soap labeling requirements
Labeling Requirements for Soap
Now, we're just going to be talking about soap here…not cosmetics. For your soap to be viewed
as soap in the eyes of the governmental labeling laws, your soap must be real soap - made
primarily of oils and lye…and it must not make any cosmetic claims like "moisturizing",
"exfoliating", or "deodorizing" - it just has to be soap…that cleans. This includes melt and pour
soap bases too, as long as they are real soap, made primarily with oils and lye.
Soap falls under the jurisdiction of the Consumer Product Safety Commission which requires
the following on the label:
- Wording on the package that identifies the product as "Soap"
- Net weight of product
- Name and address of your business
However, I have found that most consumers want to know more about the products they are
buying. They at least want to know the ingredients. So most soap makers include them on the
labels as well. If you're going to list the ingredients, I recommend you list them per the
guidelines of the FDA:
List the ingredients in descending order of predominance (the % of the total formula)
List them using the most commonly accepted industry standard names
You can list fragrance as just "fragrance" and you can list any ingredients that are less than 1%
of the total formula in any order at the end of the list of ingredients.
- One More Consideration
- The ingredients that you put into your soap pot, unlike those in a lotion or a cream, go through a
- chemical reaction. Quite literally, the ingredients that you put into the soap pot are not the same
- as the ingredients that come out of the soap pot. So, you have a choice. You can either label your
- soap with the ingredients that are there BEFORE the saponification process, or the ingredients
- that are there AFTER the saponification process. For example, Ann Bramson's Castile Soap
- Recipe has:
- 9.6 oz. olive oil
- 22.4 oz. beef tallow
- 10.5 oz. water
- 4.2 oz. lye
- 1.4 oz. of fragrance oil
You can list those ingredients as:
Beef tallow, water, olive oil, sodium hydroxide, fragrance
Sodium tallowate (the "salt" made from the combination of the tallow and the lye), water,
sodium olivate (the "salt" made from the combination of the olive oil and the lye), beef tallow
(there's still some remaining in the soap due to superfatting), olive oil (ditto, from the
superfatting), glycerin, fragrance.
See the difference? In the first one, you list the original ingredients including the lye. In the
second one, it's the ingredients as they actually are in the soap after the saponification process is
done. Notice there isn't any lye in the second one.
And Another Option
I have also seen folks do a sort of hybrid of the two, listing (for the recipe above): Saponified
beef tallow and olive oil, water, glycerin and fragrance. It's theoretically correct, in that it's
listing the ingredients, but I tend not to like this one. I think the main reason that people use it is
that they neither want to list "sodium hydroxide" as an ingredient, nor do they want to (or know
how to) label it the more complicated second way.
Technically we don't have to list the ingredients. We just have to label it "Soap", say how much
it weighs and where to find us. But like I said, people want to know just what is in their products.
That's probably the main reason they're buying hand crafted soap to begin with. So for that
reason, I prefer listing the ingredients in the clearest and most easily understood method possible,
which to me is the first option, listing the ingredients as they are before the saponification
More About Labeling Your Soap
Marie Gale's Soap & Cosmetic Labeling Book
Information on Soap Labeling from the FDA
FDA Article - Is it Soap, a Cosmetic or Both?