# Listing Ingredients



## mnten (Mar 26, 2009)

How do you folks list the ingredients for your soap? I read somewhere that this one lady listed her ingredients as: saponified olive oil, palm oil, etc., and water, colorants, and fragrants.
Would this be ok?


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## Tabitha (Mar 26, 2009)

According to the FDA if you list the ingredients they need to be in INCA form.

Coconut oil would be: Cocos Nucifera Oil 

You may insrt the common name within the INCI name like this: Cocos Nucifera (Coconut) Oil 

You can find a good list of INCI names here: http://www.oshun.ca/inci.html 

We use INCI as an international language. That way anyone, anywhere, can pick up a product and have a better chance of knowing what they are getting than if it were in everyones native language.


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## Imblebee (Mar 26, 2009)

Oh! Tabitha, Thank you for the very handy link!


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## angbaby4974 (Mar 26, 2009)

The FDA does not require labeling soap.  And this is about all the info I could find on FLPA (Fair Labeling & Packaging Act).  Doesn't say anything about INCI form???  http://www.ftc.gov/os/statutes/fpla/outline.html
Not doubting you Tabitha, just wondering where you found that info????

A good article on labeling soap...
http://www.bellaonline.com/articles/art52891.asp


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## Vinca Leaf (Mar 26, 2009)

I've heard either was acceptable if it is labeled...


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## Tabitha (Mar 26, 2009)

The FDA does not require soap to be labeled, that is correct.

_IF_ you choose to label it, it must be done correct & if you list even 1 ingredient you must list them all. That means if you  write shea butter soap or soap w/ shea on your label, you have listed 1 ingredient & therefore must list them all, INCI, from largest to smallest qty. Any ingredients under 2% can be in mix match order.

The FDA guidlines are realy not black & white. If someone thinks otherwise & can show me a link I would appreciate seeing it. It is all a learning process & things do change over time as well.


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## Guest (Mar 26, 2009)

Burt's Bees lists their ingredients the regular way on their product labels.... coconut oil, sunflower oil, etc.


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## Tabitha (Mar 26, 2009)

I guess Burt can afford whatever the fine is... I see improper labels all over the place by many of the big boys. I don't know how or why they get away with it. Who is the big B&B retailer at Disneyland? I forget, but their bath bombs are in a big barrel w/ no labels what so ever.


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## Guest (Mar 26, 2009)

Seems strange that they'd be getting fined, and not care.... doesn't make good business sense.....


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## I love soap! (Mar 26, 2009)

Danielito said:
			
		

> Seems strange that they'd be getting fined, and not care.... doesn't make good business sense.....




True indeed!


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## angbaby4974 (Mar 26, 2009)

Tabitha said:
			
		

> The FDA does not require soap to be labeled, that is correct.
> 
> _IF_ you choose to label it, it must be done correct & if you list even 1 ingredient you must list them all. That means if you  write shea butter soap or soap w/ shea on your label, you have listed 1 ingredient & therefore must list them all, INCI, from largest to smallest qty. Any ingredients under 2% can be in mix match order.
> 
> The FDA guidlines are realy not black & white. If someone thinks otherwise & can show me a link I would appreciate seeing it. It is all a learning process & things do change over time as well.



Personally I like to see the ingredients on what I'm buying.  I was just wondering where you found the info about labeling with INCI names, cause I've searched high & low & probably overlooked it. :roll: 

I totally agree that there is a LOT of "grey" area where labeling soap is concerned.


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## Tabitha (Mar 26, 2009)

OK, I have been looking for about an hour & I think I will give up for tonight. I will leave you with a few links.

http://www.cfsan.fda.gov/~dms/cos-lab3.html#clgl
The above is cosmetic labeling. I am going to have to say most soap on the market should be labeled by cosmetic tandards which includes INCI, etc. If you make any claim EX) Moisturising soap, exfpliating soap, beaty soap, your soap just turned into a cosmetic. Below is how to determine if your soap is soap, a cosmetic or a drug. If you label your soap healing, or acne soap, than you just entered the realm of drug labeling. See link below.

http://www.cfsan.fda.gov/~dms/cos-218.html 
Is It a Cosmetic, a Drug, or Both? 
(or Is It Soap?) 

It may also be hidden in fair packaging and labeling act here: http://www.cfsan.fda.gov/~dms/cos-218.html  be sure & check the  links at the top of this source, 500, 5001, 5002, 5003

My eyes are about to cross.

My day tomorrow is full but I will put more time into it this weekend.


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## Guest (Mar 26, 2009)

Personally, I'd rather see "coconut oil, shea butter...." etc... rather than "Cocos Nucifera (Coconut) Oil, Butyrospermum Parkii (Shea Butter) Fruit"..... reading the scientific names is just more cumbersome.  I think if the vast majority/100% of your clientele is English speaking, it's best to list ingredients the simpler way.


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## cdwinsby (Mar 26, 2009)

Here is a quote from Health Canadas website. Not sure were in the US you would look for this info but as far as Canada says, all cosmetics in Canada, the US and the European Nation are required to list their ingredients using the INCI system.

"INCI stands for the International Nomenclature for Cosmetic Ingredients. It is a system for naming cosmetic ingredients that is multilingual, multinational and based on Latin. The INCI labelling system was designed in 1973 and developed over a period of more than 30 years. It was created by the American Cosmetic, Toiletry and Fragrance Association's International Nomenclature Committee and the INCI system forms the basis of the International Cosmetic Ingredient (ICI) Dictionary and Handbook (currently in its tenth edition). The Dictionary and Handbook presents, in detail, the bulk of INCI names juxtaposed with their corresponding empirical chemical formulas, technical/trade names, Chemical Abstracts System numbers (CAS No.), or alternate numbers. This allows for the unambiguous identification of ingredients Health Canada, along with other government and industry representatives, is a participant of the International Nomenclature Committee, which determines the INCI name assigned to each cosmetic ingredient. *INCI is the mandatory nomenclature in the United States, the European Union, and now Canada*."

Here's the link:

http://www.hc-sc.gc.ca/cps-spc/pubs/ind ... ts-eng.php

Though many of us would prefer to have a simpler list of ingredients, it's no longer practical with the importation of goods from around the world. 

Is soap even classified as a cosmetic in the US?


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## angbaby4974 (Mar 27, 2009)

Basically if you don't make ANY claims (moisturizing, acne, etc.) soap is soap.

If you do, then it's cosmetic & possibly a drug.   :shock: 
Anywho...I found this letter on the FDA/CFSCAN 
http://www.cfsan.fda.gov/~dms/cosltr03.html
Apparently the common name is what they are requiring on the label.  (Unless I am reading it wrong)  I read almost everything I could find, & found nothing that states that you must use INCI names, but I did find a LOT that says use the common name.

Here's more tiny print reading for ya if you're interested.

http://ecfr.gpoaccess.gov/cgi/t/text/te ... 2.11.1.1.3

I wish the answer was more deliberate & easier to find than it is. :roll:

Edit:
I was researching & trying to post at the same time.  
I know that in Canada it says it's mandatory in the US, but in the US I can't find anything that states it's mandatory


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## Guest (Mar 27, 2009)

cdwinsby said:
			
		

> Is soap even classified as a cosmetic in the US?



I believe it depends on how your market it.  For example, if you list it as being moisturizing, cleansing, etc, it is considered a cosmetic.  Any indication that it is to be rubbed or massaged into the skin for a specific purpose puts it in the cosmetic category..... I am over-simplifying FDA's definition of a cosmetic but that's the jist of it.


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## Tabitha (Mar 27, 2009)

And what if it's "soap"?
Soap is a category that needs special explanation. That's because the regulatory definition of "soap" is different from the way in which people commonly use the word. Products that meet the definition of "soap" are exempt from the provisions of the FD&C Act because -- even though Section 201(i)(1) of the act includes "articles...for cleansing" in the definition of a cosmetic -- Section 201(i)(2) excludes soap from the definition of a cosmetic.

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]. 
If a cleanser does not meet all of these criteria...
If a product intended to cleanse the human body does not meet all the criteria for soap, as listed above, it is either a cosmetic or a drug. For example:

If a product -- 

consists of detergents or 
primarily of alkali salts of fatty acids and 
is intended not only for cleansing but also for other cosmetic uses, such as beautifying or moisturizing, 
it is regulated as a cosmetic.

If a product --

consists of detergents or 
primarily of alkali salts of fatty acids and 
is intended not only for cleansing but also to cure, treat, or prevent disease or to affect the structure or any function of the human body, 
it is regulated as a drug.

If a product --

is intended solely for cleansing the human body and 
has the characteristics consumers generally associate with soap, 
does not consist primarily of alkali salts of fatty acids, 
it may be identified in labeling as soap, but it is regulated as a cosmetic.

The above quote is from here:
http://www.cfsan.fda.gov/~dms/cos-218.html 
Is It a Cosmetic, a Drug, or Both? 
(or Is It Soap?)


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## Guest (Mar 27, 2009)

So that's why Burt's Bees is able to list their ingredients the simple way -- they don't make any cosmetic claims on their products.

Their lip balm just says "Soothing, cooling, refreshing"... no mention of moisturizing or healing abilities.

I've seen some soapmakers describe the potential benefits of their soap without actually making any claims.  For example:  "Contains tea tree oil, which is _reputed_ to have antibacterial properties".... etc.


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## cdwinsby (Mar 27, 2009)

Danielito said:
			
		

> "Contains tea tree oil, which is _reputed_ to have antibacterial properties".... etc.



From what I understand, even statements like that will put the soap into the cosmetic or drug catagory. It _implies_ that the soap may do something more than just wash. I'm not 100% positive on that though.

I think if you want to go with the simple terms and avoid the INCI terms you need to avoid saying anything other than that the soap will clean.

Here in Canada we don't have that problem... :roll: ....we *have* to use INCI terms since soap is catagorized as a cosmetic. We still have to worry about saying things that will put the soap into the drug catagory though.


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## Guest (Mar 27, 2009)

cdwinsby said:
			
		

> From what I understand, even statements like that will put the soap into the cosmetic or drug catagory. It _implies_ that the soap may do something more than just wash. I'm not 100% positive on that though.



The info Tabitha posted states that the soap is considered a cosmetic/drug if it is "intended" to moisturize/heal/etc.  [/b]


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## cdwinsby (Mar 27, 2009)

Here's another quote from the same link Tabitha posted:

"How is a product's intended use established?

Intended use may be established in a number of ways. Among them are:

Claims stated on the product labeling, in advertising, on the Internet, or in other promotional materials. Certain claims may cause a product to be considered a drug, even if the product is marketed as if it were a cosmetic. Such claims establish the product as a drug because the intended use is to treat or prevent disease or otherwise affect the structure or functions of the human body. Some examples are claims that products will restore hair growth, reduce cellulite, treat varicose veins, or revitalize cells. 

_*Consumer perception, which may be established through the product's reputation. This means asking why the consumer is buying it and what the consumer expects it to do. 

Ingredients that may cause a product to be considered a drug because they have a well known (to the public and industry) therapeutic use. An example is fluoride in toothpaste.* _

This principle also holds true for essential oils in fragrance products. A fragrance marketed for promoting attractiveness is a cosmetic. But a fragrance marketed with certain "aromatherapy" claims, such as assertions that the scent will help the consumer sleep or quit smoking, meets the definition of a drug because of its intended use. "

Not sure how the "antibacterial" example works though....to me this says it will kill bacteria which I consider to be a part of cleaning and washing.

I think it would apply more to a statement like "Contains tea tree oil, which is reputed to be effective at killing acne bacteria".... etc. 

It gets tricky, since the more well known an ingredient like tea tree oil becomes, the more the public expects it to do a particular thing. And that might end up putting the soap into the drug catagory due to 'consumer perception'.

Sucks.


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## Guest (Mar 27, 2009)

Ah, true.  I wonder if putting the disclaimer of "This product is not intended to cure, treat or diagnose any disease" is a way out of that.

It's a silly semantics game.


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## Tabitha (Mar 27, 2009)

The statement about making claims is only for soap. Lipbalm, etc is already in the cosmetic realm even w/o a claim.


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## Guest (Mar 27, 2009)

So.. Tabitha... do you think you're asking for trouble if you include the "folklore" about certain ingredients in the soap?  (Tea tree oil is known to be antibacterial...etc) ... Without actually making direct claims?


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## Tabitha (Mar 27, 2009)

I "think" it is safe to sidestep claims. I have used comments like "for hundreds of years people have used X to help them with X, now you can too (or whatever). I "think" that is safe. I do believe that makes your item a cosmetic though. But that's just me. It's not black & white. I have even phoned the FDA looking for specific answers and been told to read & make my interpetation & that I would be safe with that untill challeneged & then a descision would be made. That is prettty much what the copywrite office told me as well.


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## I love soap! (Mar 27, 2009)

It's crazy. Unless your a chemistry teacher most likely you don't want to list scientific names


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