My recent market analysis

[Lin19687]

@TheGecko NO, you are wrong. I will not argue it because it seems you are set.
IF you are saying it is JUST SOAP, you can choose to NOT LIST ANYTHING. But the second you list any ingredient you need to list in order, period. You may want to read up on that subject.

And there is more to curing then 'mainly hardening the bar'

 

[Mobjack Bay]

It’s good to re-read the guidelines occasionally. As I understand it, Marie Gale is a reliable authority for US soapmakers.

https://www.mariegale.com/ingredient-labels-soap/

Here’s what she states towards the bottom of the post:

“A Note of Advice
If you do decide to put the ingredients on a true soap, be aware that consumers expect that if you say “Ingredients: ____”, you are stating all of the ingredients in descending order of predominance. To withhold ingredients isn’t in violation of the FDA regulations, but it might be considered “deceptive”.

A better way to do it, if you are using non-standard ingredient names (such as “saponified oils of ___”, or are not putting all the ingredients on the list (ie saying “essential oil blend” instead of listing them out), it’s probably better to put it as information, rather than an actual “ingredient declaration.”

Something like “We make our soaps with saponified oils of ___ and scent them with only pure essential oils, including much-loved lavender and patchouli oils.” That makes it more informative, and the consumer can see that it’s not a true ingredient declaration as they normally expect on cosmetics.”

Even though I am not selling my soaps, I am fully labeling them. I feel my family and friend testers should know if a soap has lard vs. palm, EOs vs. FOs, clays, micas, carrots, aloe, cucumber, madder, indigo, etc.

 

[KiwiMoose]

It is very annoying when you are at a market and someone has just been told lies by the soap soap stall just five doors down from yours. People really do want to believe the lies! I always just quote my sister in law - who does have eczema - and how she has now ditched all soap that is commercially made, including liquid soap, in favour of my soap.

Dove - with 1/4 moisturizing cream. People still cite this as think it is gospel! Actual ingredients list: Ingredients: Sodium Lauroyl Isethionate, Stearic Acid, Lauric Acid, Sodium Tallowate or Sodium Palmitate, Water (Aqua), Sodium Isethionate, Sodium Stearate, Cocoamidopropyl Betaine, Sodium Cocoate or Sodium Palm Kernelate, Glycerin, Sodium Chloride, Tetrasodium Etidronate, Tetrasodium EDTA, Titanium Dioxide (CI 77891).

 

[TheGecko]

Whilst I understand what you are saying @TheGecko you cant make definitive statements like that without some qualification. I would hate newbies to read this thinking that they can label how they want wherever they are in the world, you cant.

If you sell ( or even gift ) in the EU and in other countries, there are strict rules on labelling and soap is soap is soap. It is a cosmetic and labels are produced using a set standard and you are required to include all ingredients including mica, EOs and to state allergens.

I know the rules are somewhat different in the states I just hate to see such definitive statements handed out when the forum covers many other countries.

Here's the deal...I was responding to the original poster who is in the US and who was purchasing from local places. I am also in the US and that is how I responded, as one US resident to another, even going so far as to mention the Fair Packaging and Label Act and the FDA, and even quoting the FDA. Had the poster been located in another country or not had a location listed, I would have responded differently as I do not know what the exact labeling requirements are in other countries, though I am learning.

People really do want to believe the lies!

People want easy peasy miracles...weight loss, younger looking skin, six-pack, etc.

 

[Lin19687]

Marie Gale link you posted was written in Dec 17, 2012 so those that are reading it please be aware of that and thing might have changed since then.

Please people, go read the ACTUAL LAWS that are Up to Date. It can be hard to understand the way they write but it is there. Soap is soap and need not have ingredients but if you list just ONE then you need to list them all in the order. Beyond that you need to go look yourself.

I PM'd someone (that listed all the oils EXCEPT the Lye on her packaging) that her labels were not correct . But she told me that since she had been doing this for 10 years and read the rules that she is correct.
Well, she is not correct but didn't want to listen to someone that pointed that out to her.

 

[Mobjack Bay]

Okay, I fully agree that we should not rely on potentially out of date information. I really don’t want to flare things up, but I do feel compelled to seek out additional information when something seems unclear to me or if I have it wrong. The information below was obtained a few minutes ago by creating a customized report on soap using the small business “regulatory robot“ available on the US Consumer Product Safety Commission website. ETA: when soap is “true” soap, it is regulated by the CPSC. The very last sentence of the relevant section states that the CPSC has no specific labeling requirements for true soaps, unless they are intended primarily for children 12 and under. The word “no” is underlined in the report.

First, it is important to provide a brief overview of how the federal government regulates “soap,” and which federal agency has jurisdiction over which type of “soap.”

Traditional soaps made primarily from fats and alkalis are regulated by our agency, the CPSC. However, many items called “soaps” on the market today are in fact not actual soap; they are cleansers, detergents, or other types of products regulated as either a cosmetic or a drug by the Food and Drug Administration (FDA).

So, how do you tell if you are making a soap (CPSC) or a cosmetic/drug (FDA)? The FDA’s website on Soap: FAQs helps to lay out the differences:

“To meet the definition of soap in FDA’s regulations, a product has to meet three conditions:

1. What it’s made of: To be regulated as “soap,” the product must be composed mainly of the “alkali salts of fatty acids,” that is, the material you get when you combine fats or oils with an alkali, such as lye.
2. What ingredients cause its cleaning action: To be regulated as “soap,” those “alkali salts of fatty acids” must be the only material that results in the product’s cleaning action. If the product contains synthetic detergents, it’s a cosmetic, not a soap. You still can use the word “soap” on the label.
3. How it's intended to be used: To be regulated as soap, it must be labeled and marketed only for use as soap. If it is intended for purposes such as moisturizing the skin, making the user smell nice, or deodorizing the user’s body, it’s a cosmetic. Or, if the product is intended to treat or prevent disease, such as by killing germs, or treating skin conditions, such as acne or eczema, it’s a drug. You still can use the word “soap” on the label.

You can read the entire regulation at 21 CFR §701.20.”

CPSC staff recommends that you take a close look through the FDA’s guidance webpages, including “Is it a Cosmetic, a Drug, or Both? (Or Is It Soap?),” “Soap: FAQs,” and also “Soaps & Lotions” to determine if you are in fact making a soap, cosmetic, drug, or some combination thereof.

As stated above, the CPSC regulates true soaps (not cosmetics or drugs) that are made primarily of fats and alkalis and that are manufactured for consumer use. To that end, the CPSC has no specific labeling requirements for true soaps not primarily intended for use by children age 12 and under.

The information was obtained by creating a report, starting here:
https://www.cpsc.gov/Business--Manufacturing/Regulatory-Robot/Safer-Products-Start-Here/

 

[TheGecko]

Please people, go read the ACTUAL LAWS that are Up to Date. It can be hard to understand the way they write but it is there. Soap is soap and need not have ingredients but if you list just ONE then you need to list them all in the order. Beyond that you need to go look yourself.

The information I quote came directly from the FDA website (as I stated) this morning, so maybe you can tell that they are wrong.

 

[Dahila]

I am selling my bars with correct weight, No natural not claims, and Everything is there is also on Label. In Canada soap is a cosmetic and must be labelled accordingly. There is another guy who not only claims but writes on the fliers ; healing soaps, eczema, psoriasis and excetera.... I do not care , I care about my sticking with regulation. I am like shunt and Cmzaha educating people that soap does not heal it washes. Lotions especially made with calendula help for my itching but they do not heal. Salves help also but do not heal . Nothing will heal psoriasis or eczema. Lotion can only relieve dry skin, which somehow helps but that's all
BTW I would never buy a bar of soap without full list of ingredients, with my allergies it is not joke

 

[Carl]

Wow, I opened a can of worms here.

So what it all boils down to is this: If you use a Mica powder with the following ingredients: "Fluorphlogopite, Titanium Dioxide, Tin Oxide, Iron Oxide"

And you decide to list out ingredients.

Can you just say:

"Mica"

or do you have to break it out:
"Fluorphlogopite, Titanium Dioxide, Tin Oxide, Iron Oxide"

So we have 1 of 2 choices:

1. Oil #1, Oil #2, Oil #3, Distilled Water, Sodium Hydroxide, Fragrance Oil, Mica
2. Oil #1, Oil #2, Oil #3, Distilled Water, Sodium Hydroxide, Fragrance Oil, Fluorphlogopite, Titanium Dioxide, Tin Oxide, Iron Oxide

I've been breaking it out. But do I really need to? In the U.S.

 

[Rsapienza]

Wow, I opened a can of worms here.

So what it all boils down to is this: If you use a Mica powder with the following ingredients: "Fluorphlogopite, Titanium Dioxide, Tin Oxide, Iron Oxide"

And you decide to list out ingredients.

Can you just say:

"Mica"

or do you have to break it out:
"Fluorphlogopite, Titanium Dioxide, Tin Oxide, Iron Oxide"

So we have 1 of 2 choices:

1. Oil #1, Oil #2, Oil #3, Distilled Water, Sodium Hydroxide, Fragrance Oil, Mica
2. Oil #1, Oil #2, Oil #3, Distilled Water, Sodium Hydroxide, Fragrance Oil, Fluorphlogopite, Titanium Dioxide, Tin Oxide, Iron Oxide

I've been breaking it out. But do I really need to? In the U.S.

I do #2 and I have always thought that we did not have to label soap (in US), if only said to be soap, but that if we did label, ALL ingredients had to be included, along with weight in oz/g per the Fair Packaging and Label Act, and identified as soap. Oh, and that any ingredient under 2% (not sure on that number) did not have to be in order of predominance, while the rest does.

 

[TheGecko]

I am selling my bars with correct weight, No natural not claims, and Everything is there is also on Label. In Canada soap is a cosmetic and must be labelled accordingly. There is another guy who not only claims but writes on the fliers ; healing soaps, eczema, psoriasis and excetera.... I do not care , I care about my sticking with regulation. I am like shunt and Cmzaha educating people that soap does not heal it washes. Lotions especially made with calendula help for my itching but they do not heal. Salves help also but do not heal . Nothing will heal psoriasis or eczema. Lotion can only relieve dry skin, which somehow helps but that's all

My soap just says 'Soap' on the label. I could, on my regular soap put 'vegan', but it drives me nuts that Cornstarch is labeled 'gluten free' so I won't. I could, on my regular and goat milk soaps that are unscented and uncolored and/or are only scented with EOs and colored with plant-based powders put 'all natural', but I'm not into gimmicks so I won't. I will tell folks that a well-balanced true soap is better for the skin than a commercial soap because it's not a detergent and therefore does not strip your skin of natural oils. At my last craft night, I had someone who was hesitate to try my soap because glycerin wasn't listed as an ingredient and it was a must for her. I explained to her that a true soap already contains glycerin...that because I don't take it out like they do with commercial soaps, I don't have to add [a portion of] it back it.

BTW I would never buy a bar of soap without full list of ingredients, with my allergies it is not joke

My sister has severe skin allergies.

 

[Marilyn Norgart]

but that if we did label, ALL ingredients had to be included, along with weight in oz/g per the Fair Packaging and Label Act

I believe all soaps need to have weight on them whether you have an ingred list or not

 

[TheGecko]

Wow, I opened a can of worms here.

Sometimes cans need to be opened to see what is inside of them.

I've been breaking it out. But do I really need to? In the U.S.

Yes and no.

Yes - Ingredients should be listed in descending order of predominance (based on their percentage, by weight, in the product). So MY ingredient labels says (by weight): Olive Oil, Distilled Water, Coconut Oil, Palm Oil (RSPO), Sodium Hydroxide, Cocoa Butter, Shea Butter, Castor Oil, Sodium Lactate and Kaolin Clay.

No - Because Fragrance Oils are proprietary, there is simply no way to list the ingredients contained within them. When it comes colorants...whether it's an oxide, plant powder, pigment, mica...so long as you don't make any cosmetic or drug claims, you don't have to go into details. I use a "May contain scents and/or color".

And I'm going to add a 'yes' to additives like seeds, pumice, coffee grounds, nut shells, etc because of allergies. On my Snickerdoodle Soap, I added Walnut Shells and it says in bold red letters: CONTAINS WALNUT SHELLS.

@TheGecko NO, you are wrong. I will not argue it because it seems you are set.

What the heck is your problem?!? Seems the only person who is 'set' here is you, because you obviously haven't read a word I wrote. But let me help you out here.

IF you are saying it is JUST SOAP, you can choose to NOT LIST ANYTHING.

What I said: 3. Actually...if it's a true soap, you don't have to list your ingredients because it falls under the Fair Packaging and Label Act and not the FDA.

But the second you list any ingredient you need to list in order, period. You may want to read up on that subject.

What I said: Since true soap is exempt you can legally list your ingredients any way you want them, BUTT, you would run the risk of deceptive labeling practices if because of the way you list your ingredients...folks think your soap is primarily made with Cocoa Butter because you listed it first, when in fact it only contains a small amount thereof. So BEST practice for labeling in that instance is to list your ingredients in descending order of predominance.

And there is more to curing then 'mainly hardening the bar'

Now you're just nitpicking. The main reason we cure our soaps is to produce a harder and longer-lasting bar...that is repeatedly emphasized in every article and/or book or website I have read about soap making. Does curing your soap do anything else...maybe, maybe not. Some folks say that the longer you allow your bar to cure, the better it lathers...that would be logical to the extent that you are reducing the water content, but at some point the water will have completely evaporated and it becomes moot.

 

[jcandleattic]

The main reason we cure our soaps is to produce a harder and longer-lasting bar

That's not the main reason I cure my soap. It's so I have a bar that is at it's best, regardless of how "hard" or "long-lasting" it is. A well cured soap will be so much milder than one that is not - even with my softer soaps, it will still need to be well cured, not to get harder, to get milder.

Does curing your soap do anything else...maybe, maybe not.

Absolutely it does. That is time tested actual physical difference that almost all soapmakers can agree on.

but at some point the water will have completely evaporated and it becomes moot.

I think if I remember correctly that after reading some scientific journals and a few other soapmaking books - Maybe it was Dunn's book? can't remember, but it takes years for all of the water to completely evaporate out of soap, not just a typical 4-6 week cure.

 

[Mobjack Bay]

I’m still not finding a requirement that all ingredients must be listed for “true soap,” but there are words and phrases in the various sources that point to issues with deceptive practices if you list some, but not all, ingredients. I would want to know more if I decided to sell my product. (ETA: the answer to the “if one, then all?” question is here: https://www.mariegale.com/if-one-then-all/)

This very recent post by Marie Gale (January 6, 2019) is an easy read. In the sections pertaining to ingredient labeling, she specifically adds “cosmetics only”. https://www.mariegale.com/new-years-resolutions-check-your-labels/, but watch out if you claim your soap is cleansing!

Marie is also an official “HSCG Expert” now and has her own page in the Handcrafted Soap and Cosmetic Guild How-To Library. (Posted January 19, 2019, here:https://www.mariegale.com/members-of-the-hscg/).

This government webpage discusses the FPLA: https://www.ftc.gov/enforcement/rul...eform-proceedings/fair-packaging-labeling-act

“Basic Requirements: The FPLA requires each package of household "consumer commodities" that is included in the coverage of the FPLA to bear a label on which there is:

• a statement identifying the commodity, e.g., detergent, sponges, etc.;
• the name and place of business of the manufacturer, packer, or distributor;
• and the net quantity of contents in terms of weight, measure, or numerical count (measurement must be in both metric and inch/pound units).”

The actual language in the US Code (law) is here, and, yes, it painful to read:
https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title15-chapter39&edition=prelim

Marie Gale also provides information on what must be included on soap labels in a post from 2015. She mentions further regulations that affect soap makers, such as state requirements for scales to be certified, here:
https://www.mariegale.com/myth-soap-labels-arent-regulated/

For example,
“For consumer commodities generally (including soap), the FTC created regulations (Title 16, Commercial Practices, Part 500, Sections 500.1 to 500.29) which specifically detail what must go on the label of every product (including soap). These regulations go into greater detail and specificity on how each of the three items required by law must be actually done.

These regulations include things like where the information must be placed, how to calculate the correct text size, when the street address may be omitted from the label, acceptable methods to identify the product, etc.

The regulations require that the net contents are presented in both inch/pound (i.e. ounces and fluid ounces) and in metric (i.e. grams, milliliters).”

She goes on to list other considerations for soap makers, including that some states require “certification of scales used to weigh products for commercial sale (generally at a state level; often under the Department of Agriculture).”

 

[SideDoorSoaps]

I feel your rant, @Carl. I was just at a show this weekend with seven other soapers and three of them had jewelweed soap for poison ivy, two had goats milk - one said 100% goats milk (are there no other ingredients?) and one makes beard balm with goats milk (and I didn’t see a preservative, I know there’s no water but milk spoils).

I weigh my soaps when I cut them and when I pack them to make sure they meet my 4oz weight on my labels. And I make no claims with my soap and put all the ingredients on there, even the micas with tin oxide, etc. Someone asked me if my ingredients were organic and while some of them are, I don’t tout them as such.

I don’t believe that they are all blatant liars but a lot are underinformed, misinformed and ignorant. I almost want to make a brochure to pass out about true soaps, labeling and FDA regulations. I know one soaper who is a friend of mine who makes things that are insect repellants and that according to the FDA is a drug and then not being registered makes it an unregulated (illegal) drug. OH MY.

I just try to do my best and make sure I am compliant and constantly reading and learning alll that I can to ensure that.

 

[Carl]

Yeah, I'll keep this going even more.

Now I know that this is not a labeling requirement, but I did notice that only about 1 out of 10 soapers puts a batch number on her/his label. You know where you tie the batch number back to a spreadsheet on your computer that has the batch numbers of all the ingredients that you used.

Again I know it's not required, but a good practice that takes A LOT of time, that very few people do.

 

[Dahila]

Carl it is for you to quickly identify Which product is a problem. I do not use it, but have all dates and products with tags in Soapmaker

 

[shunt2011]

Yeah, I'll keep this going even more.

Now I know that this is not a labeling requirement, but I did notice that only about 1 out of 10 soapers puts a batch number on her/his label. You know where you tie the batch number back to a spreadsheet on your computer that has the batch numbers of all the ingredients that you used.

Again I know it's not required, but a good practice that takes A LOT of time, that very few people do.

That's actually just good manufacturing practice. All my batches have number and are easily identified. Especially if running a business.

 

[LilyJo]

Yep, it's a part GMP and key part of EU regs.