beer I used?  I see some out on the web that do, and thought this would be a no-no.  Thoughts?  Comments? Right now I just mention that the beer I use is from local PA breweries....


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## Genny (Apr 5, 2013)

I think you can say what brand of beer you use, you just can't call your soap by the name of that beer or brewery, unless you have permission.


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## layserbrat (Apr 5, 2013)

Thanks!  I knew there was a catch...I just named it Beer....but wanted to let people know which local breweries I was using...

by the way, I love the quote on your signature line...makes me chuckle each time i read it.


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## DeeAnna (Apr 5, 2013)

I designed this label and soap as a fun gift for my stepson -- the beer is one of his favorites. The label prints onto the Avery 22814 oval labels with a glossy finish that I found at Walmart. I put the label on a simple cigar band cut from a brown paper bag -- rustic. The labels turned out nice when printed with an HP inkjet color printer. The soap was my first attempt at a swirl. The swirl came out more like random spots, but it looks okay even if it's not what I had in mind. The pig on the label is probably copyrighted, so it would not be something I would use if selling soap.


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## SoapPapaw (Apr 5, 2013)

In another thread you said, 





layserbrat said:


> I was just as confused until I got Marie Gale's book on labeling...it is written so the average person understands...well worth the money.



I don't have the book but have read her blog. Does she say there is any requirement to list any ingredients on soap. 
"True" soap made the cold process way is unregulated by the FDA, unless you make a claim the soap will change, alter or improve the consumers skin. Then it becomes a cosmetic and requires full ingredient disclosure.

You should be able to do something like this:

(company name) Pennsylvania Soap Works
(Tag line) From Amish Country
(Soap name) Dark Lager Soap
(Somewhere separate from name) Made with Beer from One of Pennsylvania's Micro Brews

Just my 2 cents.


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## SoapPapaw (Apr 5, 2013)

As for the beer name if it a trademark or registered name you might need permission from the brewery.

Case in point. Motorola Droid phone. On every ad whether in print or TV, there is a tiny disclaimer that says something like, "DROID" is a registered trademark of LUCASFILMS, INC. and is used with permission.


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## SoapPapaw (Apr 5, 2013)

Here is quote from Marie Gale's blog.

Start Quote
*Ingredient List When It’s Not Required*
Sometimes (often, actually) a soapmaker has a true soap for which no cosmetic claims have been made, but still wants to tell their customers what is in the soap.  Since it’s not a cosmetic, the FDA regulations don’t apply, so there is considerably more freedom in what you say.

In this case, you could use “saponified oils of ___”.  The ingredients don’t necessarily have to be in descending order of predominance – they don’t even have to all be included.

*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.
End of quote


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## sistrum (Apr 5, 2013)

I wouldn't put the name of the beer or brewing company on your soap without their permission in writing.

Unless opening a cease and desist letter from their attorney won't make your heart pound until you think your having a heart attack.


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## layserbrat (Apr 5, 2013)

SoapPapaw said:


> As for the beer name if it a trademark or registered name you might need permission from the brewery.
> 
> Case in point. Motorola Droid phone. On every ad whether in print or TV, there is a tiny disclaimer that says something like, "DROID" is a registered trademark of LUCASFILMS, INC. and is used with permission.


 
Wasn't going to name the actual beer name (cause each batch I use a different 'flavor'), just the brewery from where it was made....but I am thinking to play it safe,  I will just put something like "made with beer from local PA breweries"


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## layserbrat (Apr 5, 2013)

SoapPapaw said:


> In another thread you said,
> 
> I don't have the book but have read her blog. Does she say there is any requirement to list any ingredients on soap.
> "True" soap made the cold process way is unregulated by the FDA, unless you make a claim the soap will change, alter or improve the consumers skin. Then it becomes a cosmetic and requires full ingredient disclosure.
> ...


 I went back and forth on the "True" soap vs. cosmetic ingredient disclosure issue...and to play it safe I decided even though I am saying it is JUST SOAP, I decided to list all ingredients...that way if I say something stupid like how this soap has helped with my crows feet or dark spots, I am covered...at least I hope so....

I have read the book twice and still it is alot to take in...but it is very helpful....and although I am no where near ready to sell...I figured thinking about that stuff now will get me one step further from the cliff of confusion when I am ready...


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## Badger (Apr 5, 2013)

DeeAnna,
I love your Pickled Piglet


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## Lindy (Apr 5, 2013)

The INCI for beer is Beer so you don't have to list all the ingredients within it.  I am a total soap labeling geek and I do list everything via the INCI including all essential oils.  The reason I do this is because allergies are a very real consideration these days and INCI was developed so a dermatologist or even your family doctor can look up the ingredient and know exactly what it is.  For instance if you google Sodium Olivate you come up with


> "*About SODIUM OLIVATE*: Sodium Olivate is a sodium salt of the fatty acids derived from Olea Europaea (Olive) Oil(q.v.)."



In my experience most brewers are happy to have the free advertising of having their name appear on your label and permission is super easy to obtain.  For me I have a local craft brewer that I'm working with has allowed me to name 2 products after the brew that I'm using (PowTown Porter).  It makes for great interest in your soaps as well as your company.

Now the flying pig....  _*I freaken love it!!!!!!    *_That is all I have to say on that subject....


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## DeeAnna (Apr 5, 2013)

I was hoping it might lighten the mood on this thread. :grin:


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## melstan775 (Apr 5, 2013)

That is a super fun pig.  I'm with Lindy - fly piglet, fly!


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## layserbrat (Apr 6, 2013)

Lindy said:


> The INCI for beer is Beer so you don't have to list all the ingredients within it.  I am a total soap labeling geek and I do list everything via the INCI including all essential oils.  The reason I do this is because allergies are a very real consideration these days and INCI was developed so a dermatologist or even your family doctor can look up the ingredient and know exactly what it is.  For instance if you google Sodium Olivate you come up with
> 
> 
> In my experience most brewers are happy to have the free advertising of having their name appear on your label and permission is super easy to obtain.  For me I have a local craft brewer that I'm working with has allowed me to name 2 products after the brew that I'm using (PowTown Porter).  It makes for great interest in your soaps as well as your company.
> ...


 
Thanks for all that Lindy!  You have been very helpful... Good to know about the breweries, will be sure to check in with them.  

DeeAnna, your label is super cute!


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## Robert (Jul 28, 2013)

I keep thinking in this context about what Tony Os'eland (apostrophe may be in wrong place) would've had to do to label his bath foam by these regs.  He used Ivory Dishwashing Liquid as his base.  Would he have had to list it just like that as an ingredient?  Probably.  I doubt P&G would've told him the exact recipe so he could break it down by component.  Would he have been barred in using their trademark on the ingredient list?  If so, then saying "dishwashing liquid" on the label wouldn't serve the purpose of allowing a user to track down what was in it.  Would he have been required to take Ivory's MSDS and copy what was listed to his ingredients list?

At least there'd be no TM issue in the case of "mud from the creek behind the house".


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