SeattleMartin, I know your prototype does not include ingredients, which you explained, but within the confines of responses to your request for feedback, it is clear many consumers will forego purchasing a product without an ingredients list. Some suggestions have been made as a way to list ingredients for sale, but the mention of using the phrase '
saponified oils of ...' as an option brings me to point out that this is not the better option when listing ingredients on soap and I will explain why I say that.
Also it will not meet the US federal regulations if you ever sell a soap that can be called a cosmetic or drug by the FDA. IMO, conforming all labels to meet the most restrictive regulations to start will make it far easier in the long run. Granted, you may never sell a cosmetic or medicinal soap, of course. But that would leave out a certain amount of expansion in your business. Case in point: Many male soapers seem to like making and selling shaving soap, and as I read the law, that is a cosmetic by US federal standards, so cosmetic labeling laws would apply.
Further discussion about creating an ingredients list by using the phrase '
saponified oils of...' followed by the list of oils that went into the pot:
Where does this leave the un-saponified portions of those oils? Was the soap made with a superfat? Even if not, are there not still unsaponfiables in soapmaking? Yes, in fact, there are. (Hint - the lower the SAP value, the more unsaponifiables in the oils/fats/waxes.)
Therefore, is the use of 'saponified oils of ...' an accurate or inaccurate method of listing ingredients? I suggest, as do others, that it is inaccurate, and in fact misleading.
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Previous commenters and the same webpage states that soap does not in fact legally have to have an ingredient list at all.
That is irrelevant to my point about using the phrase '
saponified oils of...' in the ingredients list for soap per the quote you sited, therefore I don't understand what point you were trying to make when you made this statement in response to my comment about using the phrase '
unsaponified oils of...' on the ingredients label. Regardless of the fact that I also have stated that the US regulations indicate that ingredients lists are not required for true soap (although is required for cosmetic and medicinal soap).
I have had store owners and customers ask endless questions about INCI labeling and lye and such. Just giving my input as a regional brand and what has worked best for me in terms of selling product. Which is the OP's end goal.
And I am giving input as well, based on my understanding, research and many discussions here at SMF about proper labeling, and from lectures and presentations at various soap maker conventions, seminars, etc. on the topic at hand. I also saw '
saponified oils of ...' being used and when new, thought, sure 'why not?' But that was before learning it is not really the correct way to label soap for sale. And although I don't sell, it was recommended that labeling properly whether one sells or not, especially if one plans to sell eventually, should be the goal at the outset. So for conformity's sake and being the federal regulations geek that my job of my profession made of me, I chose to follow the US federal regulations as best I can and stopped using that term on my soap ingredients list.
I, too, have numerous discussions with people who receive my soap. Most of them had no idea how soap was made, and many of them would ask questions about the process and the ingredients when they learned I make soap. Discussion of the ingredients list is part of the educational process for the customers, which IMO is a good thing. Sadly, I have heard a few soap sellers give mis-information when having these discussions with their customers in the sales setting. It is sad, but true, which is why we often have these discussions here at SMF to help clarify and separate such things as doing it the right way as prescribed by (in this case) federal regulations vs. what seems to be an accepted practice that is not considered the right way per the experts on the regulations in question as they pertain to the topic at hand.
Still, since it works for you and the soap you sell is only sold as 'a cleansing soap' and none can be construed as cosmetic (oh, wait, don't you sell shaving soap, which by definition is intended to improve ones appearance and provide a smooth shave and possibly sooth the skin?) I suppose you can list your ingredients anyway you want.