Warning on "cosmetic" soap lables question...

[RocknRoll]

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 wish there was. thats a very good question. I have a soap that I have named "tranquility" does that mean I'm insinuating that it has some sort of mind altering effect lol! I dont know where that fine line is, but I wish i did!

 

[RocknRoll]

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).

A new thread would be good!

 

[RocknRoll]

Just imho, but I think with that change your labels will be perfect, and the envy of many of us, yours truly included

awww, thank you all for helping me decide with thess last few details

 

[Genny]

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 you are going the cosmetic labeling route, then yes you do. Honestly, I'd just drop moisturizing from label. So much easier

 

[AlchemyandAshes]

My "soap" labels read (no cosmetic claims):
For External Use Only
Avoid Contact With Eyes
Discontinue Use If Rash or Irritation Occur

Not required, but CYA...

 

[RocknRoll]

My "soap" labels read (no cosmetic claims):
For External Use Only
Avoid Contact With Eyes
Discontinue Use If Rash or Irritation Occur

Not required, but CYA...

Thanks for the imput. I have come to the conclusion that if i want to go the cosmetic route, i need a back lablel to fit all the necessary info.

 

[melstan775]

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.

If you really wanted to simplify your label, you would go to the store, buy a Dove bar, and copy the panels of information. Why Dove? It's a mass circulated brand with a lot of formulas that clearly make cosmetic claims. My mother's box of Dove bars has a panel of great info that in fact, claims the white bar is"Beauty bar for deep moisture."

Then it says, "Everyone knows the secret to beautiful skin is everyday moisture. Simply put, no other bar hydrates skin better then Dove. And when used daily, Dove can even even reduce the appearance of fine lines over time. What can we say? It's just that good."

Then there is one more box that says, "Dove doesn't dry your skin like ordinary soap."

I'm pretty sure if Dove can go on like that, it's okay for you to label your soap "Moisturizing Soap."

 

[Gryfonmoon]

Is Dove even soap though? I mean, legally.

 

[Genny]

Is Dove even soap though? I mean, legally.

Nope, it's a cosmetic.

 

[Gryfonmoon]

Nope, it's a cosmetic.

I thought a Dove bar was a delicious ice cream snack.

 

[melstan775]

Nope, it's a cosmetic.

I think Dove trails the line between soap and cosmetic. It's clearly a soap with a moisturizer added. But you find it on the soap aisle. It's advertised as a soap, only it's marketing is cosmetic-like. Actually, now I am curious, what IS it, exactly ,based on what we know. I'm going to scout MSDS sheets. BRB.



And, it's MSDS sheet labels the product as a bar soap. It's Trade name is Dove Beauty Bar, it turns out. So, it looks like a cosmetic, but it's soap.

http://www.gjfood.com/pdf/msds/31_800100.pdf

Here's another MSDS for it, which also applies it as soap:


http://www.andersonsanitary.com/MSDS/Dove_Soap_and_%20Dri_White%20Powder.pdf

So now the question is, how is Dove getting away with riding the line? :?:

 

[Genny]

Well technically Dove is a soap. It cleans. It's a soap product. But FDA regulatory-wise, it would be considered a cosmetic.

 

[melstan775]

Well technically Dove is a soap. It cleans. It's a soap product. But FDA regulatory-wise, it would be considered a cosmetic.

There should be a category for "Cosmetic Soaps." Or maybe the FDA needs to reevaluate their regulations (knock on wood they don't, the last thing we need is more regs, right?) cuz face it, those rules are about 50 years out of date. Soap and cosmetic making has come a long long way since then!

But I think your'e right, in the end its legally a cosmetic. It label meets the cosmetic requirement, not just the soap one:

Identity Labeling (Dove)
Common or usual name (Dove)
Descriptive name (white - blanc)
Fanciful name (beauty bar with deep moisture)
Illustration (dove bird soap stamp, actually under the word Dove)
Prominence (1/4 moisture cream)
Placement (found in soap aisle


And yes, I did go to my mother's and get her soap. I even had to open the package because she buys it in bulk.

 

[RocknRoll]

If you really wanted to simplify your label, you would go to the store, buy a Dove bar, and copy the panels of information. Why Dove? It's a mass circulated brand with a lot of formulas that clearly make cosmetic claims. My mother's box of Dove bars has a panel of great info that in fact, claims the white bar is"Beauty bar for deep moisture."

Then it says, "Everyone knows the secret to beautiful skin is everyday moisture. Simply put, no other bar hydrates skin better then Dove. And when used daily, Dove can even even reduce the appearance of fine lines over time. What can we say? It's just that good."

Then there is one more box that says, "Dove doesn't dry your skin like ordinary soap."

!
I'm pretty sure if Dove can go on like that, it's okay for you to label your soap "Moisturizing Soap."

Excellent thought thank you! ;-)

 

[Kersten]

From what I have read (and I could be missing something here) once you make ANY kind of claim outside of, " it is soap and it cleans", you have to follow labeling requirements of a cosmetic. Since a lot of soapers already follow most of those requirements with their ingredients listed according to INCI standards, it really isn't much more effort to include your physical location, related warnings, and the other minor details to comply with the requirements. Just my humble opinion.

 

[Gryfonmoon]

What 'related warnings" though? That's one part I don't understand completely. Are warnings like "Hey don't put this lip balm tube in your rectum" or more like "Contains wheat and other allergies"?

 

[Kersten]

If you read the regs, they will detail them better than I can here, but one such warning found in the regs is:


§ 740.10 Warning: "If the cosmetic product contains an ingredient for which adequate substantiation of safety has not been obtained a warning must be placed on the PDP like "Warning —The safety of this product has not been determined".

 

[Kersten]

Heheh "Don't put this lip balm in your rectum"!! That would be hilarious and maybe even genius in the right market ;-) I kid. But here is the direct link to warnings http://www.fda.gov/Cosmetics/CosmeticLabelingLabelClaims/default.htm

 

[RocknRoll]

What 'related warnings" though? That's one part I don't understand completely. Are warnings like "Hey don't put this lip balm tube in your rectum" or more like "Contains wheat and other allergies"?

LMFAO!!!:clap:

 

[melstan775]

From what I have read (and I could be missing something here) once you make ANY kind of claim outside of, " it is soap and it cleans", you have to follow labeling requirements of a cosmetic. Since a lot of soapers already follow most of those requirements with their ingredients listed according to INCI standards, it really isn't much more effort to include your physical location, related warnings, and the other minor details to comply with the requirements. Just my humble opinion.

you know what would be great? An example. Does anyone have an example label we could look at? Google turns up nothing useful on this one.