What exactly are the regulations re: ingredients

[wetshavingproducts]

I understand that soap doesn't need an ingredients list, but what if a maker decides they want to put one on? Does it have to be accurate and conform to the descending order of ingredients standard?

Can they use a fanciful list that says "this soap contains XYZ oils" and nothing else?

I'm curious because I'm starting to see people doing this.

 

[LBussy]

Just spit-balling here: If a soap had a package that said something like: "Contains Crappleberry Oil" and it otherwise qualified as a soap, the way I read the regs is that's fine and it's exempt. If it said "Contains Moisturizing Crappleberry Oil" that makes it a cosmetic, and needs a proper ingredient list. The things that make a soap a cosmetic are (intentionally) vague so I think if a guy/gal wanted to say anything but "shaving soap" that it would be a Really Good Idea (TM) to have a proper label.

Further, I think if you create a list that looks like an ingredient list, it has to be a real (regulated) ingredient list - otherwise it's deceptive packaging.

 

[cmzaha]

From what I have researched if you list ingredients on the soap package it as to be done in descending order of ingredient of what go into the pot. I also read on, I think it was FDA's site, that the verbage saponified oil xxx is not recognized as proper labeling. If labeling what come out of the pot coconut oil would be sodium cocoate, almond oil, Sodium almondate, etc

 

[wetshavingproducts]

Right, but can anyone link or point me to the regulation?

 

[IrishLass]

http://www.fda.gov/Cosmetics/GuidanceRegulation/LawsRegulations/ucm074201.htm

Scroll down to 'soap'.

IrishLass

 

[LBussy]

Right, but can anyone link or point me to the regulation?

Oh hell, sorry about that. I've spent so much time reading it these past couple weeks I just figured you all did so too

GREAT for insomnia.

 

[new12soap]

Just an FYI, soap is not required to label ingredients (other labeling requirements DO apply!), but shaving soap is a cosmetic and must be labeled as such.

 

[LBussy]

Just an FYI, soap is not required to label ingredients (other labeling requirements DO apply!), but shaving soap is a cosmetic and must be labeled as such.

No ... shaving soap is a soap and not subject to labeling unless cosmetic properties are applied.:

In section 701.20 of Title 21 of the Code of Federal Regulations [21 CFR 701.20], the Food and Drug Administration (FDA) defines the term "soap" as a product in which the non-volatile portion consists principally of an alkali salt of fatty acids, i.e., the traditional composition of soap; the product is labeled as soap; and the label statements refer only to cleansing. If cosmetic claims, e.g., moisturizing, deodorizing, skin softening etc., are made on a label, the product is a cosmetic. Synthetic detergent bars are also considered cosmetics, although they may be labeled as "soap."

ETA: If you go on to say "leaves skin soft", "moisturizes", etc., then it's a cosmetic. If you just say "Shaving Soap" it's no different than "Ivory Soap", "Bar Soap", "Liquid Soap", etc. Say "Moisturizing Soap" and it's all over.

 

[new12soap]

Yep.

The label of a soap can refer only to cleansing. A shaving soap is for shaving; despite being comprised of an alkali salt of fatty acids, its purpose is to assist in removing hair, not cleansing.

 

[LBussy]

The soap does not remove hair, deodorize or condition. It is used as a soap. It makes no claims to do anything but act like a soap.

Had a reference for this but of course I can't put my finger on it at the moment. Perhaps one of the others has it handy. If not I'll look when I get home.

I think all in all it's safest to label every freaking thing.

 

[VanessaP]

Shaving is considered a change to the look of your skin - as in you are using the soap to aid in hair removal process. It is considered a cosmetic if you call it shaving soap and therefore requires cosmetic labeling requirements. If you simply call it a soap and use a witty name like Whiskers Be Gone or Whiskers Away, then that is more neutral territory that I think is really up in the air.

TBH, if you are making soap, you're proud of your ingredients and are probably going to put the ingredients on the soap anyway, so its really not any different than cosmetic labeling in general.

 

[VanessaP]

From Marie Gale's blog at http://blog.mariegale.com/monday-mailbag-2014-07-28/

IF the soap is marketed as something other than soap (as a body wash or facial bar, for example) OR there are any cosmetic claims for the soap (moisturizing, soothing, exfoliating, for example), then the soap is a COSMETIC and therefore requires the ingredients to be listed.

 

[new12soap]

Cosmetic product category codes:

http://www.fda.gov/cosmetics/registrationprogram/paperregistration/ucm111279.htm

"11. Shaving Preparations
Aftershave Lotion
Beard Softeners
Men's Talcum
Preshave Lotions (all types)
Shaving Cream (aerosol, brushless, and lather)
Shaving Soap (cakes, sticks, etc.)
Other Shaving Preparations"

 

[DeeAnna]

Yep, shaving soap is a cosmetic, Lee. It is definitely not sold or used simply to clean the skin. Shaving soap has the commonly accepted functions of softening the beard, making the hairs stand away from the skin, offering lubrication to the razor, and protecting the skin. Not to mention the FDA also has ruled it is a cosmetic, as New12Soap has pointedout.

For my normal everyday soap, I choose to follow cosmetic labeling requirements, I use common names (not INCI nomenclature) per FDA regs, and I use the "what went into the soap pot" approach. Do I need to, since it's Just Soap? Nope, but I think my friends and family have a right to know what they're washing with.

 

[LBussy]

Cosmetic product category codes:

http://www.fda.gov/cosmetics/registrationprogram/paperregistration/ucm111279.htm

Thank you and I stand corrected. It *may* explain why I can't find the reference I thought I had but have you ever KNOWN you read something ... ?

 

[LBussy]

For my normal everyday soap, I choose to follow cosmetic labeling requirements, I use common names (not INCI nomenclature) per FDA regs, and I use the "what went into the soap pot" approach. Do I need to, since it's Just Soap? Nope, but I think my friends and family have a right to know what they're washing with.

This.

Nobody should be ashamed of what goes into the soap and people have a right to know.

 

[LBussy]

Cosmetic product category codes:

http://www.fda.gov/cosmetics/registrationprogram/paperregistration/ucm111279.htm

"11. Shaving Preparations
Aftershave Lotion
Beard Softeners
Men's Talcum
Preshave Lotions (all types)
Shaving Cream (aerosol, brushless, and lather)
Shaving Soap (cakes, sticks, etc.)
Other Shaving Preparations"

Wait hold on ... this does not say that these are cosmetic products, just that when you are (voluntarily) registering these products that you categorize them thusly.

I realize I may sounds like a jailhouse lawyer, not my intent. I deal with the gubmint in other areas and I can think of a lot of instances where I can find a category that's described but not necessarily regulated.

For instance: 02b Bubble Bath, 05f Shampoo (unless it says moisturizing, conditioning), 10a Bath soaps (obviously not detergents) ... these are not regulated products.

 

[IrishLass]

For my normal everyday soap, I choose to follow cosmetic labeling requirements, I use common names (not INCI nomenclature) per FDA regs, and I use the "what went into the soap pot" approach. Do I need to, since it's Just Soap? Nope, but I think my friends and family have a right to know what they're washing with.

I have always done the same, even though I'm not in business. Just like you- I feel my family and friends have a right to know what they are washing with.


IrishLass

 

[IrishLass]

I posted this link earlier in this thread, but I'll post it again in case anyone missed it:

http://www.fda.gov/Cosmetics/GuidanceRegulation/LawsRegulations/ucm074201.htm#Soap

also:

http://www.ecfr.gov/cgi-bin/retriev...60&r=PART&n=21y7.0.1.2.11#21:7.0.1.2.11.3.1.1


IrishLass

 

[LBussy]

I posted this link earlier in this thread, but I'll post it again in case anyone missed it:

http://www.fda.gov/Cosmetics/GuidanceRegulation/LawsRegulations/ucm074201.htm#Soap

also:

http://www.ecfr.gov/cgi-bin/retriev...60&r=PART&n=21y7.0.1.2.11#21:7.0.1.2.11.3.1.1


IrishLass

I read that, but I don't know that it tells us that shaving soap - which is "an alkali salt of fatty acids and the product's detergent properties are due to the alkali-fatty acid compounds," and if it is "labeled, sold, and represented solely as soap" is a cosmetic if we make no cosmetic claims. Helping to remove whisters no more makes this a cosmetic than it would do so for a shaving brush or a razor.

I want to be clear: I want to KNOW the regulation says something. I'd prefer to see an interpretation by the FDC/CPSC. I am labeling my shaving soap even though I am giving it away and this clearly exempts me ... but I'd still like to feel like I have no question about the law and I still do.

I know I can write a letter asking for clarification, and I've done that before to the CPSC, I'd just like to make sure I exhaust the Google-Fu.