# NaOH on soap label?



## math ace (Nov 7, 2020)

Can I list " NaOH " on my soap label instead of "sodium hydroxide" to save space?


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## DeeAnna (Nov 7, 2020)

If you're wanting to do a proper ingredients list per FDA rules for cosmetic products, you should use the correct chemical name written out, not its abbreviation. Quite a few people will not have the chemistry background to know Na = sodium and OH = hydroxide. 

The even more generic word "lye" is certainly short and space saving, but even less helpful. Few people will know what that means either, even those with a chemistry background.


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## shunt2011 (Nov 7, 2020)

I list sodium hydroxide on my labels.


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## DawninWA (Nov 8, 2020)

I use lye.  It's what my customers react best to. .  "Oh, good, it's lye soap! That's the best kind!" 

I pretty much only sell a one small farmers market.


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## MegaSoap (Nov 8, 2020)

I list as sodium hydroxide.


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## math ace (Nov 8, 2020)

Do I remember correctly,  if it is just "soap that cleans" , we don't technically have to list ingredients?   We have to list ingredients for a cosmetic product,  but not for soap that just cleans?

However, to prove it is just soap,  it needs to be mostly oil without added detergents.  So,  then wouldn't we have to list the ingredients to prove that it is just soap?  I am clearly a little confused about this LOL!


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## DeeAnna (Nov 8, 2020)

math ace said:


> Do I remember correctly,  if it is just "soap that cleans" , we don't technically have to list ingredients?   We have to list ingredients for a cosmetic product,  but not for soap that just cleans?



Yes, technically (in the US), if it's just soap-that-gets-you-clean, you don't have to list the ingredients.

_"...However, to prove it is just soap,  it needs to be mostly oil without added detergents.  So,  then wouldn't we have to list the ingredients to prove that it is just soap?  I am clearly a little confused about this LOL!..."_

Well, okay, think about it -- how does the presence of an ingredients list PROVE the soap is just soap? There is no system (in the US) to ensure an ingredients list is correct. And even in the EU and other places that are more rigidly controlled, I'd say it's a safe bet that people don't always strictly adhere to the exact formula they paid to get approved. 

At some point, the honor system comes into play.

Is an honorable soap maker who makes legitimate soap-that-gets-you-clean but doesn't do an ingredients list somehow worse than a maker who writes a misleading ingredients list?


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## math ace (Nov 9, 2020)

@DeeAnna 

I get what you are saying.  I want to do the right thing and list the ingredients.  If I want the ingredients to fit, I'll either have to reduce the font size, which is counterproductive to helping the consumer make an informed purchase OR I'll have to use NAOH for sodium hydroxide.  

Since, don't have to list the ingredients, then it can't be against the law to use NAOH.  

Thanks for helping me think this through .


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## GemstonePony (Nov 9, 2020)

math ace said:


> @DeeAnna
> 
> I get what you are saying.  I want to do the right thing and list the ingredients.  If I want the ingredients to fit, I'll either have to reduce the font size, which is counterproductive to helping the consumer make an informed purchase OR I'll have to use NAOH for sodium hydroxide.
> 
> ...


Make sure it's at least NaOH, not NAOH. NAOH is not an molecular compound, since "A" is not a symbol for any of the elements.


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## DeeAnna (Nov 10, 2020)

_"...Since, don't have to list the ingredients, then it can't be against the law to use NAOH...."_

No it's not "against the law" and I never said or even implied it was.

It's your soap and your ingredients list. If you want to find some middle ground between nothing at all and the FDA cosmetics rules, it's your call.


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## TheGecko (Nov 10, 2020)

math ace said:


> Since, don't have to list the ingredients, then it can't be against the law to use NAOH.



While you are correct that there are no labeling requirements for True Soap insofar as you are required to have an ingredient label on your soap, you are NOT correct that you can just do whatever you want when it comes to labeling because of it. There are rules/laws/standards when it comes to labeling and you ARE required to follow those rules. When it comes to my soap recipe ingredients, I follow said rules/laws/standards:

_Ingredients:  Olive Oil, Distilled Water, Coconut Oil, Palm Oil (RSPO), Sodium Hydroxide, Coconut Butter, Shea Butter, Castor Oil, Sodium Lactate and Kaolin Clay._

This is exactly what goes into every bar of Regular Soap that I make descending order of predominance (weight).  Now I do _slightly_ bend the rules when it comes to scent and colorants with the last line:  _May contain fragrance oils and/or colorants._  It's a bit of stating the obvious, but I didn't want to have to have a gazillion different labels just because of a different FO or mixing different Micas together to produce a certain color.  But with that said, for anything other than True Soap, I do list _Fragrance Oil_ and follow Cosmetic Rules for my colorants.


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## DeeAnna (Nov 10, 2020)

@TheGecko -- You're doing an ingredients list per FDA cosmetic rules. That's fine.

The OP doesn't want to do that. That is fine too since we're talking about soap-that-just-gets-you-clean.

I personally prefer your approach and that's how I create my ingredients lists too, but my understanding is an ingredients list like this is NOT a LEGAL requirement in the US for soap-that-just-gets-you-clean.

If you disagree and feel it IS a legal requirement, please provide a link to the pertinent FDA rules or an article by Marie Gale or other reputable authority. I need to see the basis behind your thinking about ingredients lists for soap-that-just-gets-you-clean. I apparently need a refresher.


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## TheGecko (Nov 10, 2020)

DeeAnna said:


> If you disagree and feel it IS a legal requirement, please provide a link to the pertinent FDA rules or an article by Marie Gale or other reputable authority. I need to see the basis behind your thinking about ingredients lists for soap-that-just-gets-you-clean. I apparently need a refresher.



Apparently you do.

I NEVER said that labeling True Soap was a legal requirement: _While you are correct that there are no labeling requirements for True Soap insofar as you are required to have an ingredient label on your soap...._

What I said was:_  ...you are NOT correct that you can just do whatever you want when it comes to labeling because of it. There are rules/laws/standards when it comes to labeling and you ARE required to follow those rules.  _

Now using _rules/laws/standards_ is meant to be inclusive, not exclusive because I do not presume to know what every state's laws are regarding labeling.  But the _rules/standards_ are as follows:

*In what order should ingredients be listed?*
Ingredients should be listed in descending order of predominance (based on their percentage, by weight, in the product).

Blended ingredients used in the product (such as pre-made bases or preservatives) must have their component ingredients listed in the ingredient declaration based on the percentage of use in the entire formula.

There are a few exceptions:

Fragrances may be listed as “fragrance” without identifying all the component ingredients in the fragrance blend.
Ingredients that are present at less than 1% may be listed _in any order_ after the ingredients present at 1% or greater.
Color additives (which must be on the FDA list of approved color additives), may be listed after all other ingredients (regardless of the percentage at which they are used).
Incidental ingredients, “trade secrets,” and alternative ingredients have special methods of being listed (or not) in the ingredient declaration.  See the FDA website, the labeling regulations or the book _Soap and Cosmetic Labeling_ for details.









						Quick Labeling FAQ
					

Here are some of the basics of labeling and the questions that frequently come up about the basic labeling. What goes on the FRONT panel? Name. Your unique product name; the name that separates your lavender soap from someone else’s lavender soap. Identity.  What is the product? (soap, lotion...




					www.mariegale.com


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## DeeAnna (Nov 10, 2020)

The specific topic of this thread is whether sodium hydroxide can be called NaOH on the OP's ingredients list for soap-that-just-gets-you-clean. Marie Gale answers this specific question in the link you provided --

"..._If it is a “true soap” (made from oil and lye), AND the only claim is that it cleanses AND it is only called “soap,” it is exempted from the FDA cosmetic regulations (but not the basic consumer commodity labeling requirements). _​​_"If it is exempted from the FDA cosmetic labeling regulations, an ingredient listing is not required.  That doesn’t mean you can’t put an ingredient listing on the package, but it is not required, and isn’t regulated by the FDA rules for cosmetic ingredient declarations_...." (underlined emphasis is mine)​
Later in this same article, Marie provides a link to a second related article where she gives more insight --

"..._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_...." (again, the underlined emphasis is mine)​
These statements are a definitive answer to the OPs question about whether NaOH can be used instead of sodium hydroxide for the ingredients list for soap-that-just-gets-you-clean.

The answer is, yes, the OP can indeed use NaOH rather than sodium hydroxide. And furthermore, the OP can list the ingredients in whatever order or whatever way seems appropriate.

***

_"...Apparently you do...."_

@TheGecko -- I really dislike being addressed like this, and I dislike seeing other people being treated likewise. You have useful insights and information to share, but you are delivering your thoughts in an authoritarian tone that brooks no objections and discourages further discussion. Can you find a lighter tone, please?


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## TheGecko (Nov 10, 2020)

DeeAnna said:


> I really dislike being addressed like this, and I dislike seeing other people being treated likewise. You have useful insights and information to share, but you are delivering your thoughts in an authoritarian tone that brooks no objections and discourages further discussion. Can you find a lighter tone, please?



Perhaps you should practice what you preach DeeAnna. You're being awfully snarky when all I did was agree that you needed a refresher course. It has ALREADY been established several times now that there is NO LEGAL REQUIREMENT for an ingredient label for True Soap. The horse is dead...quit beating on it.

As for the rest...you might want to check yourself because you responded to the same thing I did so the whole "the specific topic of this thread is...." is a bunch of horse feathers or the pot calling the kettle black.

If you need additional information regarding labeling rules/standards, I'll be more than happy to help you out.  You have a great day.


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## amd (Nov 10, 2020)

I'm going to throw this out there for anyone who uses SM3 to create their ingredient list, as I do, that their export function specifies as "lye (NaOH)". This annoys me to no end as I either have to change it after copy+paste into my label or choose to be lazy and leave it. Ahem, the latter is what I do... but after reading through this thread I think I should stop the laziness.

@TheGecko play nice. You were carefully and thoughtfully critiqued, and your response is childish.


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## lsg (Nov 10, 2020)

Locking thread.


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