They are all simple to fix – it’s just a matter of putting the right information in the right place, and making sure that it’s the correct information.
1. Failure to place net contents on the front panel.
The net weight MUST go on the front panel (called the “principal display panel”) of the product. That’s the panel that would typically face the consumer when they are looking at the product trying to decide whether or not to buy. The net weight goes in the bottom 30%, placed parallel to the bottom.
2. Text of net contents not large enough or not in bold text.
The size of type is determined by the size of the principal display panel. If the principal display panel is less than 5 square inches, the type size can be 1/16″, if it’s 5 – 25 square inches, the type size must be 1/8″.
As an idea on the size of the principal display panel, a soap that is 2″ x 2.5″ has a PDP of 5″ inches and a 2 oz boston round bottle has a PDP of 4 sq. inches. Those sizes would allow 1/16″ text. A typical full size bar of soap or a 4 oz or larger bottle would require 1/8″ text.
The actual size of the text depends on the font being used, but Arial 16 pt or Times 18 pt is about 1/8″. Your label designer probably won’t like it … that size looks really BIG!
Also, the net contents must be in bold text, and with about a line-size space above and below.
3. Net weight of soap not allowing for additional water evaporation.
The net weight stated on the product when it is sold to the consumer cannot be more than the actual weight of the product at that time. If you made the soap, let it cure and packaged it when the bar weighed exactly 4 oz, and put “4 oz. net weight” on the package, it would be correct if you sold it right then.
But, as we all know, water continues to evaporate out of soap for quite a while. If you check that same bar in a month or two, the weight will probably be less than 4 oz – even if only a little bit.
So in calculating the net weight for a bar of soap, you need to take into consideration the amount of time it will be before the bar is sold and the expected amount of water evaporation. Then make sure that the stated net weight is less than the lowest weight you think it might be when sold.
4. Using “saponified oils of …” in the ingredient declaration for COSMETIC soap.
While it’s true that soap does contain saponified oils, that term is not accepted for use on a label (and the oils have to be individually listed). If you want to list the saponified oils, you need to use the correct term, which would be, for example, sodium oleate (saponified olive oil), sodium palmate (saponified palm oil), sodium cocoate (saponified coconut oil), etc. Listing it this way, you also must list the glycerin that is in the soap (since it’s not part of the saponified oils), and the water that is retained in the soap (and do so in the correct order, based on the amount in the finished product).
The easiest way is to just list the ingredients that actually went into the soap pot, i.e. palm oil, coconut oil, water, sodium hydroxide and olive oil.
[Update 12 Sept 2021] NOTE: When a soap is exempt from the definition of a cosmetic the cosmetic labeling regulations don’t apply and it could be acceptable to use the term “saponified oils of ….”. See Ingredient Labels for Soap for an in-depth discussion of this point.
5. Making accidental drug claims for the product.
A drug is defined as “a product is intended for use in the cure, mitigation, treatment, or prevention of disease and articles intended to affect the structure of any function of the body.”
We all know that many ingredients and essential oils have wonderful properties, many of which are known to be highly beneficial and even healing. HOWEVER, making those claims in any way that makes the consumer (and thus the FDA) think the product will heal or cure constitutes a drug claim … big no-no.
What to do?
Check your product labels to be sure that you haven’t made any of these 5 most-common labeling errors.