Canadian labelling: water content (and more)

[Karri]

So I'm just making soap as a hobby right now (and LOVING it) but eventually I may want to do this as a business. Being in Canada however, well, it will probably take months to pore over all the legislation guidelines put forth by Health Canada and Industry Canada. LOL. Figure I'll just start studying up on it now and if/when I decide to sell my soap I'll be prepared!

One question that's nagging me: do you label water content? And, if so, how would you measure that? i.e. because ingredients must be stated in order of highest concentration to lowest. To go by the water used in the actual soap-making process doesn't seem at all accurate to me.

I would think that most of the initial water loss happens in the first month or so after pouring, yes? But still ... is there a method for measuring how much water is actually still in the soap? Or would any remaining water content be negligible anyway? And if it's negligible, do you still list it?

See how crazy this is? HA!

Curious how other Canucks handle this and other labelling challenges (bilingual descriptions, "average net weights," and on and on and on ....)

Karri

 

[Rob K]

While I don't know about Canadian rules specifically, here in the US the water content would be labeled as "water".

As for the percentage of water in cured soap, you can calculate it by subtracting the cured weight from the poured weight of the soap. This difference is the amount of water that has evaporated during the curing period. If you subtract this difference from your initial water amount, then you know how much water is remaining in your soap.

As you know, your soap will continue to lose water content over time, but more and more slowly as time goes on. So from a practical point of view for ingredient listing purposes, I consider water to be a smaller percentage than the base oils, but greater than the fragrance, colorants and other additives.

Hope this helps...

 

[Karri]

That DOES help Rob. Thank you!

I guess there wouldn't be many instances where water weight after curing (say 4 weeks) would be LESS than fragrance/additives/EOs/etc. But it will be interesting to test this and do a before and after

Thanks again. Makes perfect sense!
Karri

EDIT: Now .... what about for goat's milk? The water content IN the milk itself would evaporate but not the milk and fats. But same method would apply here in that you would subtract whatever weight was lost from your soap after 4 weeks from the original weight of the milk, yes?

 

[Lindy]

Hi Karri - it's not as bad as you think it is.

First thing you do is register your recipes here http://www.hc-sc.gc.ca/cps-spc/cosmet-person/indust/require-exige/cnf-dcf-eng.php.

labeling - you are going to use INCI for your ingredients with your highest ingredient first. I recommend http://www.oshun.ca and look at their INCI list they also give you the name of the oil as soap rather than having to list your lye on the label. Weights must be shown in metric and you are going to show the minimum weight of the product.

Insurance - a must - check with the Co-Operators in your area...

Alberta has an on-line registry to register your sole proprietorship. Until you are selling $25,000 in any given 12 month period you don't have to worry about collecting GST. But that also means you can't claim it back as easily.

I hope this has helped.

It is really not as complicated as it first looks to sell soaps and B&B in Canada, not like the UK where you have to get safety assessments on all your products.

Cheers

ETA - you are going to list the ingredients as they go into the pot. Water is seldom the first ingredient in soap, but it does have to be listed as the percentage going in. Same with your Goat Milk or any other liquid being added.

 

[Karri]

Hey Lindy,

If ingredients are by weight "going into the pot" ... well that makes life SO much easier!! Happy Dance!!

Am def. familiar with the "normal" biz-related stuff as I already own one business (consulting). e.g. registering for GST, municipal licensing, etc etc. Though it does seem that folks get a little "weird" about soaping as a home biz. I hope I do not run into that if I set up shop in our city. (Our community is a tad ... hmm, how do I say this: not-pro-business )

Good thing to know re the Co-Operators! I'll have to get in touch with them.

Thank you again!
Karri

EDIT: Now in terms of calculating the concentration (% of total soap weight) for the oils, how does the lye weight factor in then? For example:

Olive xx g
Palm xx g
CO xx g
Water xx g
Lye xx g

Total oils/water = xxx grams going into pot (100%) OR

Total oils/water/lye = xxx grams going into pot (100%)

Which "total" am I using? (I hope my question makes sense...LOL)

 

[Lindy]

Kerri do you have SoapMaker3 ?

Let's say your recipe was:

Olive 48 oz
Palm 16 oz
CO 6 oz
Water 16.8 oz (35% lye concentration)
Lye 9 oz (8% SF)

This is how you would list it on your label:

Sodium Olivate
Aqua
Sodium Palmate
Sodium Cocoate

First those are the INCI names of the ingredients. They are listed in the order of highest concentration when they hit the pot. The lye does not have to be listed separately as you are indicating it's presence in the "Sodium" part of the name. If you were making a liquid soap it would then be Potassium instead of Sodium. Does that make sense?

So any other additives will also be listed in the order of their presence in the product.

Kerri if I can help you at all, let me know. It really is far less complicated that it at first seems. For instance, when you send in your Cosmetic Notification Form you are not required to receive approval before you start selling because it is assumed you know what you are doing. If there is a problem they will contact you.

By the way, if you make MP this too needs to be reported on the same Form because you are adding things to it which creates liability for you....

Hope this helps...

 

[chibilightangel]

Wow, thanks for the great info. I've been starting to look into the forms that I'll need to fill and your description makes it sound a whole lot less complicated than if you just read it straight through the legal stuff.

I'm in Quebec, do you know if I have to fill in 2 forms per formulation so that I can list my ingredients in french and in english?

 

[Lindy]

Because it's going to the federal government if can be in either of the official languages. Because you're in Quebec I'm sure you already know that you actual labels will need to be French first or the language police will get you :shock:

The have a guide on the site for helping you fill out the notification form. Another thing you do need to do is review the Cosmetic Hot List of restricted ingredients. It is surprising in spots.

Cheers

 

[Karri]

Aaah, I see! So that's what you meant by the INCI names for each saponified oil! Totally didn't catch that when I was reviewing the oshun list I think the fog is lifting!

I don't have SoapMaker 3 ... will have to check it out. I've seen that software program but didn't even think it would help with this kind of thing.

[edit: shoot, am on a Mac ... ]

More Q&A then!

1) When you say "minimum weights" does that mean you don't get too concerned about tolerances from the "average net" weights of the finished soap? I was going through this section of the regulations the other day and the tolerances are very low. I'm assuming though that as long as your stated weight is the bare minimum product the customer will receive you don't have to worry so much about the tolerances? i.e. just ensure you always have at LEAST that much soap in each bar and you're good to go?

2) Even though the concentrations for the ingr. list are "in the pot" weights, you'd still go by the "final/cured/shrunk" weight for your ready-for-sale soap, yes?

You're a wealth of wisdom Lindy. Thank you!!
Karri

 

[Lindy]

1) When you say "minimum weights" does that mean you don't get too concerned about tolerances from the "average net" weights of the finished soap? I was going through this section of the regulations the other day and the tolerances are very low. I'm assuming though that as long as your stated weight is the bare minimum product the customer will receive you don't have to worry so much about the tolerances? i.e. just ensure you always have at LEAST that much soap in each bar and you're good to go?

Make sure that you soap weighs at least the minimum weight, I prefer to label lower than they are getting because it is going to shrink more as it continues to age/cure. I also like to check soap that has been sitting for awhile labeled and ready to go just to make sure they haven't gone beneath that magic number.

2) Even though the concentrations for the ingr. list are "in the pot" weights, you'd still go by the "final/cured/shrunk" weight for your ready-for-sale soap, yes?

Your label is going to reflect the weights of in the pot and be shown in that order. Yes the water is going to cure out, but if we wanted to become totally technical the water is already gone just in the process of saponification. It is all part of the soap or "Sodium" part of the soap, just like the lye is no longer present in the saponified soap. There are some discussion that water could be omitted from our labels altogether, but as far as I know that final determination hasn't been made yet and it's better to be safe than sorry when it comes to following the regulations.

HTH

 

[Karri]

This is really helpful.

So the concern with "average weight" (as in the documentation with Health Canada) is a bit misleading ... because truly, are they gonna come after you for giving the customer extra soap beyond the "tolerance" levels stated in the guide?

(I know I'm being a little Type A here .... sorry.)

I think what makes it confusing for newbies is that the labelling sorta plays it from both ends of the soap making equation. ie. we want to list final product weight post saponification, post curing and water loss. And we're listing ingredients in their "saponified" format also.

BUT we're using "in the pot" weights to figure out concentration levels and what order to list those ingredients in. i.e. water going INTO the pot versus water left in cured soap. Because who could ever figure that out?

It's a little nutty.

Or soapy

Karri

 

[Lindy]

Karri they want to make sure that the customer is getting the amount claimed at a minimum. They are not concerned about you giving extra.

Your labeling needs to follow what you have listed in the Cosmetic Notification Form. That is what they would compare it against.

 

[Karri]

Gee, one would think you've been doing this a while eh?

At any point did you just pick up the phone and start grilling them for answers at Health Canada? LOL. Seems a lot is left to interpretation ... maybe that's what makes my analytical head spin. Thank goodness for experts like you!

I was at a one of the big grocery stores today looking at some of the "natural" (ish) soaps they carried. And of course scrutinizing labels. Wow. It's all over the map.

Karri