Five Most Common Labeling Errors

Soap and Cosmetic Labeling questions

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.

If you need help, or have questions, see the Soap and Cosmetic Labeling section of the website.  If you can’t find what you’re looking for, there’s even a place to submit your question.



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13 responses to “Five Most Common Labeling Errors”

  1. Could i write a fact about an ingredient without stating it “does” help with a specific skin condition?
    “Sunflower Oil is known to help moisturize dry skin because it naturally has Vitamin E in it”?

    1. Yes, you can write a fact about an ingredient — just remember that the facts/claims you make for ingredients essentially transfer to the product itself. So if you make a claim that “sunflower oil is known to help moisturize”, then the product has a “moisturization” (cosmetic) claim and would need to be labeled as a cosmetic. If you claimed that it “reduced sunburn pain” then it would be a drug claim and would make the product an unapproved new drug.

      You raise an interesting point with the full claim you quoted because of the “naturally has Vitamin E in it”. Vitamins tend to change the body by altering the function or structure of the body. therefore, by combining the vitamin claim with the “moisturizing” claim could result in the implication that the Vitamin E in sunflower oil somehow changes the structure because of the vitamin E. Honestly, I’m guessing here, but it seems probable. Might be better to just say that sunflower oil is moisturizing and/or that it contains vitamin E, but not give a cause/effect statement.

  2. What are the consequences, exactly, for not complying.

    1. Generally if there is a problem, the FDA (or the local state/county inspection person) issues a warning letter. They have the right to stop you from selling products that are misbranded or adulterated and can confiscate product under certain circumstances.

  3. If i put an fda disclaimer can I describe the benefits of essential oils? Something like ‘I am not a doctor all medical issues should he seen and treated by a doctor’ etc. Can I label soaps according to what they are good for ie ‘dandruff bar’ ‘acne bar’ and so on.

    1. An FDA disclaimer doesn’t really make any difference – the FDA doesn’t evaluate cosmetics in at all anyway. As soon as you start describing the potential healing benefits of essential oils that you use in your products, you are essentially making the claim for the product itself. You could probably say something like “plant-based essential oils have a long history of beneficial use and we strongly recommend that you become educated about the ingredients used in our products as well as any other products you use containing essential oils.” that doesn’t make any claims, but encourages the consumer to become educated in general about all products. Recommending a person see a doctor for medical issues is never a bad idea.

      The actual NAME of a product is not regulated. Theoretically you could name a product whatever you wanted – but iof the name implies treatment for some condition (acne or dandruff, for example) then you are walking a VERY fine line. If the FDA has the idea that your are making a claim for the product – or that the consumer thinks that you are making a claim – then you’ve stepped out of bounds.

      Instead of making a claim, or a round-about claim, in the name, maybe saying what skin or hair type the product is for, without making any statement about what it might or might not do. “Oily skin formulation”, “best for dry skin”, “recommended for scalp issues”. It’s still slightly borderline, but not too bad (depending on what else is being said about the product).

  4. Question-obviously aromatherapist make recommendations to use essential oils to aid in relieving the symptoms of health problems. What would be considered the “boundaries?” Can you say that they help with problem skin as opposed to making claims that it will “cure” it?

    1. Unfortunately, right from the get-go, using essential oils to help relieve symptoms of heath problems is treading into the area of medical/drug claims. It’s a very difficult issue for those practicing aromatherapy because almost anything you say to try tom communicate what the essential oil can do (and we know that it can!), is stepping out of the boundaries.

      To say that something “helps” a condition is another way of saying that it could “mitigate” the condition … a drug claim. You might be able to get away with saying a product is “for troubled skin” (rather than saying what it would do for the troubled skin), but even might be interpreted as a drug claim, depending on what else is being said about the product and what the consumer thinks the product will do for them.


  5. Thanks. I think I need a better soap cutter, that might help.

  6. In regards to weights on labels, what do you do if each batch weighs a different amount? My lavender goat’s milk may have 16 bars all of which have varying weights after 4 weeks of curing. My soaps without goat’s milk may weigh less, and still not weigh the same in one batch. How do you choose a weight? I may be selling my soap in a small gift shop, and do not know how quickly they will sell. Do I just take the lightest weight in the batch and use that for each bar? Is it okay to sell different bars at different weights for the same price? My soaps are never over 5 oz, nor under 4 oz.

    Thanks, Melissa

    1. Melissa,

      The safest way is to figure out the lightest weight it could be, and then use that as the weight. It’s okay for the bar to weigh a little more than what is on the label, but never any less.

      It’s understandable that a soaps with different formulations could have a different weight, but the soaps within a batch should be, I would think, pretty consistent. If they vary very much, you might check your cutting procedure to see if you can get bars that have a consistent size (and therefore weight) within each batch.


  7. Thanks for this great post, Marie! Just wanted to let you know that the link at the bottom doesn’t seem to be working. Also, that if anyone was hoping for some help, they should consider your upcoming Labeling class!

    1. You’re welcome – and thanks for pointing out the link issue. I’ve fixed it, so the links are working.

      I’m looking forward to the Labeling Class on October 14th!

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