# Aren't All Fragranced Soaps Cosmetics?



## ErinO (Oct 14, 2018)

I'm very new, I have yet to make a single bar of soap for my own use that I thought was really great. But I'm wandering through the forums and learning. 
It seems to me that by FDA regs, any soap with a fragrance would be intended to fragrance/deodorize the body -- a cosmetic claim. Is anyone selling plain, unscented soap? Who would ever buy it? Is it generally about what you say/imply it is for?


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## Obsidian (Oct 14, 2018)

Soap isn't intended to scent the body, its intended to wash, thats all. A scented soap doesn't generally leave a scent on the skin after rinsing, if it does its faint and only for a short period.
Scent is just their to make the washing experience more pleasant. I only sell small quantities to friends and family but my most requested soap is my unscented. The people buying it have allergies or sensitivities.


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## penelopejane (Oct 14, 2018)

In Australia whether a soap is scented or not it still comes under the NICNAS regulations as a cosmetic that required a chemical reaction to make it.  Only M&P soap doesn’t require regulation.

My most popular soap is unscented.  As obsidian said most use it because they have allergies or sensitivities.  It’s difficult to get unscented soap with no additives commercially.


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## Lin19687 (Oct 16, 2018)

Obsidian said:


> Soap isn't intended to scent the body, its intended to wash, thats all. A scented soap doesn't generally leave a scent on the skin after rinsing, if it does its faint and only for a short period.
> Scent is just their to make the washing experience more pleasant.



Exactly.  I have found that anyone selling a soap that says it scents your skin is likely to be using TOO much FO and that can be dangerous thing.


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## shunt2011 (Oct 16, 2018)

I only have a few scents that actually leave a scent behind and they are manly scents.  Everything is very mild or none at all.   I generally scent at 6% except my men's fragrances as they are much stronger and overpowering.


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## Lin19687 (Oct 16, 2018)

But I am sure they only last for say 30 min max ?

Only a few of mine leave a scent behind and you have to bite your nose into the skin to smell it.  And even that only lasts about 20-30 MAX .  I always laugh when I shove my nose on my arm...


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## shunt2011 (Oct 16, 2018)

Nope, my Perfect Man and Cracklin Birch stick round for quite some time.  It's not over powering but it's there for several hours.


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## amd (Oct 16, 2018)

I think it depends on your skin as well. My husband and I can use the same soap, and no scent sticks to my skin, but he still has the scent on his skin the next morning (we shower at night). Even my lightest scented soaps stick to him. My daughter and I just smell like soap, hahaha.


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## jcandleattic (Oct 16, 2018)

amd said:


> I think it depends on your skin as well. My husband and I can use the same soap, and no scent sticks to my skin, but he still has the scent on his skin the next morning (we shower at night). Even my lightest scented soaps stick to him. My daughter and I just smell like soap, hahaha.


Agreed, my sister and I are the same - scent sticks to her, not to me. 

But I never make that claim (even though I always label my soaps) - my soaps are for the sole purpose of cleansing the body in either a shower, tub, or sink.


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## amd (Oct 16, 2018)

^^^Agreed. The fragrance is the incentive to buy what cleans the body. Works the same way when people ask if I have soaps made for dry skin. Nope, I make soap for dirty skin.


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## shunt2011 (Oct 16, 2018)

My soaps as well.  No claims, just soap to get you clean!


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## cmzaha (Oct 16, 2018)

Unscented soap is my worst seller of all. It can take up to a year to sell a 14 bar batch of unscented. My customer base like scent and some do say the stronger one's like DB stick on the skin for awhile. I do not have any that stick on my skin for more than 15 min


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## amd (Oct 16, 2018)

cmzaha said:


> Unscented soap is my worst seller of all. It can take up to a year to sell a 14 bar batch of unscented.



Agreed. Made an 18 bar batch in January 2017, I have 2 bars left. I made a 9 bar castile that was fully cured in January, I've sold 1 bar of that. I now have soapers regret because I put 18 bars of castile on the cure in January. All are unscented. I didn't trust a fragrance to last through a full year cure, maybe I should have taken a chance. I am not looking forward to hauling around those soaps.


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## shunt2011 (Oct 16, 2018)

Me too. I made 16 bars in January and still have 13.  People like good smelling soap.


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## dndlyon (Oct 16, 2018)

ErinO said:


> I'm very new, I have yet to make a single bar of soap for my own use that I thought was really great. But I'm wandering through the forums and learning.
> It seems to me that by FDA regs, any soap with a fragrance would be intended to fragrance/deodorize the body -- a cosmetic claim. Is anyone selling plain, unscented soap? Who would ever buy it? Is it generally about what you say/imply it is for?



Let's take the same bar with fragrance, but with a different label. Bar A says "Soap" and Bar B says "Deodorant Soap" then you may have just bumped the bar into the cosmetic category - depending on what country you live in. A lot of the regulations in the US line up with the intent that the label communicates to the consumer - Is it clearly labeled as just a soap, or does the label imply a cosmetic use as well (moisturizing, deodorizing, etc.).

I also make unscented soap, and have the same experience as the others. Lots of people I know are looking for something without all the additives in a commercial bar of soap, and fragrances and colors (even essential oils and "natural" colors) can be irritating to sensitive skin.


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## Lin19687 (Oct 17, 2018)

I have had 3 people ask for unscented soap... they also wanted it to be moisturizing.... Nope, it is soap and I DO NOT make unscented.
What is the point ?  You can buy that anywhere.  I make scented because you can't get those scents at the grocery store 
Shoot, I still have a few scents that  didn't sell from May !  Will be using them up in blends


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## shunt2011 (Oct 17, 2018)

I make 1 batch a year/2 years. I do have one customer that has problems with fragrances of any kind.  She buys a couple bars at one of my annual festivals.  Otherwise they just hang around.


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## amd (Oct 17, 2018)

Once my unscented soaps are gone, I'm only going to offer it as a custom order. For the few sales I get for it every year, it's not worth hauling around and relabeling after a year of being handled.


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## Primrose (Nov 12, 2018)

Lin19687 said:


> I have had 3 people ask for unscented soap... they also wanted it to be moisturizing.... Nope, it is soap and I DO NOT make unscented.
> What is the point ?  You can buy that anywhere.  I make scented because you can't get those scents at the grocery store
> Shoot, I still have a few scents that  didn't sell from May !  Will be using them up in blends



What is the point? Some people can't use fragrances. Some just like unscented soap. 

I love a plain bar of goat milk soap. My absolute favorite. 

I definitely can't buy it anywhere. Can't get it in the shops anyway.


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## Lin19687 (Nov 12, 2018)

Agreed that 'Some' people can't use scents.  Those people usually do not come to smell the soaps.
I don't remember where you are since it isn't in your avator. But you can buy unscented soaps in stores, maybe not Goats milk.  You might even have to work extra hard to get those types of customers in, not talking about friends.  Because they don't usually like all the scent that surrounds you when you get close.
As others said, when you sell, you don't want to haul around soap that doesn't sell well nor have it sit around a year.

I even have a couple scents that sold ok, but not well enough for me to keep making it.
Come February I will be going over what sold this year.  Great sellers, Ok sellers, NON-sellers and they will be discounted and not made again.


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## shunt2011 (Nov 12, 2018)

As I've stated before.  I make unscented/uncolored soap and make a unscented colored soap every year or two.  They usually contain GM.  I don't sell a lot but I have them if someone wants them.  It also amazes me how many people pick up the unscented (Naked) soap to smell it.

I evaluate my sales every year and fragrances that don't sell I discontinue.  Except unscented.  I keep it for those that like handmade soap but no fragrance.


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## DeeAnna (Nov 12, 2018)

At least in the US, the intended purpose of the soap is as important as the fact that the soap is soap. In other words, are you labeling the soap as a way to fragrance or otherwise enhance the body or are you labeling the soap as soap that cleanses the body and also happens to have pretty colors and a nice scent? Per the US FDA from 2014:

"...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...." [emphasis mine]

I mean if you look at the literature, the use of soap also reduces the bacterial population of the skin, so it could be considered a drug if you wanted to take that view. But unless the soap is _labeled _as an antibacterial product, the soap is just soap.

edit: Another example is the pine tar soap I make. I do not claim, verbally or otherwise, that it will cure your psoriasis or whatever. (A drug claim) I never claim it changes or reduces your body odor, which the main reason why some of my DH's hunting buddies scrounge bars off him. (A cosmetic claim.) My claim about this soap is simple -- it's soap and it gets you clean. It happens to have pine tar in it to give the soap a smoky campfire scent, but the scent is incidental to the purpose of the soap. If someone thinks pine tar soap might have other benefits, that is up to them to decide.


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## earlene (Nov 12, 2018)

Strange as it may seem, to me all unscented soap has a scent, but they don't all smell the same, either.  I know the general discussion here is probably thinking about people with sensitivities or allergies to certain ingredients in fragrance oils or essential oils, but there are instances where the smell of some plain soaps with no added scent may be an issue as well.  (For example, take a neem oil soap to which no fragrance is added.  Or DeeAnna's pine tar soap example.  And the oft-discussed lard soaps.  Or in some cases pure olive oil soaps - some people can't stand the smell of olive oil soap.)

I think that for the person who is sensitive to odors (not necessarily FO's themselves) even plain unscented soaps might smell as if it is scented.  Last year I gave some unscented soap to a lady who insisted that it had lavender fragrance added, when I knew it positively did not and had never even been stored near a lavender fragranced soap ever.  But of course, I also have a family member who says, 'I don't do unscented' who won't even look at, touch or sniff a soap that I say it is unscented.  

But to the original question, 'aren't all fragranced soaps considered cosmetics?'  I wonder where the question is coming from.  In re-reading the question, I suppose the OP is referring to 'intent' of the soapmaker.  I suppose if the soapmaker's *intent* is to fragrance the body, then yes, I suppose it would be, but only if so labeled.  But I don't think that is the intent of most experienced soapmakers because we know it is a rare soap that actually leaves a long-lasting fragrance on the skin.  And even then, when it does happen, it doesn't happen to everyone, as mentioned in another thread, where the fragrance in the same soap left scent on the husband's skin, but not on the wife's (I'd link it, but can't find it now) and/or not everyone has a sensitive enough nose to smell it lingering on the skin.  (Often my husband who smoked for decades can't smell things I can smell.  Is my nose more sensitive because I am not a long-term smoker?  Or is it just the way my nose is regardless?  I don't really know, but I do know smoking does interfere with the sense of smell as do some drugs and other factors can as well.)

So, No, soap is not a cosmetic by the US FDA's standards simply based on added fragrance.  Published claims about the soap is more to the point when the FDA determines how it should be categorized.  Although there are cases where consumer perception might be included in the FDA's determination of whether a particular soap is considered a cosmetic (or a drug).  https://www.fda.gov/cosmetics/guidanceregulation/lawsregulations/ucm074201.htm


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## Primrose (Nov 12, 2018)

Lin19687 said:


> Agreed that 'Some' people can't use scents.  Those people usually do not come to smell the soaps.
> I don't remember where you are since it isn't in your avator. But you can buy unscented soaps in stores, maybe not Goats milk.  You might even have to work extra hard to get those types of customers in, not talking about friends.  Because they don't usually like all the scent that surrounds you when you get close.
> As others said, when you sell, you don't want to haul around soap that doesn't sell well nor have it sit around a year.
> 
> ...



Not arguing that should make soap that doesn't sell for you, that's clearly not a good business choice

But you asked what was the point in making it. 

I am in Australia. But even if you can buy unscented soap in your location at the shops - then it's commercial soap which we all know is different to a nice handmade soap.


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## Alfa_Lazcares (Nov 12, 2018)

Primrose said:


> Not arguing that should make soap that doesn't sell for you, that's clearly not a good business choice
> 
> But you asked what was the point in making it.
> 
> I am in Australia. But even if you can buy unscented soap in your location at the shops - then it's commercial soap which we all know is different to a nice handmade soap.



Yeah, i am In Mexico, and i have never seen comercial soap with no fragrance. True i never made it a point to look for it, but its not like you can get in to wallmart and buy one. I prefer scented soaps, because i dont like fhe smell of the oils once they become soap, but i do not want a soap that leaves my skin smelling like the fo for hours cause i use perfume for that!


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## Primrose (Nov 12, 2018)

It depends too on the oils used in an unscented soap. I can tell the difference between my three unscented recipes by their different smell, but I don't mind them at all. I know other people don't like the unscented smell of lard, others don't like the unscented olive oil.


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## cmzaha (Nov 13, 2018)

I always have a batch of uncented uncolored soaps. They may not sell well but they just get better and better, so when someone buys one I explain the primo soap they are getting. We only take four to six bars of the unscented, so it is no big deal to add them in with the 2-3 hundred soaps we haul to markets.


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## JanelleTrebuna (Nov 13, 2018)

Obsidian said:


> Soap isn't intended to scent the body, its intended to wash, thats all. A scented soap doesn't generally leave a scent on the skin after rinsing, if it does its faint and only for a short period.
> Scent is just their to make the washing experience more pleasant. .



I'm so glad to read this.  I was afraid I was doing something wrong.  My soaps smell great while curing and when I sniff the bars, but the scents don't stay on my skin after the shower is over.

Janelle


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