M&P Soaps- Do they fall under Cosmetic category?

[Kalyani]

I have been following several posts regarding the Labeling of soaps and got a bit confused. Firstly, do M&P soaps fall under the "Cosmetic" category and therefore all the ingredients have to be listed?
Or should I just list all the ingredients regardless
on the label?
Thanks!

 

[dagmar88]

http://www.fda.gov/cosmetics/guidancecomplianceregulatoryinformation/ucm074201.htm

 

[Genny]

Some are, some aren't. It would matter what the ingredients are in the mp base.
In my opinion though, I'd just list the ingredients anyway. Due to allergies, I won't buy anything without seeing the ingredients first and I know there are many more people out there that do the same.

 

[carebear]

Consider it a cosmetic and you will probably be right. Really, though, why would you not list the ingredients regardless?

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.

 

[Kalyani]

M&P Soaps-Do they fall under cosmetic category

Thanks for the replies.

I just want to get it right.

So I should list the ingredients for the M&P soap base as below but in INCI?-
Glycerine, Palm Oil, Coconut Oil, Lauric Acid, Purified Water, Sodium Hydroxide, Sodium Lauryl Sulfate, Sorbitol, Triethanolamine, Sodium Chloride, EDTA

I was under the impression that soap falls under CPSC and the label requires-
1)Identifying statement indicating the word "Soap"
2)Net Weight of Product
3)Name and Place of Business

Thanks!

 

[carebear]

you don't need INCI, just use clear language - what you have is fine.

and yes product ID, name of business, weight of product, contact info (place of business not required any longer)