# Warning on "cosmetic" soap lables question...



## RocknRoll (Jan 26, 2013)

I've been working on my lables. I want to be in full compliance with the laws requiring wordage and stuff like that. I have reviewed the regulations for cosmetic labeling but I'm still not sure if I really NEED to include a warning. 

I'm also unclear if I need to add a "direstions for use" statement. If I need to in fact add these statements then I will need to have an entire back panel to draft in order to accomodate all the wordage.

So my question is, does anyone else add these things onto their lables (if selling retail)?  If anyone can shed some definate light I would be forever grateful!


----------



## 2lilboots (Jan 26, 2013)

http://candleandsoap.about.com/od/soapglossary/a/soaplabeling.htm


----------



## 2lilboots (Jan 26, 2013)

You are just selling "soap" right?  If you are just selling soap then you don't need the warning.


----------



## RocknRoll (Jan 26, 2013)

2lilboots said:


> You are just selling "soap" right?  If you are just selling soap then you don't need the warning.


Well yes but if I say its moisturizing then its considered a cosmetic and all new rules are set. I add luxury oils specifically for their moisturizing properties so I would hate to NOT be able to say it moisturizes!


----------



## 2lilboots (Jan 26, 2013)

Okay understood.  Perhaps you can google to get the info you need for labeling your soaps the way you need to.  I was stumped when Genny posted that soaps had to have the weight in ounces and grams.


----------



## RocknRoll (Jan 26, 2013)

2lilboots said:


> http://candleandsoap.about.com/od/soapglossary/a/soaplabeling.htm


 thanks! Im gonna go brows this


----------



## paillo (Jan 26, 2013)

I'm no expert here and would love to hear from others with more experience/research, but I think your labels must be much more strict than the descriptions you might put on your website or in placards in front of your soap displays at a festival. In the latter you can (I think, and I do) go into more detail on the avowed benefits of various butters, oils, clays, etc. etc. -- all such things you could not, of course, have room for or be allowed to, put on your soap label. I wouldn't put 'moisturizing' on my actual soap label, but I  would in a more lengthy description elsewhere.

Am I incorrect in assuming this is OK? I see the practice everywhere online, in brochures, at festivals, markets, etc, and I practice it myself.


----------



## Soapsense (Jan 26, 2013)

I came across this book http://candleandsoap.about.com/od/bookproductreviews/gr/labelinggale.htm

When reading that article, I don't know if it will help.
I thought the aritcle was interesting that it listed the word exfoliating as making it 
a cosmetic.  I work at a Hotel, and we use a brand of soap that is used in alot of big name hotels because it is a greeen product.  The brand is Green Natura, it says on the front of the box "Waste reducing exfoliating body cleanser"  50g, the back has a statement about the "waste reducing, green packing" Not a single ingredient is listed.


----------



## paillo (Jan 26, 2013)

Oh how I hate that! Consumers have to be able to protect themselves by reading ingredients that they might be allergic to. I WON'T use anything that doesn't have a full ingredient listing, no matter how green(washed), organic, all-natural it claims to be! On Etsy I see SO many products that claim to be all-natural while the ingredient list includes FOs (all of which are synthetic), or no ingredients listed at all. Bleah!


----------



## RocknRoll (Jan 26, 2013)

It's so complicated! Maybe I should just leave off that its moisturizing. Now I'm even wondering if I can use the wordage "detoxifying facial soap with activated charcoal" without it being touted as a "drug" and all new restrictions. I want to be able to "brag" so to speak about  at least a couple of the benefits of my soap (moisturizing, natural) but i'm wondering if the hassel is worth it. 

It's called "misbranded" if the lable isnt strictly to "code" but I see misbrands even on the lip balb packaging I bought at a farmers market. Say i did accidently "misbrand" my product (for instance puting the net weight on the back lable instead of the front) I wonder what the reprocussions would be, I mean are there really "soap lable police" out there? LoL! I just want to be within compliance but its frustrating. Thanks for the imput.


----------



## RocknRoll (Jan 26, 2013)

paillo said:


> Oh how I hate that! Consumers have to be able to protect themselves by reading ingredients that they might be allergic to. I WON'T use anything that doesn't have a full ingredient listing, no matter how green(washed), organic, all-natural it claims to be! On Etsy I see SO many products that claim to be all-natural while the ingredient list includes FOs (all of which are synthetic), or no ingredients listed at all. Bleah!


Ya, and thats another thing, am I required to put alergy warnings too? For instance shea butter is derived from a nut isnt it? :crazy:


----------



## Genny (Jan 26, 2013)

Rock&Royalty said:


> Ya, and thats another thing, am I required to put alergy warnings too? For instance shea butter is derived from a nut isnt it? :crazy:



If you're in the U.S. you do not need to put allergy warnings on your labels.  Ingredients are fine.


----------



## paillo (Jan 26, 2013)

Well, I wouldn't call myself a 'soap police' but I do occasionally contact sellers that particularly annoy me with false advertising about all-natural ingredients when they blatantly list synthetic ingredients. And I have on more than one occasion filed a complaint with the FDA about particularly egregious false advertising (the recently discussed popular soap sold at many Mennonite outlets being the latest).  Seriously, I do hope there are at least the occasional 'soap police' perusing online listings and looking at farmers markets and festivals. Most such agencies are so short-staffed and under-funded that I doubt they can spend much time at this, sadly.

And my latest pet peeve? The new Dove commercials that put down soap. Grrrrrrrrrrrr......


----------



## green soap (Jan 26, 2013)

Rock&Royalty said:


> I've been working on my lables. I want to be in full compliance with the laws requiring wordage and stuff like that. I have reviewed the regulations for cosmetic labeling but I'm still not sure if I really NEED to include a warning.
> 
> I'm also unclear if I need to add a "direstions for use" statement. If I need to in fact add these statements then I will need to have an entire back panel to draft in order to accomodate all the wordage.
> 
> So my question is, does anyone else add these things onto their lables (if selling retail)?  If anyone can shed some definate light I would be forever grateful!



If what you are selling is 'just soap' it does not fall under FDA jurisdiction.  All you NEED to list is:

that it is soap
the weight
who makes it

The ingredient list is optional in 'just soap' but a much recommended thing because customers deserve to know what ingredients are in their soap.  I do not like to use soap without an ingredient list myself, so do unto others...right?

Cosmetic claims should not be on the soap label.  Listing the oils for example cocoa butter, shea, jojoba - this is usually enough to let customers know that the soap has conditioning ingredients, or humectants like honey and oatmeal.  No need to say anything more.  Good way to stay out of trouble too.


----------



## RocknRoll (Jan 26, 2013)

Genny said:


> If you're in the U.S. you do not need to put allergy warnings on your labels.  Ingredients are fine.


 
Oh good! 

So now I just need to find out if Im required to put "directions for use" and a simple warning like "discontinue if irritation occurs."

Thanks!


----------



## RocknRoll (Jan 26, 2013)

green soap said:


> If what you are selling is 'just soap' it does not fall under FDA jurisdiction.  All you NEED to list is:
> 
> that it is soap
> the weight
> ...


 
Thank you! I will take your advice and eliminate the word "moisturizing." i hate getting into trouble :shock:


----------



## paillo (Jan 26, 2013)

Rock&Royalty said:


> Thank you! I will take your advice and eliminate the word "moisturizing." i hate getting into trouble :shock:



Just imho, but I think with that change your labels will be perfect, and the envy of many of us, yours truly included


----------



## RocknRoll (Jan 26, 2013)

paillo said:


> Well, I wouldn't call myself a 'soap police' but I do occasionally contact sellers that particularly annoy me with false advertising about all-natural ingredients when they blatantly list synthetic ingredients. And I have on more than one occasion filed a complaint with the FDA about particularly egregious false advertising (the recently discussed popular soap sold at many Mennonite outlets being the latest).  Seriously, I do hope there are at least the occasional 'soap police' perusing online listings and looking at farmers markets and festivals. Most such agencies are so short-staffed and under-funded that I doubt they can spend much time at this, sadly.
> 
> And my latest pet peeve? The new Dove commercials that put down soap. Grrrrrrrrrrrr......


 
Ya, I totally agree with you on that one. I dont even call my soap "all natural" because I use Fragrance oils too. I do however say "natural" and I dont feel its misleading. It amazes me what companies get away with! Such a shame.


----------



## Crocoturtle (Jan 26, 2013)

I may need to start a new thread for this but I'm curious what words are considered "health claims" or "cosmetic" 
Part of my business model is developing signature soaps for small businesses such as I made a soap for a local beekeeper using their honey and beeswax that they sell with their products. 
For the most part I avoid the issue by just saying <fragrance> soap
I have a client who runs a karate school and wants to call the product "Chi Invigorating Soap." Is "invigorating" a claim? Is there a list somewhere of what words you can and can't use?


----------



## paillo (Jan 26, 2013)

Crocoturtle said:


> I may need to start a new thread for this but I'm curious what words are considered "health claims" or "cosmetic"
> Part of my business model is developing signature soaps for small businesses such as I made a soap for a local beekeeper using their honey and beeswax that they sell with their products.
> For the most part I avoid the issue by just saying <fragrance> soap
> I have a client who runs a karate school and wants to call the product "Chi Invigorating Soap." Is "invigorating" a claim? Is there a list somewhere of what words you can and can't use?



I like your idea of starting a new thread, as this one is pretty specific to one person's products (which I think I love, btw).


----------



## RocknRoll (Jan 26, 2013)

Crocoturtle said:


> I may need to start a new thread for this but I'm curious what words are considered "health claims" or "cosmetic"
> Part of my business model is developing signature soaps for small businesses such as I made a soap for a local beekeeper using their honey and beeswax that they sell with their products.
> For the most part I avoid the issue by just saying <fragrance> soap
> I have a client who runs a karate school and wants to call the product "Chi Invigorating Soap." Is "invigorating" a claim? Is there a list somewhere of what words you can and can't use?


  I wish there was. thats a very good question. I have a soap that I have named "tranquility" does that mean I'm insinuating that it has some sort of mind altering effect lol! I dont know where that fine line is, but I wish i did!


----------



## RocknRoll (Jan 26, 2013)

paillo said:


> I like your idea of starting a new thread, as this one is pretty specific to one person's products (which I think I love, btw).


  A new thread would be good!


----------



## RocknRoll (Jan 26, 2013)

paillo said:


> Just imho, but I think with that change your labels will be perfect, and the envy of many of us, yours truly included


 awww, thank you all for helping me decide with thess last few details


----------



## Genny (Jan 26, 2013)

Rock&Royalty said:


> Oh good!
> 
> So now I just need to find out if Im required to put "directions for use" and a simple warning like "discontinue if irritation occurs."
> 
> Thanks!



If you are going the cosmetic labeling route, then yes you do.  Honestly, I'd just drop moisturizing from label.  So much easier


----------



## AlchemyandAshes (Jan 26, 2013)

My "soap" labels read (no cosmetic claims):
For External Use Only
Avoid Contact With Eyes
Discontinue Use If Rash or Irritation Occur

Not required, but CYA...


----------



## RocknRoll (Jan 26, 2013)

AlchemyandAshes said:


> My "soap" labels read (no cosmetic claims):
> For External Use Only
> Avoid Contact With Eyes
> Discontinue Use If Rash or Irritation Occur
> ...


Thanks for the imput. I have come to the conclusion that if i want to go the cosmetic route, i need a back lablel to fit all the necessary info.


----------



## melstan775 (Jan 27, 2013)

Rock&Royalty said:


> It's so complicated! Maybe I should just leave off that its moisturizing. Now I'm even wondering if I can use the wordage "detoxifying facial soap with activated charcoal" without it being touted as a "drug" and all new restrictions. I want to be able to "brag" so to speak about  at least a couple of the benefits of my soap (moisturizing, natural) but i'm wondering if the hassel is worth it.
> 
> It's called "misbranded" if the lable isnt strictly to "code" but I see misbrands even on the lip balb packaging I bought at a farmers market. Say i did accidently "misbrand" my product (for instance puting the net weight on the back lable instead of the front) I wonder what the reprocussions would be, I mean are there really "soap lable police" out there? LoL! I just want to be within compliance but its frustrating. Thanks for the imput.




If you really wanted to simplify your label, you would go to the store, buy a Dove bar, and copy the panels of information. Why Dove? It's a mass circulated brand with a lot of formulas that clearly make cosmetic claims.  My mother's box of Dove bars has a panel of great info that in fact, claims the white bar is"Beauty bar for deep moisture." 

Then it says, "Everyone knows the secret to beautiful skin is everyday moisture. Simply put, no other bar hydrates skin better then Dove. And when used daily, Dove can even even reduce the appearance of fine lines over time. What can we say? It's just that good."  

Then there is one more box that says, "Dove doesn't dry your skin like ordinary soap."

I'm pretty sure if Dove can go on like that, it's okay for you to label your soap "Moisturizing Soap."


----------



## Gryfonmoon (Jan 27, 2013)

Is Dove even soap though? I mean, legally.


----------



## Genny (Jan 27, 2013)

Gryfonmoon said:


> Is Dove even soap though? I mean, legally.



Nope, it's a cosmetic.


----------



## Gryfonmoon (Jan 27, 2013)

Genny said:


> Nope, it's a cosmetic.



I thought a Dove bar was a delicious ice cream snack.


----------



## melstan775 (Jan 27, 2013)

Genny said:


> Nope, it's a cosmetic.



I think Dove trails the line between soap and cosmetic. It's clearly a soap with a moisturizer added. But you find it on the soap aisle.  It's advertised as a soap, only it's marketing is cosmetic-like. Actually, now I am curious, what IS it, exactly ,based on what we know. I'm going to scout MSDS sheets. BRB. 



 And, it's MSDS sheet labels the product as a bar soap. It's Trade name is Dove Beauty Bar, it turns out. So, it looks like a cosmetic, but it's soap. 

http://www.gjfood.com/pdf/msds/31_800100.pdf

Here's another MSDS for it, which also applies it as soap:


http://www.andersonsanitary.com/MSDS/Dove_Soap_and_%20Dri_White%20Powder.pdf

So now the question is, how is Dove getting away with riding the line? :?:


----------



## Genny (Jan 27, 2013)

Well technically Dove is a soap.  It cleans.  It's a soap product.  But FDA regulatory-wise, it would be considered a cosmetic.


----------



## melstan775 (Jan 27, 2013)

Genny said:


> Well technically Dove is a soap.  It cleans.  It's a soap product.  But FDA regulatory-wise, it would be considered a cosmetic.



There should be a category for "Cosmetic Soaps." Or maybe the FDA needs to reevaluate their regulations (knock on wood they don't, the last thing we need is more regs, right?) cuz face it, those rules are about 50 years out of date. Soap and cosmetic making has come a long long way since then! 

But I think your'e right, in the end its legally a cosmetic. It label meets the cosmetic requirement, not just the soap one: 

Identity Labeling   (Dove)
Common or usual name  (Dove)
Descriptive name  (white - blanc)
Fanciful name (beauty bar with deep moisture)
Illustration (dove bird soap stamp, actually under the word Dove)
Prominence (1/4 moisture cream)
Placement (found in soap aisle 


And yes, I did go to my mother's and get her soap. I even had to open the package because she buys it in bulk.


----------



## RocknRoll (Jan 27, 2013)

melstan775 said:


> If you really wanted to simplify your label, you would go to the store, buy a Dove bar, and copy the panels of information. Why Dove? It's a mass circulated brand with a lot of formulas that clearly make cosmetic claims.  My mother's box of Dove bars has a panel of great info that in fact, claims the white bar is"Beauty bar for deep moisture."
> 
> Then it says, "Everyone knows the secret to beautiful skin is everyday moisture. Simply put, no other bar hydrates skin better then Dove. And when used daily, Dove can even even reduce the appearance of fine lines over time. What can we say? It's just that good."
> 
> ...


 Excellent thought thank you! ;-)


----------



## Kersten (Jan 27, 2013)

From what I have read (and I could be missing something here) once you make ANY kind of claim outside of, " it is soap and it cleans", you have to follow labeling requirements of a cosmetic. Since a lot of soapers already follow most of those requirements with their ingredients listed according to INCI standards, it really isn't much more effort to include your physical location, related warnings, and the other minor details to comply with the requirements. Just my humble opinion.


----------



## Gryfonmoon (Jan 27, 2013)

What 'related warnings" though? That's one part I don't understand completely. Are warnings like "Hey don't put this lip balm tube in your rectum" or more like "Contains wheat and other allergies"?


----------



## Kersten (Jan 27, 2013)

If you read the regs, they will detail them better than I can here, but one such warning found in the regs is:


 § 740.10 Warning: "If the cosmetic product contains an ingredient for which adequate substantiation of safety has not been obtained a warning must be placed on the PDP like "Warning —The safety of this product has not been determined".


----------



## Kersten (Jan 27, 2013)

Heheh "Don't put this lip balm in your rectum"!! That would be hilarious and maybe even genius in the right market ;-) I kid. But here is the direct link to warnings http://www.fda.gov/Cosmetics/CosmeticLabelingLabelClaims/default.htm


----------



## RocknRoll (Jan 27, 2013)

Gryfonmoon said:


> What 'related warnings" though? That's one part I don't understand completely. Are warnings like "Hey don't put this lip balm tube in your rectum" or more like "Contains wheat and other allergies"?


 
LMFAO!!!:clap:


----------



## melstan775 (Jan 27, 2013)

Kersten said:


> From what I have read (and I could be missing something here) once you make ANY kind of claim outside of, " it is soap and it cleans", you have to follow labeling requirements of a cosmetic. Since a lot of soapers already follow most of those requirements with their ingredients listed according to INCI standards, it really isn't much more effort to include your physical location, related warnings, and the other minor details to comply with the requirements. Just my humble opinion.



you know what would be great? An example. Does anyone have an example label we could look at? Google turns up nothing useful on this one.


----------



## Gryfonmoon (Jan 27, 2013)

Kersten said:


> If you read the regs, they will detail them better than I can here, but one such warning found in the regs is:
> 
> 
> § 740.10 Warning: "If the cosmetic product contains an ingredient for which adequate substantiation of safety has not been obtained a warning must be placed on the PDP like "Warning —The safety of this product has not been determined".



Okay, so if I'm understanding this properly, it's a particular ingredient or ingredient(s) IN my product I would need to warn about, not the product as a whole (meaning my hypothetical rectumless lip balm doesn't need to be officially tested)?

Also, thanks for the link  Here's hoping my brain can comprehend the legalese.


----------



## Kersten (Jan 27, 2013)

Well, not exactly, that was just an example. It's best to read the manual, which isn't really as cumbersome a read as I thought it would be. This is what the *summary* on warning section states (more details are given within the manual):

Label Warnings
Cosmetics which may be hazardous to consumers when misused must bear appropriate label warnings and adequate directions for safe use. The statements must be prominent and conspicuous. Some cosmetics must bear label warnings or cautions prescribed by regulation (21 CFR 740). Cosmetics in self-pressurized containers (aerosol products), feminine deodorant sprays, and children's bubble bath products are examples of products requiring such statements.

"Although the FD&C Act does not require that cosmetic manufacturers or marketers test their products for safety, the FDA strongly urges cosmetic manufacturers to conduct whatever toxicological or other tests are appropriate to substantiate the safety of their cosmetics. If the safety of a cosmetic is not adequately substantiated, the product may be considered misbranded and may be subject to regulatory action unless the label bears the following statement: Warning--The safety of this product has not been determined. Sec. 21 CFR 740.10."


----------



## Kersten (Jan 27, 2013)

Btw, you crack me up!!! I think you would be safe not testing the rectum lip balm for safety, as long as you included the warning bwahahahaa


----------



## melstan775 (Jan 27, 2013)

Gryfonmoon said:


> Okay, so if I'm understanding this properly, it's a particular ingredient or ingredient(s) IN my product I would need to warn about, not the product as a whole (meaning my hypothetical rectumless lip balm doesn't need to be officially tested)?
> 
> Also, thanks for the link  Here's hoping my brain can comprehend the legalese.



But some people put sodium hydroxide on their labels. Technically, it's correct, but lye within itself is dangerous. So doesn't taking the route of labeling soap as made with "water, sodium hydroxide, (insert favorite) oil, and glycerin," technically violate the added warning requirement? 

And for that matter, if you put "lavender soap calms and refreshes," is that a cosmetic claim or a drug one? I would think drug since the claim is physical not just cosmetic.  So you have to have an active ingredient panel too.  This is so confusing!


----------



## Kersten (Jan 27, 2013)

Here is another section of interest within the manual:

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.

The safety of a cosmetic may be considered adequately substantiated if experts qualified by scientific training and experience can reasonably conclude from the available toxicological and other test data, chemical composition, and other pertinent information that the product is not injurious to consumers under conditions of customary use and reasonably foreseeable conditions of misuse.

The safety of a cosmetic can adequately be substantiated by:

a. Reliance on available toxicological test data on its ingredients and on similar products, and

b. Performance of additional toxicological and other testing appropriate in the light of the existing data.

Even if the safety of each ingredient has been substantiated, there usually still is at least some toxicological testing needed with the formulated product to assure adequate safety substantiation.


----------



## RocknRoll (Jan 27, 2013)

I've decided Im just going to go with labeling my soap as a cosmetic. Im going to include a back label which will have the ingredient list, a short little statement about the soap with contact info and warnings. That will free up more space on the front too without having to cram everything onto one side. If dove can get away with all their "claims" then i think it will be ok for me to make such claims as "moisturizing" and the like. As long as I follow all the guidlines I will be in compliance. In the end it comes down to really wanting to highlite the benefits of the ingredients i've added. I pay good money to add things like cocoa butter, shea butter and goats milk and I want people to know they add benefits. thats just me, please correct me if I'm wrong. i guess it's a risk I'm wiling to take as long as I feel all bases have been covered.  Thank you for all the advice!


----------



## RocknRoll (Jan 27, 2013)

melstan775 said:


> But some people put sodium hydroxide on their labels. Technically, it's correct, but lye within itself is dangerous. So doesn't taking the route of labeling soap as made with "water, sodium hydroxide, (insert favorite) oil, and glycerin," technically violate the added warning requirement?
> 
> And for that matter, if you put "lavender soap calms and refreshes," is that a cosmetic claim or a drug one? I would think drug since the claim is physical not just cosmetic.  So you have to have an active ingredient panel too.  This is so confusing!


 Right!? *rolls:crazy: eyes*


----------



## RocknRoll (Jan 27, 2013)

Kersten said:


> Here is another section of interest within the manual:
> 
> 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:
> 
> ...


 Wow, ya, i really wish they would provide us with example labels for cosmetic soaps.


----------



## paillo (Jan 27, 2013)

Not to belabor my earlier point, but how often would you sell soap if you can't accompany it with a placard or website description (maybe much longer and more explanatory)?

I always put longer descriptions of the skin benefits of my soap (e.g. moisturizing ingredient, exfoliating ingredient, detox ingredient and history, uses) on my website, along with warnings for pregnant women, children, those with allergies. For markets  and shops I have a shorter but still descriptive placard in front of the rows of soap.  A brochure would be a great idea too. This allows people to read more and ask questions, and eliminates the sticky issue of cosmetic vs. soap labeling.

Sigh... in light of Genny's post on health claims, this may be not be the way to go either -- or still possible with very careful wording.


----------



## Soapsense (Jan 27, 2013)

Maybe you could use "The safety of this product has been determined by my own toungue"  lol
If I am interpretting correctly, the above post on testing says that if your ingredients are tested by your supplier that counts?


----------

