Today I wanted to make a bar of soap containing tea tree essential oil, rosemary oleoresin and clay. All of these things have been marketed for aiding in the prevention and cure of acne. But how does one approach a product that with one misplaced word can land you right in the middle of the OTC drug(over the counter drug) camp? Very carefully.
Consider what you would do in my shoes. What would you call a bar that has clay, tea tree and rosemary in it? A Blemish Bar? Zit Be Gone? While these are great names, those names also make them drugs, not cosmetics.
You also can’t make a label that calls it a cosmetic while verbally saying it will get rid of acne. This is making claims that puts it into drug status.This means you either have to have some fun names or let the reputation of a product make the sales for you. But when asked “Will this get rid of acne?” your best bet is to answer with “No, this is soap.”
So here is my question for you. If you have a product that could be labeled as a drug, how do you keep it a cosmetic and give the product name some creativity? Would you call this soap Dirt from Down Under? Australian Vacation? HELP! In the mean time, come join me for a fabulous soap!
Collect Needed Materials:
Hydrogenated Soybean Oil
French Green Clay
Lye (Sodium Hydroxide)
Tea Tree Essential Oil
|Recipe in Ounces
6 oz Coconut Oil
5 oz Hydrogenated Soybean Oil
5 oz Olive Oil
0.16 oz Rosemary Extract
1 tsp French Green Clay
6 fl oz Water
2.31 oz Lye
0.125 oz Tea Tree Essential Oil
|Recipe in Grams
170 grams Coconut Oil
142 grams Hydrogenated Soybean Oil
142 grams Olive Oil
1 tsp French Green Clay
178 mL Water
65.5 grams Lye
Tea Tree Essential Oil
|Recipe in Percentages
37% Coconut Oil
31% Hydrogenated Soybean Oil
31% Olive Oil
1% Rosemary Extract
Q.S. French Green Clay
Q.S. Tea Tree Essential Oil
Weigh all of the oils into a microwave safe container. Heat gently until liquid. While the oils are heating, measure and add the lye to the water to for a lye solution. Never add your water to your lye. This can cause a dangerous volcano. Safety first! Allow the oil and lye solutions to cool to about 115ºF. This recipe has some materials that can accelerate trace. Lower temperatures help prevent this batch from running away on you.
Mix the oils and lye solution and blend until a light trace is achieved. Add the clay and essential oil and mix well. Pour into a molds and allow to sit for 24 hours. Cut the soap. Allow the soap to cure. If you need help keeping track of your cure times, try our fabulous cure cards. We can even include them into qualifying orders for free! Enjoy your soap!
I’d call it “MALEUCA” sub-text: “with Rosemary & French Green Clay”. If someone asked me if it would cure acne, I would say, “It’s good for everything! Especially stinky feet!” LOL And then go into my bit about why all natural soaps are better than commercial soaps.
I would call it “My Favorite Soap for Blemished Skin” and then go on to say that it contains Tea Tree Essential Oil and Rosemary which are naturally astringent and French Green Clay which is believed to have the power of drawing out impurities and removing toxins from the skin. Both claims are factual.
If asked if it would “get rid of acne,” I would reply that one of the best defenses against blemishes is cleansing regularly with a quality product.
I’d call it ZiTea GriTea Bar Soap: for clearing and smoothing skin
Now that is cute!
In the USA, that would be considered to be making a drug claim, and would be illegal. You cannot claim it *does* anything.
While you are correct the goal of this post is to be aware of the law and that many companies push the envelope, so to say. If we come up with a crazy name then it is name only, just as you said – until we use the verbal side of the coin. Do you have any names you might give this soap? MyTea Soap? Let’s try to find some great names!
Just checking is this rosemary essential oil or rosemary extract?
Taylor used the Rosemary Oleoresin Extract in this soap.
Hello there! I just want to say that, as someone who works in the field of FDA labelling compliance, the care that you’re taking with naming the soap is absolutely necessary and spot on! It’s actually really encouraging to see people having more awareness for those rules, because those kinds of claims can be very misleading. Not making the claims is the best way to avoid misleading or confusing people.
Thank you! We always tell our customers that it’s easier to just say their soap cleans. We don’t want anyone to get into trouble or hurt others!