Ingredient Declarations for Soap (US Only)


There has been a lot of discussion over the years about whether an ingredient declaration is required on soap products. Let’s take another look.

Applicable Laws

There are several Acts and laws that apply to the labeling of soap and cosmetics, including the requirements of an ingredient declaration on the product label.

Fair Packaging and Labeling Act

The Fair Packaging and Labeling Act (FPLA), passed in 1968, governs the labeling of all consumer commodities. Consumer commodities are products that are sold to end users who “use up” the product. Soap AND cosmetics AND many other things are used by consumers and are used up: they are consumer commodities. See also What is a CONSUMER COMMODITY?

The FPLA is the LAW (not a regulation). You can find it online (search for “15 USC 1451” or “15 USC Chapter 39”). It requires that every product label include:

  • The identity of the product (what it is);
  • The name and place of business of the manufacturer, packer, or distributor;
  • The net quantity of contents.

The FPLA gives the “regulating body”  the authority to establish all the standards for the label and the option to require ingredients to be listed.

Food Drugs & Cosmetics

The FPLA gives authority to the FDA to establish the label requirements for foods, drugs and cosmetics.

The FDA requires the ingredient declaration on all the products they regulate.

Other Consumer Commodities

The FPLA gives authority to the Federal Trade Commission (FTC) to make regulations for other consumer commodities. (Such things as dish soap, laundry soap, toilet paper, etc.)

The FTC does NOT require ingredients listings for the consumer commodities they regulate.

Truth in Advertising

Finally, no matter what the product, you cannot make false or misleading statements about the product.

Soap: What Laws & Regs Apply?

The first thing to determine for the soap is whether it is a cosmetic or not. Soap is a cosmetic by default because it is applied to the human body to improve appearance or cleanse. However, the Food Drug and Cosmetic Act definition of a cosmetic exempts soap. Confusing? A little bit.

Luckily, the FDA regulations clarify when a soap is exempt. To be exempt, a soap must:

  • Mainly consist of the alkali salt of fatty acids (in other words, it must be a lye/oil soap)
  • Get its cleansing properties from the alkali salt of fatty acids (not added detergents)
  • Be marketed only as “soap”
  • Have no claims that it will have any cosmetic benefits (moisturizing, exfoliating, etc.)

If the soap is a cosmetic, then all cosmetic laws and regulations apply. The ingredient declaration is required and it must meet the requirements in the FDA regulations. Color additives are limited to those specifically approved for use in cosmetics.

But if it’s NOT a cosmetic?

Non-Cosmetic Soap

Also called soap that is exempt from the definition of a cosmetic, or exempt soap, or (slightly incorrectly) true” soap.

The ingredient declaration is not required on a non-cosmetic soap. The cosmetic regulations concerning them do not apply. There are no restrictions on the ingredient naming or other details.

Ingredients? Say Whatever You Want

Well, not quite. The guiding principle is: don’t deceive or mislead the consumer.

Telling your customer which ingredients you use can be a great marketing tool. Savvy shoppers want to know what they are getting so they can compare the value of products. And if you use high-quality ingredients, then it’s great to let your customers know. So go ahead if you want to—there aren’t any regulations (or anything else) saying you can’t market your product by telling what you use to make it.

Don’t deceive or mislead

Deceiving or misleading the consumer means that you lie, omit, or otherwise camouflage “material facts.”  A material fact is one that could affect whether or not the consumer will purchase the product. Staying within the parameters of not being deceiving or misleading, you have several options when it comes to soap and the ingredient declaration.

1) Follow the Cosmetic Regulations Anyway

You could list all of the ingredients just as you would for a cosmetic, following all of the FDA regulations on how to list the ingredients. While not totally simple, it does ensure that the consumer won’t be deceived or misled. Savvy buyers know what the ingredient declaration means and how items are supposed to be listed. If you list the ingredients that way you are well in the clear of any accusations a consumer might throw at you concerning ingredients.

2) List the Ingredients Your Way

You could make up your own way to list the ingredients.  You might use “saponified oils of ___” (which isn’t acceptable in a cosmetic ingredient list). Or you might list “essential oil blend” (which also isn’t acceptable in a cosmetic ingredient list). You could add in descriptive words like “naturally sourced ___” or “plant based ___” instead of sticking to the INCI names.  You might have one label for several soaps and check off the ingredients that are in THAT soap. So long as you aren’t misleading or deceiving the consumer, the field is open here.

3) Highlight Only Some Ingredients

You could highlight the fact that your product contains certain ingredients, but not include the whole list. If you go this way, you need to be very, VERY clear that you are not listing all of the ingredients. Don’t make it an “ingredient declaration” that the consumer expects to include every ingredient. Instead, present it in some different way, making it clear you are highlighting some, but not all, of the ingredients.

Where to draw the line?

So where do you draw the line between being “creative” and being “deceptive or misleading?”

Think about how YOU would feel if you were considering purchasing a soap with that description of the ingredients? Would you feel that the soapmaker was being “tricksy” (as my daughter would say)? Would you wonder if you were getting cheated (maybe it’s all soy oil and just a teensy bit of shea?)  Would you have reservations about buying it because you weren’t completely sure if it was healthy/natural/safe/honest/true?  If YOU would have reservations, then don’t do it to your customers.

Soap and Cosmetic Labeling cover

To really be able to create your own labels that comply with the regulations, get my book from Amazon and use it.


20 responses to “Ingredient Declarations for Soap (US Only)”

  1. Joy Hunley

    I made a soap, that I sell on my store and it gets rid of psoriasis 100%. Can you give me an idea of what the laws are? It’s just Soap. How can I market it?

    1. Marie Gale

      If it’s just soap, you can market it as “soap” and that it cleans. that’s it.

      If it’s soap, you can make claims that it will improve attractiveness, beautify or alter the appearance (including moisturizing) in which case it would be a cosmetic and must follow the cosmetic laws and requirements.

      In no case can you make any claims that it will treat, cure, heal, mitigate, or prevent any type of disease (including psoriasis) or that it will alter the function or structre of the body. Doing so would make it an unapproved new drug and illegal to sell.

  2. THIS is the article I was looking for! My cold press soap is NOT cosmetic. At the end of the ingredients list, can I simply write “Colorants” or “Natural Colorants” instead of listing all the colorant ingredients such as mica, chromium oxide greens, iron oxides, etc? (by US law)
    Thank you so much for providing such great information.

    1. Marie Gale

      If your soap is NOT a cosmetic then the cosmetic regulations–including the specifications for the ingredient declaration–don’t apply. That said, if your “ingredient list” LOOKS like a cosmetic ingredient list, the consumer MAY expect it to include all of the ingredients (which includes all the color additives) and MAY consider it false or deceptive if they find out that everything isn’t actually included.

      If you want to list your ingredients but not include each ingredient specifically, then just don’t make it LOOK like it is a full ingredient declaration. That way nobody is confused about what it is.

    2. Chromium?! Wow. Definitely would not buy that soap! Please label explicit colorant chemicals. Certain ones have allergies associated. More relyctant to buy “natural soap” as a result of this comment.

  3. Jennifer Rowland

    Just found this article. Thanks for the clarification, it can sure be confusing.

    1. You’re welcome!

  4. Is Cold Processed soap considered a soap that is exempt from ingredient declaration ? If it is made from oils/butters and lye ? If not can you give an example

    1. In order for a soap to be exempt from the definition of a cosmetic (and therefore the requirements of the cosmetic ingredient declaration):

      (1) The bulk of the nonvolatile matter in the product consists of an alkali salt of fatty acids and the detergent properties of the article are due to the alkali-fatty acid compounds; and 
      (2) The product is labeled, sold and represented only as soap.

      #1 is covered if the soap is a lye/oil soap.
      #2 depends on how you describe and market the soap. To keep it exempt, it must be only marketed as “soap” and there cannot be any claims that it does anything other than clean. No moisturizing, no exfoliating, no “smooth skin” etc., as those statements would make it a cosmetic and no longer exempt.

      1. Tarey Martin

        For plain old soap made , I see many labels that list the oils as coconut oil, olive oil, castor oil etc. Most do not have an INCI “name”. So….If I’m understanding correctly, you have to use the INCI name for all of your oils, not the common name?

      2. Marie Gale

        The INCI name is the INTERNATIONAL STANDARD. For the US, we generally use the international standard—except for botanical ingredients. In that case, the FDA has said that they want the common English name used first and, if you want, you can put the international scientific name in parenthesis. So they want “coconut oil” or “coconut (cocos nuciferia) oil” NOT just “cocos nuciferia oil”.

        That said, they don’t seem to be doing any sort of enforcement for ingredients that are listed in the international style with the Latin scientific name first.

  5. Love all these tidbits of info.( even us seasoned soapers need a refresh now and again)

  6. For essential oils/fragrance oils can you list them as “fragrance”? Or is more required ?

    1. Yes. Any “smell” components can be lumped under the word “fragrance” in the ingredient declaration.

    2. Donata Cocks

      If I used 3-4 colors in my soap do I list every ingredient for the color?

      Green : Mica, Titanium Dioxide, Tin Dioxide, Green Chrome Oxide, Palmitic Acid, Coconut Oil, Palm Oil, Safflower Oil, Glycerin, Water, Sodium Hydroxide, Sorbitol, Propylene Glycol, Sorbitan oleate, Oat Protein

      Red: Mica, Iron oxide, Coconut Oil, Palm Oil, Safflower Oil, Glycerin, Purified Water, Sodium Hydroxide, Sorbitol, Sorbitan oleate, Soybean Protein

      Gold: : Synthetic Fluorphlogopite,Titanium Dioxide, Iron Oxide, Cocos Nucifera Oil, Elaeis Guineensis Oil, Carthamus Tinctorius Seed Oil, Glycerin, Aqua/Eau/Water, Sodium Hydroxide, Sorbitol, Sorbitan Oleate, Hydrolyzed Soybean Protein

      1. Yes, all of the ingredients in the color additive must be listed in the ingredient declaration for the soap (if it is a cosmetic).

        The color additives can go at the end of the ingredient declaration. Note that “synthetic fluorphlogopite” is not an approved color additive for cosmetics, but it is an acceptable ingredient and should be listed with the ingredients in the soap.

        “Green chrome oxide” should be listed as “chromium oxide greens.”

  7. If then soap is considered a cosmetic- I list ingredients in descending order based on qty in soap blend- is it OK to use common names or must INCI names be used for the ingredients as I am not sure ?

    1. “INCI” is the international standard. You should use it for all ingredients EXCEPT botanicals (if you are in the US). For botanicals, the FDA wants the “common English name” first and then you can put the scientific name (what the international standards use) in parentheses.

      Example: Lavender (lavendula officinalis) bud/flower oil

  8. Gwendolyn Webster

    Thank you, Marie! It is always so beneficial to go over these requirements and to be reminded about what is “regulated” and what is the “law”.

  9. Carmen L Guzman


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