Labeling Your Soap 4

All information in this blog comes from the excellent book “Soap & Cosmetic Labeling” by Marie Gale.

If you make true soap, and you don’t make any cosmetics claims, your soap can be sold without any label.

What?! That was my reaction.

True soap is defined in the Food, Drug and Cosmetic Act as a product in which the non-volatile portion consists principally of an alkali salt of fatty acids.

“In other words, it’s the result of mixing an alkali (usually sodium hydroxide or potassium hydroxide) with fatty acids (animal or vegetable fats or oils or straight fatty acids such as stearic acid).” From Soap & Cosmetic Labeling by Marie Gale

Even though it’s not strictly required, most soap makers want to tell their customers what oils were used in making the soap. What is the correct way to do that?

The simplest way is to list what the FDA calls “starting materials.” This is what you actually put into your soap bucket, for example: Olive oil, coconut oil, palm kernel oil, water, sodium hydroxide, hemp oil, color, and fragrance are the ingredients I used to make the Lavender Flowers Soap in yesterday’s blog. If I were to create a label for my soap, those are the ingredients I could list.

But what about INCI (International Nomenclature of Cosmetic Ingredients) names? Aren’t we supposed to use those?

When it comes to botanical ingredients (plant-based ingredients such as vegetable oils, herbs, essential oils, flowers, or spices), current regulations note the correct way to list botanical ingredients is to use the common English name.

Things only get complicated when you want to make claims, such as that the soap is moisturizing, softening, or has any type of skin care benefits. That makes your soap a cosmetic, and then you must follow cosmetic labeling rules, which are different.

Our advice is always the KISS principle: Keep It Simple, Sam. Soap is a cleansing product, and it’s simplest if you label it as such.