Ingredient Labels for Soap

Soap has some interesting labeling issues when it comes to the ingredient declaration.  It can be a chameleon – a consumer commodity, a cosmetic, an insecticide or a drug.

Whether or not the ingredient declaration is required depends on what is is in the eyes of the law, what the ingredients are, and what claims are made about it.

What is it?

Soap can be many things, depending on how it’s made and what claims are made about it.

Is It “True Soap”?

The first thing to determine is whether it is “true soap” as defined by the FDA.  A true soap is one in which “the bulk of the non-volatile portion consists primarily of an alkali salt salt of fatty acids” (according to the FDA regulations). In other words, it is made with lye and oils.

A true soap is exempt from FDA cosmetic regulations, and is the labeling requirements are governed by the Fair Packaging and Labeling act.  The name of the product, net weight and name and address of the manufacturer, distributor or packager are required on the label; the ingredient declaration is not required.

In order to be exempt from other labeling requirements, the only claims that can be made about a true soap are that it is soap and that it cleanses. A true soap can become a different type of product if other claims are made about it.

A soap that is made with primarily with detergents or other ingredients, it is NOT a true soap.  Most, but not all, melt and pour soaps, are not “true soap”.  A soap that is not a true soap is usually a cosmetic.

Is it a Cosmetic?

As noted above, a soap that isn’t a true soap is automatically considered a cosmetic if it’s used on the human body.  However, a true soap can be a cosmetic if a cosmetic CLAIM is made about the soap or one of it’s ingredients.  If you say “contains moisturizing shea butter,” it’s a cosmetic.  If you say it’s a “moisturizing soap,” it’s a cosmetic.

Cosmetic labeling is governed by the FDA.  The label requires the name of the product, what it is, the net weight, the name and address of the manufacturer AND a declaration of the ingredients.

Is It Something Else?

A soap that claims to “repel insects” becomes an insecticide and is governed by the EPA’s labeling requirements.

A soap that claims to “cure, treat, mitigate or prevent disease” or that is intended to “affect the structure or any function of the body” is a drug, and is subject to the FDA drug approval and labeling regulations.  Some common drug claims for soap include: “anti-bacterial,”kills fungi,” “treats or cures eczema,” etc.  Note that if a claim is made for an ingredient in the soap it is still considered a claim for the soap itself, so claiming that it contains tea tree oil which is “known to be antibacterial” can make the soap a drug.

Cosmetic Ingredient Declaration

If the soap is a cosmetic, then the cosmetic ingredient declaration is required. The ingredient declaration must be in descending order of predominance, except that  ingredients at less that 1% can be listed in any order after the ingredients at more than 1%.  There are some other exceptions for FDA approved colorants and multi-product packages.

The ingredients need to use the INCI name or the common name if no INCI name is assigned.  For botanicals, the common name is required; the latin name may be included. It’s important to note that “saponified oil of ____” is NOT a valid ingredient name.

What About Lye?

An ingredient declaration can state what goes into the pot or what comes out of the pot. Since soap has a chemical reaction that occurs, that gives two different ways to present the ingredients.

Into The Pot

In a typical example soap, what goes into the pot is oil, lye, water and additives.  Therefore a valid ingredient declaration would be “Water, palm oil, coconut oil, olive oil, sodium hydroxide, lavender essential oil, and mica”.

The oils could also include the Latin name of the plant.

Out Of The Pot

Using the correct INCI names, what comes out of the pot is mostly sodium palmate, sodium coocate, sodium olivate, lavender essential oil and mica. HOWEVER, there is also  water, glycerin and any unsaponified oils.

The problem with declaring the ingredients based on what comes OUT of the pot is that you don’t (normally) know exactly how much water, glycerin, and unsaponified palm, coconut and olive oils are still in the soap – so you can’t put them in the right order.

Ingredient List When It’s Not Required

Sometimes (often, actually) a soapmaker has a true soap for which no cosmetic claims have been made, but still wants to tell their customers what is in the soap.  Since it’s not a cosmetic, the FDA regulations don’t apply, so there is considerably more freedom in what you say.

In this case, you could use “saponified oils of ___”.  The ingredients don’t necessarily have to be in descending order of predominance – they don’t even have to all be included.

A Note of Advice

If you do decide to put the ingredients on a true soap, be aware that consumers expect that if you say “Ingredients: ____”, you are stating all of the ingredients in descending order of predominance. To withhold ingredients isn’t in violation of the FDA regulations, but it might be considered “deceptive”.

A better way to do it, if you are using non-standard ingredient names (such as “saponified oils of ___”, or are not putting all the ingredients on the list (ie saying “essential oil blend” instead of listing them out), it’s probably better to put it as information, rather than an actual “ingredient declaration.”

Something like “We make our soaps with saponified oils of ___ and scent them with only pure essential oils, including much-loved lavender and patchouli oils.”  That makes it more informative, and the consumer can see that it’s not a true ingredient declaration as they normally expect on cosmetics.


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101 responses to “Ingredient Labels for Soap”

  1. Can a QR code be used on the packaging that links to the ingredients or does the list have to be included on the label?

    • For a cosmetic, the ingredients must be listed on the label. You could ALSO have a QR code on the label.

      For a soap that is exempt from the definition of a cosmetic, the ingredients aren’t required, so a QR code could be used if you wanted.

  2. Can I put “saponified oils” on my recipe? I see dr squatch uses it. Plus they sell small bars for $10 a bar!!!

    • “Saponified oils” is not the correct term to use in the ingredient declaration for COSMETICS. If the soap is a cosmetic, then you can’t use “saponified oils of ___” or “saponified ___ oil.”

      If the soap is exempt from the definition of a cosmetic — that is, it is the alkali salt of fatty acids (lye/oil soap) AND it is only marketed as “soap” (not shampoo, shaving soap, etc) AND only claims to clean (no “moisturizing” etc) … then the cosmetic regulations don’t apply. The ingredient declaration is not required and if you decide to state the ingredients, the cosmetic regulations don’t apply. The primary law/regs that apply in that case are to not be deceptive or misleading in your statements.

  3. Please ma, if I make a cold processed soap that has color additives such as Mica and oxides .. do I have to declare ingredient list .. I know that Mica can contain oxides, etc to get the desired color … But do I really have to include every components of the micas used on my labeling especially when I don’t want to add ingredients list and only want to provide additional information such as ” made of” …. Anyone who sees my soap would obviously know there’s been different color additives added … I need an easy way to go about it considering it’s not a cosmetic but a soap and doesn’t need ingredients list

    • Soap that is exempt from the definition of a cosmetic does not need the ingredient declaration – even if it has colors in it.

      If you choose to identify some of the ingredients (“made of …”) but not all of them, be sure it’s very clear that you are not including all of the ingredients in your statement. Keep in mind that some people have issues with some color additives, so if they see something that looks like an ingredient declaration and see that it doesn’t include their particular sensitivity ingredient, they might have issues.

  4. If I make cold processed soap for my own use as well as to gift to family and friends,can I simply label the ingredients? ,and a possible, a “not for sale” statement?

    • The labeling regulations apply to products that are sold to consumers. If you don’t sell the products and only make them for yourself or as gifts, the labeling regulations aren’t applicable. What you choose to put on the label is your call.

  5. I’m so confused. Lol So if I make Lye soap, with oils of course, it’s technically soap. But if I add colors and fragrance oils does that mean that I now have to label it and list ingredients? I usually add food coloring, goats milk, yogurt and Fragrance or Essential oil blends to it.

    • What makes a soap exempt from the definition of a cosmetic is if the bulk of it is the alkali salts of fatty acids. Addition goats milk, yogurt, color and fragrance doesn’t change the bulk of it. So it would still be exempt from the definition of a cosmetic … providing you only say that it cleans and don’t make any other claims for it.

  6. Hello I have found this all very useful.

    I want to formulate soaps with certain skin types in mind, and will provide transparent ingredient listing on our website, and if possible on our shipping packages, but would like to sell my bar soap itself package free, just stamped with our logo and wrapped in an organic muslin washcloth. Could I give my soap a name that indicates its purpose in a round about way, without making claims but thoroughly list the ingredients and their known properties on my website? For example

    “Oil Slick Soap” (Image of soap with a bunch of eucalyptus leaves. just image no mention of eucalyptus)

    INCI Ingredient listing, followed by detailed info on all the ingredients and what they do on an individual basis. i.e.

    Coconut oil: Coconut oil contains lauric acid which has antimicrobial properties
    oil 2: properties
    Tea tree Oil has antimicrobial properties
    Eucalyptus Oil: properties

    I want complete ingredient transparency, clear information, and package free without breaking any rules.

    • There are several different issues in what you propose here.

      First is the intended use of the product. If the product is intended to treat, mitigate or prevent disease (acne, for example) then the product is an unapproved new drug. It is what the customer (and thefore the FDA) understands as the intended use based on the materials on (label) or with (website) the product. Not only is it what you say about the produt, it is ALSO what you say about the ingredients. So if you say that “coconut oil contains lauric acid which has antimicrobial properties” or “tea tree oil has antimicrobial properties” then you are saying that the PRODUCT is intended to be used as an antimicrobial (making it an unapproved new drug). From the customer and FDA perspective, why else would you include that information?

      Second is the actual labeling of the product. Neither the FDA nor the FTC have provisions for selling completely unlabeled products. That being the case, we must assume that even if there isn’t a label attached directly to the product, all the required information must still be provided to the customer WITH the product when it is purchased, and is available to the customer BEFORE they purchase (so they know what they are buying).

      The FDA does have a provision for omitting the ingredeient declaration from the product label IF the product is only sold mail-order and the ingredients are provided in a very specific manner to anyone who requests them and to the customer when the product is purchased.

      I hope that helps!

  7. Hi Marie, can you please advise me?
    I am importing a container of African black soap from Ghana to the USA to sell on Amazon. The soap ingredients are palm kernel oil, coconut oil, unrefined Shea butter, cocoa pod ash, and purified water, which make it a true soap.
    I have packaged it in a box, and make no claims other than it cleans.
    My customs broker wants to file it for FDA notice.
    I called up FDA to inquire whether this was needed and was told that as it is a true soap, etc, it isn’t regulated by FDA but by the Consumer Product Safety Commission.
    I have a document from Ghana Standards Authority, certifying that it contains only the ingredients stated above..
    My packaging has been designed to meet the necessary soap regulations of the Consumer Product Safety Commission and the FPLA and not those for cosmetics, so I’m concerned.
    If I inform the customs broker that I don’t want them to file for FDA, and instead claim Consumer Product Safety Commission would that be wise?
    Thanks for taking the time.

    • I don’t know the ins and outs of importing products. I do know that soap, if it is true soap and no claims are made (and that includes not only on the package label, but on any website or in any materials that go with the product) — then the soap isn’t regulated by the FDA. The LABELING is regulated by the FTC and the SAFETY is regulated by the CPSC.

      I THINK that when cosmetics (and drugs, and maybe food) are imported to the US, a notice must be given to the FDA so they can inspect and make sure everything is okay. Since the soap isn’t a cosmetic and doesn’t come under the FDA regulations, you certainly don’t want a notice filed with the FDA.

      I don’t have a clue if there are other notices that are required for other products that are imported … does toilet paper or dishwashing liquid require a notice? If so, then soap would need the same sort of thing as it’s in the same category.

      Maybe the customs broker doesn’t understand the differences? There are some pretty good explanations on the FDA website …

  8. Hi, I bought a couple of your books, which have been very helpful. I am wondering if just soap (with no cosmetic or drug claims, can be sold “naked”, without a label at all. I would include info about what it is “soap” and the weight and ingredients for people’s info on my website. I’m trying to go package free. And I guess this goes for cosmetics too, is it possible to provide an online label or must it be physical? thank you!

    • Products must have the information on the package. If you are selling naked soap in a farmer’s market type setting, it generally seems to be okay to put the weight, name and address and what it is on signage … but the information should still go home with the person.

      If you are selling online, obviously putting the details on the website is acceptable. But you do need to provide the consumer with the information. With SOAP, where the label comes off when the product is used, it could be acceptable to put the label information with the product when you ship (like CLOSELY with – attached as a piece of paper). For cosmetics, I would discourage you from omitting a physical label. Creams, lotions, and things in containers need to be identified as to what they are.

      Rather than going for NO packaging, maybe look at ways to reduce down the amount of packaging to as little as possible and selecting sustainable and reusable/recyclable materials.

  9. Hello I’ve been reading info regarding what to put on soap labels and it’s a lot! But to the point can I just put this wording on my soap label
    Company Name
    oils & additives

    • Yes – on the front you also need the net weight, and on the back (or somewhere) you must have the company name and address.

  10. Thank you for all of the information you have shared — in both the post and the comments. So helpful!

    I have a few questions that I hope you can either clarify or point me in the right direction.

    How would you label a cold process soap that is intended to be used as a shampoo bar. Is it okay to call it a shampoo bar? Or would that make it a cosmetic? Would that be more of a descriptor like “can be used on your face or body” instead of a name?

    Also, are you allowed to use the terms that soapcalc (and others) use when describing oil blends like bubbly lather, cleansing, conditioning, hard, long-lasting, and creamy lather? Or is that off limits for soaps?

    And if this information is all contained in your book, I totally understand a “refer to the book for more specifics.” 🙂

    • A soap, to be exempt from the definition of a cosmetic, must be the alkali salt of fatty acids (cold process, for example) AND the be marketed and labeled only as “soap”. If you say it is a shampoo bar or give any other intended use than “cleansing”, then it typically becomes a cosmetic. Words that are used to describe the soap itself (hard, long lasting, etc) normally don’t alter the intended use (although “conditioning might, depending on how it’s used).

  11. could you expand on your statement about most melt and pour soaps not being true soaps. I use a melt and pour soap base whose first three ingredients are coconut oil, sustainable palm oil, and safflower seed oil and of course, sodium hydroxide is listed as well. Would this melt and pour soap base fall under the title of true soap or would it still be considered something else? It is detergent-free, has no sulfates, it has no parabens, alcohol or gluten and is soy-free. What kind of info would I need on my labels considering this base???

    • Most, but not all, MP soaps used to be detergent based and as such were considered cosmetics. Several of the large manufacturers are now making MP soap that is oil/lye based and it is a “true soap”. If the product is marketed only as “soap” and makes no cosmetic claims (only that it cleans) then it would be exempt from the definition of a cosmetic.

  12. Hi Marie
    i was wondering if the Net weight has to be true to the soap or can it say sonething like at No less than 4oz or maybe 4oz or more???

    • The net weight can’t have any “qualifying terms”. That means you can’t put “not less than” or “or more” statements with the net contents.

      The correct way to manage is to put the lowest possible weight that the soap might be (including taking into account water loss over time). See Calculating the Net Weight of Soap (Part 1) as a place to start.

  13. Hi Marie. I’ve recently come across comments on FB stating that adding fragrance and color turns true soap into a cosmetic. I’ve never heard this before and I can’t find anything to back it up, nor has anyone been able to provide me any info to back it up. I know that making a claim such as moisturizing or exfoliating makes it a cosmetic, but why would fragrance and color (if this is true)? Thank you.

    • The definition of a “true soap” (that is, one that is exempt from the definition of a cosmetic) is from the regulations at 21 CFR 701.20(a), which says:

      Soap 21 CFR 701.20(a)
      (a) In its definition of the term cosmetic, the Federal Food Drug, and Cosmetic Act specifically excludes soap. The term soap is nowhere defined in the act. In administering the act, the Food and Drug Administration interprets the term “soap” to apply only to articles that meet the following conditions:
      (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.

      The key here is that the BULK (higest percentage or biggest portion) of the matter in the product is soap. Even when adding fragrance, color or additives, the BULK nonvolatile matter is still soap. Note that non-volatile means that it doesn’t evaporatable, like some fragrances and alcohol).

      Here’s are examples:

      You make a cold process soap and add some salt to it. Since the salt is only a small percentage overall, the product is still soap and exempt from the definition of a cosmetic (providing, of course, that no other claims are made for the product).

      You make a liquid soap and add a large percentage of salt, to make a salt scrub. The BULK of the product is no longer soap, it is salt. Now you have a salt scrub, which IS a cosmetic.

  14. How do I properly label my ‘soap’ using a goat’s milk melt and pour base if I want to label “out of the pot” ingredients? The goat’s milk base has many listed ingredients by the supplier. Would I be labelling properly if I listed a lavender soap as (for example) “Goat’s milk, lavender essential oil, lavender buds”? Or do I have to list all the ingredients that are listed in the goat’s milk melt and pour base plus the essential oil and lavender buds?

    • What comes “out of the pot” is only used when what you put into the pot has resulted in a chemical reaction making a completely new substance (for example oil + lye = soap + glycerine).

      When talking about a melt and pour base, you don’t have enough infoirmation to determine what chemical reactions may have occurred. You really have to go with what you received from the manufacturer, which is what you put INTO your pot. Your ingredient declaration would be all of the component ingredients from the MP base PLUS anything that you added placed in descending order of predominance.

      • Thank you so very much for your prompt reply. I have searched about this a lot and never found an answer this specific or detailed. I appreciate you allowing me to pick your brain!

  15. Hello, I am wanting to sell cp soaps with no claims, raw with a stamp, but no label. I see soaps out there sold this way (Whole foods sells soap in large blocks that you carve off of. How about that?
    Thank you for all of the info!

    • Cold process soaps, sold only as soap and with no claims, are not cosmetics. There are still regulations covering the necessary information to be provided to the consumer … mainly WHAT the product is, the NET WEIGHT (Whole foods probably sells by weight, and they have certified scales to do so), and the BUSINESS NAME AND ADDRESS of the manufacturer or responsbile party.

  16. For the Net Weight, you say it has to state the amount of the product and no less. If I know my product will be no less than 3oz but usually more than that, can I write on my label “3.0+ oz”? to show that it will be at least 3 oz if not more?
    Thank you so much for your information and making it easily understandable for so many people!

    • No, actually you can’t have any qualifying information on the net contents (such as “not less than” or “minimum” or – as in your example “+”). Just put the minimum weight and try to be as accurate as you can.

  17. Hi there, what would solid bubble bath/ bubble bars be classified as? Or what category is bubble bath in general in? Are there any extra considerations for labeling like warnings I need to include?

    • Bubble bath in whatever form is a cosmetic. There are FDA regulations that require a warning label on bubble bath for children. Unless the bubble bath is CLEARLY labeled for adults only (by a statement of “keep out of reach of children” or “for adult use only” on the package), then the following warning must be included on the package:

      “CAUTION: use only as directed. Excessive use or prolonged exposure may cause irritation to skin and urinary tract. Discontinue use if rash, redness or itching occurs. Consult your physician if irritation persists. Keep out of reach of children.”

      If the product is specifically for children, change the last sentence to:

      “Keep out of reach of children except under adult supervision.”

  18. Hi. I would like to begin making soap and I am doing research. So if I use a melt and pour product and add for example Lavender buds, would I include all of the ingredients in the melt and pour product and lavender on the label, or can I just state that the soap is made from a “glycerin” base soap product with lavender added?? I am just beginning and there is a lot to learn. Thanks for your time.

  19. This helps a ton, I have the entire ingredient list of what goes into the pot on my website, I don’t make claims about any of my products, but all of this is on my website. As for the actual packaging of my product, I state what it is, the net weight, and my company name. Is this an alright practice or should I add my address to this as well (note that I work out of my home and don’t entirely feel comfortable adding this little tidbit to the label as compared to just a shipping label. Also, I make other products such as lotion bars and lip balms but I don’t make claims about what it does and I hold to the same methods as I do with my soaps. Because these are slightly different products, should I be more strict with my labeling or what? My business is also entirely online with the exception of when I run a vendor stall, which is like 4 days out of the year. Any information is appreciated! Thank you much!

    • On all of the non-soap products you must include the ingredient declaration (it is required for cosmetic products regardless of what you say about them).

      For the soap, if you have claims on your website or signage that the soap will do anything more than clean, then it becomes a cosmetic and requires the ingredient declaration.

      Both require the business name and address on the label.

  20. I have several soaps curing that I had planned on naming after the fragrance oil used. So my soap that I scented with Tobacco Vanilla fragrance oil I was planning on naming “Tobacco Vanilla.” My soap that I scented with Oatmeal Milk & Honey fragrance, and contains oatmeal, cream, and honey, I had planned on naming “Oatmeal Milk & Honey.” Is this not allowed?

    • The regulation for cosmetics says and ingredient can’t be in the NAME of the product; the regulation for soap says an ingredient can’t be in the IDENTITY of the product. Either way, I would recommend that names like “Tobacco Vanilla” or “Oatmeal Milk & Honey” should be identified as the SCENT — not the NAME or the IDENTITY of the product.

      First, consider the difference between “Oatmeal Milk & Honey” soap that is scented with a fragrance oil and soap that actually contains oatmeal, milk and honey. How does the consumer know? Are they expecting actual oatmeal milk and honey when they purchase your soap? Would they feel tricked or cheated to buy it and find out there isn’t any of that in the product?

      Second, consider a person who is allergic to tobacco or milk. If they don’t know whether the product CONTAINS the allergen or just SMELLS like it, how do they know if they can use the product?

      The point of the Fair Packaging and Labeling Act (which is the law that governs the regulations) is that the person should be able to make a value judgement before purchasing the product. For some one who WANTs oatmeal or who is allergic to tobacco, having the correct information makes it possible for them to decide if the product has value to them.

  21. Hi Marie, I was always under the impression that if we include MICA on the label, we must include the whole ingredient (mica, titanium dioxide, chromium green, magnese violet, tin oxide, etc…). Is that true for soap, lotions, lip scrubs, etc? Or is just “MICA” ok to use?

    • You must list all the color additives that are in any a cosmetic product. Mica itself is a whitish, translucent material. When colored, there are other color additives combined with it. ALL of those need to be listed on the label. Your supplier should be able to provide you with the complete list of components.

    • The FDA regulations for COSMETICS state that the name of an ingredient can’t be included in the NAME of the product.

      The FTC regulations for SOAP (and other products) state that the name of an ingrendient can’t be included in the IDENTITY of a product unless it is present is significant and functional amounts (which are not defined).

      When you call your product “Goats milk soap” there is some question as to whether that is the NAME of the product or the IDENTITY (what it is). How it would be interpreted by an inspector would depend on whether the soap in question was a cosmetic or not and how the presentation of the statement was made on the label.

      In order to prevent ANY confusion, my best advice would be to ensure that the statement about goat’s milk is not part of either the product name OR the identity statement …. put it on the label in such a way that it is completely separate from both the name and the identity (using spacing, color and/or font) and make the statement as INFORMATION about the product – such as “contains goats milk” or “made with goat milk from our farm” or whatever is appropriate.

      If you choose to call it “Goat Milk Soap” then make sure that if it’s not the NAME of the soap (if the soap is a cosmetic) or not the IDENTITY of the soap if it’s exempt from the definition of a cosmetic (and regulated by the FTC).

      • I’m so thankful to have found this blog–such great information! Is “mocha” a slang enough term for chocolate coffee that I could use it in the soap title? How about calling my true soap made with a strong coffee w/grounds, goat milk and lye base “Mocha Isle Soap” then “with goat milk & coffee grounds” underneath in lower case letters? (I live on an island, hence the “Isle,” and it also has cocoa powder, coffee essential oil, and vanilla oleoresin in it.

      • Mocha Isle Soap isn’t really the name of an ingredient … even though it includes “mocha”. It could be interpreted several ways. Putting “with goat milk $ coffee grounds” is a good descriptor (marketing, marketing, marketing!). So long as it is clearly NOT part of the name or identity, it should be okay.

  22. When labeling a product as only soap and not making any cosmetic or drug claims, does the size of the label and size of the font, or even style of font matter? Or is there a specific style and size that is to be used? Any information on this would be super helpful! Thank you!

    • Yes – there are specific requirements for the size of the net contents — if the primary display panel is 5 – 25 square inches (for a rectangular bar of soap, that would be one full side) then the net contents must be 1/8″ high, measuring the lower case “o” for upper and lower case, or the uppercase “L” for all uppercase. There are no specifications ont he font itself … just that the net contents are clear and easy to read, not obscured by any other design … and of the required size. The size is a LOT bigger than you’d expect. Design people generally complain about it!

  23. I use Clear M&P base with mica and fragrance/essential oils for embeds (cubes/curls/shreds) and then pour Goat’s Milk M&P with just fragrance/essential oils over it all (no colorant in the Got’s Milk part). How would I list the ingredient list of both bases/parts properly?

    • You need to list all the ingredients in both the MP bases individually, in descending order of predominance in the whole. It takes some math … See Calculating Percentages for Blended Ingredients for and explanation and example.

      Remember, also, that the alternate way of listing ingreidents is:

      • First: All ingredients present at more than 1% (except color additives), listed in descending order of predominance
      • Second: Ingredients present at 1% or less (except color additives), listed in any order
      • Third: Color additives, regardless of amount

      In your case, it is likely that if you are only using the clear MP base for embeds, then the amount is probably a relatively small percentage of the whole … and that would make the ingredients in it even smaller percentages of the whole — probably most of the ingredients will be present at less than 1% of the whole. that means you won’t have to figure out the exact order, making the math much easier.

  24. I make a soap for the face that is different than my usual recipe and I want to be able to differentiate one from the other without the face recipe being considered a cosmetic. Am I allowed to call it a face soap without it being a cosmetic? I wanted to say something like, “mild soap that can be used on the face, as well as the whole body,” what do you think? Can I even call the soap “mild?” Thanks!

    • Yes, you can call it mild, so long as all you say about what it is used for is to clean. I don’t believe that saying that it is suitable for the face would make it a cosmetic.

  25. Hello, great article and I learned alot. My question is in regards to fragrance and essential oils. When listing fragrances and essential oils on a label, is it okay to say “fragrance ” especially if bought from from a place like bramble berry , or say “essential oil blend” ; a blend that I formulated myself or do I need to list the “list of ingredients from that MSDS sheet” provided by bramble berry? Just wondering how all that information will fit on a tube lets say the size of a lipstick. Thank you for your time.

    • You can either list the scent components as “fragrance” OR list the individual components. Typically fragrance companies don’t disclose the ingredients of their fragrances, so you are stuck with using “fragrance” in the ingredient declaration.

      If you make your own fragrance blend using essential oils, you can either list them all OR just list “fragrance”. “Essential oil blend” is not an approved ingredient name.

      If you make your own fragrance using essential oils and you don’t what to disclose all the ingredients but for marketing purposes you still want the consumer to understand that you use only essential oils, you can put “fragrance” in the ingredient list and then say – somewhere else on the label – that you only use essential oils to scent your product (however you want to word that).

      Note that there is a difference between a FRAGRANCE and a FLAVOR when it comes to lipsticks. The same rules as above apply to flavors — you just use the word “flavor” in the ingredient declaration (not “fragrance”).

  26. Wonderful – I will still to what goes Into the pot like you suggested since those words are most “familiar” I feel. This was immensely helpful and will really help me update my labels. Thank you so much for the very thorough response!

  27. This was a super helpful article! I’m a little stuck on a cosmetic I make with raw honey, vegetable glycerin and 100% Olive Oil, lye and water soap. I’m working with the FDA now and was going to use “Raw Honey, Glycerin and Saponified Olive Oil, Lye and Water. But am wondering if I need to still use the lye? I haven’t had my product tested but wanted to ask in case you had any advice!

    • If you are putting the ingredients on the label in the cosmetic format, then you need to list either what goes INTO the pot or what comes OUT of the pot, in descending order of predominance.

      Assuming that you are using a small amount of honey and added glycerin, the ingredient label would probably be:

      If it’s what goes INTO the pot:

      • water
      • olive oil
      • sodium hydroxide
      • glycerin
      • honey

      (The order of the honey and glycerin would depend on how much you put in.)

      If you are doing what comes OUT of the pot, it would likely be:

      • sodium olivate
      • water
      • glycerin
      • honey
      • monoglycerides
      • diglycerides

      The water is the amount remaining in the product after most has evaporated (usually several percent). Glycerin amount increases because you have not only what you put in, but also the amount in the soap as a result of the saponification process. Monoglycerides and diglycerides are the unsaponified fatty acids (type and amount unknown, so that’s what they are called). If you are doing a high percentage of superfat or lye discount, the amount of mono- and di-glycerides could possibly be higher than the honey or glycerin, depending on your percentages.

  28. Ok, I am selling only soap and am not considering it to be cosmetic. So, I am leaning toward the conversational ingredient listing like this,

    “This soap is made with saponified coconut, olive, sunflower, and safflower oils, and gets its rich colors from coffee and cocoa powder. It contains a fun coffee scented fragrance oil as well as coffee essential oil.”

    “This Cupcake Soap is made with saponified coconut, olive, sunflower, and safflower oils. Its fragrance will remind you of cherries and almonds. Celebrate! ”

    In the Coffee Soap, I mention both the ingredients that colored the soap.
    In the second, I am not mentioning the micas or colorants at all.
    Do you see a problem with that? They are safe colorants that brambleberry sells for soapmaking.

    One more question, I am understanding that using the name of a single ingredient in a product name is only a problem for cosmetics, but not for a simple soap seller? (So, I would be ok with “Coffee Soap” and “Lavender Oatmeal Soap”?)

    Thank you for your time!!!!!!!

    • Those conversational ingredient lists look good!

      For soap exempt from the definition of a cosmetic, the FTC regs say that the name of an ingredient can’t be in the IDENTITY of the product unless it is present in “significant or functional amounts”. The percentage that is “significant” or “functional” is not defined. So if “Coffee Soap” is the IDENTITY of the product (rather than the name), it’s a little gray. … but done all the time. Personally, I suggest NOT putting an ingredient/schent name in the same the place where you say it’s “soap” …. so you’d have an identity of “soap” or “handmade soap” or “luxury soap” or “awesome soap” (etc), then elsewhere you say that it’s “coffee scented” or “smells like coffee” or a picture of a coffee cup or coffee beans — to tell the consumer that it smells like coffee. If you have a product name, it could be “Good Morning!” or “Have a Cuppa” or “Eyes Wide Open” (etc). Like “Cupcake Soap” (no one thinks there are ground up cupcakes in it). Product name is not required, BTW.

  29. Hi Marie,

    Would something like this be okay on the back of a bar of soap with NO cosmetic claims, or do I have to change the “made with” to something even farther away than the traditional “Ingredients:” wording? I’d like to list my ingredients for allergy purposes only.



    • That should work.

      However, your list is per the ingredient declaration except for the wording of the colorants … if you just put the correct ames for the color additives, you wouldn’t have to worry about anyone getting confused.

      • I have made a colorful cupcake soap that has shreds of 5 different colors of soaps grated into the soap.

        For example, one color is a Brambleberry colorant that has this for its ingredient list: Polyester-3, Red 28, Manganese Violet.
        Another is a mica with ingredients: Fluorphlogopite, Titanium Dioxide, Ultramarine Blue, Tin Dioxide.

        If I comply with all the colorants and micas used for the tiny color shreds, I will have a list so long it won’t fit on my soap!!!
        What can I do?

      • Assuming that you are making an ingredient declaration that is compliant with the cosmetic regulations, you need to list ALL of the color additives that are in the soap. The good news is that they can be listed in any order after all of the other ingredients, and if one ingredient is used in two or more of the color additives, you only need to include it once.

        This is an issue that could explain why commercial companies don’t use lots of color additives in one product!

  30. Is it in compliance if we put “mica”? I know there are companies selling mica without saying what is in the mica. How can they not be required to put ingredients but then we must put the ingredients on the soup after mixing? Just curious.

    • Your supplier should provide you with the ingredients that are in any colored micas. Use that and put it in the ingredient declaration. Luckily, since they are color additives, you can put them at the end of the ingredient declaration regardless of the amount used.

  31. When I read the INCI definition for some of the saponified oil terms, like sodium tallowate, I found they included the resulting glycerin and remaining unsaponified fatty acids. It seems to me that this indicates that the glycerin and superfat need not be listed separately and that the order of ingredients would not be affected by the variable saponification rates of different oils. I have seen it widely reported that in order to use these names, it is required to get a laboratory analysis to determine the order of ingredients (some even claim that each batch must be certified based on this lab analysis), but I have been unable to find anything in the regulations to suggest this is the case. It appears to me that since all of the products of reacting lye with a given fat or oil are included in the INCI saponified oil names, it should be simple enough to determine the correct order of ingredients without the need for any laboratory analysis. What is your take on this?

    • First off, sorry for the long lag on answering you!

      The actual definition of Sodium Tallowate, from the Cosmetic Ingredient Dictionary (2nd ed) is “The sodium salt of tallow acid”. Same with Socium Cocoate, it is the “sodium salt of coconut acid”.

      When you add “sodium” in front and “-ate” at the end, you are referring to the sodium salt of whatever it is. In the beginning, the terms were used for very specific fatty acids, as in sodium laurate, sodium palmitate, and sodium stearate. Later, the practice evoloved into using the terms for whole oils (which are actually made up of a number of different fatty acids). As in sodium palmate, sodium cocoate, sodium tallowate and sodium palmate.

      The term refers to the sodium salt of the fatty acids … not the glycerin and not the unsaponified oil.

      When you put the ingredients “out of the pot” on your ingredient list, you do need to take into account the glycerine and the unsaponified oils that are a result of your superfat or lye discount. Getting the soap lab certified is one way to determine the exact amounts. However, you can also calculate the amount of glycerine based on the amount of oil, and the amount of unsaponified oils if you have the exact sap value of the oils you used. And, in actual fact, the unsaponified oils aren’t usually in the form of whole oils (because lye is greedy and takes the fatty acids it wants). According to Kevin Dunn, it’s generally in the form of mono-, di- or tri-, glycerides.

  32. I have been really struggling with how to label the ingredients for a cp soap with mp embeds. Any help would be wonderful! Thank you.

    • You need to list all of the ingredients of the CP soap AND the embeds, in descending order of predominance in the whole. In order to label correctly, you need the percentage of each ingredient in the CP soap, the percentage of each ingredient in the embeds, and the percentage of CP soap and embeds total. From that, you can fig and then figure out their percentage of the whole.

      I’ll do a blog post on it – it will come out next week.

  33. Hi Marie,

    I love your books! Thank you for communicating your extensive research to the soap making community. I have a question that I’m not sure is covered: are images of ingredients considered too suggestive to consumers to use as artwork on front label packaging? For example, I’ve been trying to figure out a way to label my coffee soap, that does in fact include coffee. I know not to call it “Coffee Soap” on the label, but merely using “coffee-scented soap” in the description area doesn’t seem to communicate enough to consumers. I’d like to reinforce that idea with an image of coffee beans, or a coffee plant’s branch. I know this sort of marketing happens all of the time on product labels, but a lot of incorrect labeling occurs all of the time, too (and sometimes by the “big guys”), so I don’t want to perpetuate that sort of behavior.

  34. I feel more confused and overwhelmed after reading your book. I think this site helps clear up some things. I am one of those that gets into trouble with out even trying.

    • Just take it step by step. First thing is make sure you have the BASICS covered … identity of the product (what it is) and the net weight on the front; name and address of the manufacturer on the back (or side). If it’s a cosmetic, then you also need the ingredient declaration. Start with that, then tweak them one at a time to make sure they are in compliance with the regulations.

      • OK, let me get this straight … can I or can I not make and sell M/P soap, as a soap?

      • If the MP soap is detergent-based, it is a cosmetic.

        However, if the soap is the alkali salt of fatty acids (a lye/oil soap) and the only thing you say about it is that it cleans, then it can be considered a soap and exempt from the definition of a cosmetic.


  35. I appreciate your blog and explanations. I hadn’t thought about melt and pour soap not a true soap. I usually do cold process true soap. Thanks again for your informative blog.

  36. Marie, i’ve read your cosmetic labelling book and am left with still a few questions: iif I am making a coffee soap using home brewed coffee, how would I know the amount of coffee that is extracted into the water in order to list ingredients in proper order? Likewise, I make soap with commercial beer, commercially prepared yogurt, and infuse oils with various botanicals. I want to be able to include these ingredients in my list properly. 2). This then leads me to also ask for clarification from p 35-36 of your book, am i not allowed to identify a product as a Coffee, Beer Soap or Goat’s Milk Soap because there are other ingredients? 3) Activated charcoal is thought to be clarifying, but if I’m only adding it to soap as a colorant, then this doesn’t make the list of approved colorants. How would I identify activated charcoal in the ingredients. Most assuredly though, this would be less than 1%. Likewise, I might use annanato seed to infuse oil but wouldn’t know exactly how much of that is retained in the oil infusion. Mi’dsure appreciate your guidance on these items. Thank you.

    • You’ve run into one of the major issues faced by handcrafters in creating correct ingredient labels. I’ll try to give some guidance …

      The regulations state the “common name” is mandatory on the label. For the beer, I would think that “beer” would be acceptable (without listing the ingredients in the beer, which are unknown to you and not on the label – at least on the beers I checked before writing this). Placement on the list should be based on the percentage of beer in the total formulation.

      For the coffee and infused oils, the base in which it is infused (water or the oil) and the coffee or botanical need to be listed separately. If you don’t have actual testing, you’ll have to make an honest estimate of the amount of coffee or botanical constituents remaining in the infused liquid. My guess is that it would be a very small amount once the solids are removed; probably less than 1% of the total.

      So if you had 10 oz of infused oil, you might have 9.9 oz (99%) oil and .1 oz (1%) botanical. If your finished batch is 60 oz, then divide the amount of oil by the total batch size to get the percentage that the oils makes up in the whole batch (9.9 oz divided by 60 oz = .165 or 16.5% of the total batch). Doing the same with the botanical (.1 oz divided by 60 oz = .0016, or .16% of the total batch).

      For a commercially prepared food product (like yogurt) which has ingredients and additives, you’d need to find out what the percentages are of the ingredients and then do the same calculation on them. There is an “incidental ingredient” exemption for listing (see pages 70-71 in the book) which might eliminate the need to include some of the ingredients in the yogurt.

      As for the product names — yes, technically using the name of one ingredient in the name of a product that contains two or more ingredients is not allowed. so “Beer soap”, “Goat’s Milk Soap”, “Coffee Soap” are technically not allowed. Maybe you can figure out a more descriptive name that implies the ingredient or use instead of the actual ingredient name, and then put information about the specific ingredients on an informational panel – “Made with locally micro-brewed beer” or “Contains fresh-brewed Columbian coffee”, for example.

      For activated charcoal, just add it to the ingredient list in descending order of predominance. (And don’t refer to it as a “color” – since it’s not an approved color additive – it’s just an ingredient in the product.

      I hope that helps!

      • Marie, this one confuses me a little.

        “As for the product names — yes, technically using the name of one ingredient in the name of a product that contains two or more ingredients is not allowed. so “Beer soap”, “Goat’s Milk Soap”, “Coffee Soap” are technically not allowed. Maybe you can figure out a more descriptive name that implies the ingredient or use instead of the actual ingredient name, and then put information about the specific ingredients on an informational panel – “Made with locally micro-brewed beer” or “Contains fresh-brewed Columbian coffee”, for example.”

        Does this mean I can’t use only the ingredient as the name for example “Lavender Soap” wouldn’t be allowed, but would “Summer Lavender Breeze” be an acceptable name, or no using any ingredient at all in the name of your soap? Thanks!

      • “Lavender” is trickier than most ingredients because it is a fragrance, a plant and also a color.

        “Summer Lavender Breeze” doesn’t really imply an ingredient … the “ingredient” (if there were one in the name) would probably be “breeze” with “summer” and “lavender” describing it. Can’t add a “breeze” to your soap – so you’re probably safe.

        (Disclaimer – I’m not an attorney, and some FDA official might see it differently. You’d probably have a good case to argue, if it came to that, though.)

      • This reply that you wrote is literally the most clear, helpful bit of information I’ve read on the matter. I cannot tell you how much I appreciate both the original question and the time and knowledge with which you replied. I get that these laws help keep people safe from unscrupulous manufacturers, but it seems as though they mostly make it so the 99% of us who are just trying to make some cool soap need to go to law school!

  37. I’ve read your book twice all the way through and I often refer to it, nevertheless, I still find your articles to be informative and excellent reminders. Please keep them coming and keep up the good work!

  38. Thank you for this information on labeling soaps, I see now where I need to make some changes on my web site of my soap descriptions! Wondering if you sell your books in audio format? I am blind and could scan your book, but it would take much work to do so.

    Thanks again for all you do to help us small business owners!

    • Glad to hear that the information was helpful.

      Sorry, but the books aren’t available as audio books.

      • Regarding melt and pour, are detergent free melt and pour considered soap? If I add fragrances or colorants does that change them to cosmetics? I want to use detergent free melt and pour to make children’s soaps.

      • Usually when a manufacturer or supplier claims a MP soap is “detergent free” it means that it is the alkali salt of fatty acids (lye/oil soap) and is therefore isn’t automatically a cosmetic. It could be exempt from the definition of a cosmetic if there are no claims that the soap will do anything other than clean. Adding colorants or fragrances doesn’t make them a cosmetic.

        If you are making them for CHILDREN, then you have to follow the Consumer Product Safety Commission guidelines for Children’s Products. See this page on the CPSC website which has one paragraph about the requirements for soap for children, which states:

        “Soaps that are primarily intended to be used by children age 12 and under are considered to be children’s products by CPSC. These products must bear a permanent tracking label, and they must be tested for total lead content by a CPSC-accepted third party laboratory. Manufacturers of children’s soaps must issue a Children’s Product Certificate for their products, verifying compliance with these standards.”

        The links in that paragraph can provide you with additional information on the requirements.

        There is a provision for registering as a small business manufacturer, which can give an exemption for third party testing in some cases (and with soap). See Small Batch Manufacturers and Third Party Testing.

  39. This is SO HELPFUL, Marie! I found this chapter of your book to be amazing & constantly refer back to it. It’s great to cross-reference this portion of your book with the more detailed chapters – the Labeling book really is a great resource!

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