Okay, I found
A link, although it is NOT on the FDA website (which regulates cosmetics & drugs), nor on the CPSC website (for true soap), nor any other government site (that I could find as yet). It is on the American Herbal Products Association (AHPA) site. It includes an excerpt from a written response they received from Mr. Lark Lambert of the FDA in which he says,
"Neither of the terms "soap" nor "saponified oil" are included in the INCI dictionary."
So if this 7-year old document is still considered current, my guess would be that using the word 'saponified' on 'true soap' would be allowed, but not so on soap that falls into the category of a cosmetic or a drug. Notwithstanding all the other labeling requirements, which as pointed out previously include other detail when the soaps are being sold.
Not that I am selling soap, nor do I ever plan to sell soap. I just like to understand the laws and regulations because that's the way I am. Plus in my former life as a nurse educator, I used to have to wade through federal & state regulations, as well as Joint Commission standards all the time because I was responsible for training our staff to comply with said standards & regulations. Then after retiring as a nurse, my son talked me into opening a restaurant and I had to learn Food Safety and Public Health Safety Regulations and assure that our restaurant complied, which we did and always got 100% on our inspections, btw. But as a result of all that in my past, I have no desire to deal with any of it again on a business level. I want to know and understand it, but that's as far as it goes.
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ETA: And yes Marie Gale does say that true soaps can be labeled using the word 'saponified'.
Quote from
http://www.mariegale.com/ingredient-labels-soap/
Ingredient List When It’s Not Required
Sometimes (often, actually) a soapmaker has a true soap for which no cosmetic claims have been made, but still wants to tell their customers what is in the soap. Since it’s not a cosmetic, the FDA regulations don’t apply, so there is considerably more freedom in what you say.
In this case, you could use “saponified oils of ___”. The ingredients don’t necessarily have to be in descending order of predominance – they don’t even have to all be included.
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.
End quote.
