Warning on "cosmetic" soap lables question...

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RocknRoll

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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! ;)
 
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!
 
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.
 
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.
 
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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.
 
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!
 
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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.
 
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:
 
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......
 
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.
 
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!
 
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.

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