# Labeling WSP "Premium" and "Signature" Soap Bases



## hmlove1218 (Apr 13, 2014)

Are these classified as a cosmetics?  Do they need to have the warnings about use and not being tested by the FDA even if you make no other claims than it just being soap?


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## lsg (Apr 13, 2014)

Well, that is a close one, but I think if they contain synthetic detergent, then they need to be labeled.  I  put a warning on each label as a safeguard whether it is required or not.


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## hmlove1218 (Apr 13, 2014)

Which warnings do you put?  Do you just put "Warning - The safety of this product has not been determined."  Or do you put others as well?


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## lsg (Apr 13, 2014)

Well here is a general warning example---- "Caution:  Please read the ingredient list before using. Do not ingest. If redness, itching or irritation occurs, discontinue use. Keep out of reach of small children and pets."  And on the bottom of the front label  "Warning:  The safety of this product has not been determined."


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## hmlove1218 (Apr 13, 2014)

Thank you!  I'll figure out something similar to that.  Do you know if that could be placed on the side of the package instead of the back?


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## lsg (Apr 13, 2014)

I think the side would be fine as long as it was noticeable.


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## hmlove1218 (Apr 13, 2014)

Alright. Thank you for your help!


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## Kansas Farm Girl (Apr 13, 2014)

According to the cosmetic labeling rules the 740.10 warning needs to be on the primary display panel defined as: 
…..A label may consist of more than one panel. It may consist of a front panel, side panels and a back panel. Back and side panels are generally called information panels.
  The FP&L Act also defines for consumer commodities, or packages containing a consumer commodity, the term "principal display panel," otherwise known for short as PDP… that part of a panel that is most likely to be shown or examined under customary conditions of display for retail sale. Usually, it is the front panel of the label of the outer package.
  The label”





  The warning is:
*21 CFR 740.10: *A cosmetic is considered misbranded if its safety has not adequately been substantiated, and it does not bear the following conspicuous statement on the PDP:
  Warning - The safety of this product has not been determined.
http://www.fda.gov/Cosmetics/Labeling/Regulations/ucm126444.htm#clgk

Are you sure that the WSP bases are not true soap based on the FDA definition?
http://www.fda.gov/cosmetics/guidanceregulation/lawsregulations/ucm074201.htm


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## lsg (Apr 14, 2014)

I thought the OP was referring to the caution statement and not the "Warning, the safety of this product has not been determined."  I always put this warning on the front label. As for your other comment, here is a quote from the link you posted. 


"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"
*This from Nature's Garden:* 
"Melt and pour soaps that contain detergent ingredients that enhance the quality, performance, or clarity of the soap are considered to be cosmetic products, and must follow the FDA’s guidelines for proper cosmetic labeling. These guidelines include labeling all ingredients in your melt and pour soap in descending order of prominence."
http://www.naturesgardencandles.com/mas_assets/pdf/meltsoap.pdf

Here is the ingredient list of WSP premium crystal soap base__Sorbitol, Propylene Glycol, Water, Sodium Stearate, Sodium Laureth Sulfate, Sodium Myristate, Sodium Cocoyl Isethionate, Glycerin.

http://www.wholesalesuppliesplus.com/ProductDetail.aspx?CatalogID=1&GroupID=1&CategoryID=2572&ProductID=2290&ProductName=Crafters+Choice%e2%84%a2+Signature+Crystal+Clear+Soap+Base+-+2+lb+Tray&Mode=INCI


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