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, and what is required to be in it, depends on what is is in the eyes of the how the soap is made 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”.  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.

 

Comments

  1. 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!

  2. 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!

    1. Author

      Glad to hear that the information was helpful.

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

  3. 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!

  4. 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.

    1. Author

      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!

      1. Marie, thank you so much for your time and thorough response. – Michelle

      2. 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!

      3. Author

        “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.)

      4. 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!

  5. 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.

  6. 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.

    1. Author

      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.

  7. 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.

    1. Author

      As far as I know, there hasn’t been any issue with images a product that depict the scent or ingredients.

  8. 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.

    1. Author

      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.

  9. 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?

    1. Author

      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.

  10. 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.

    1. Author

      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.

  11. 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.

    MADE WITH: OLIVE OIL, COCONUT OIL, PALM OIL, WATER, SODIUM HYDROXIDE (LYE), CASTOR OIL, SWEET ALMOND OIL, FRAGRANCE, SKIN-SAFE COLORANTS (SUCH AS MICAS AND OXIDES), GLITTER

    Thanks!

    1. Author

      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.

      1. 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?

      2. Author

        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!

  12. 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!!!!!!!

    1. Author

      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.

  13. 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!

    1. Author

      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.

  14. 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!

  15. 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.

    1. Author

      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”).

  16. 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!

    1. Author

      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.

  17. 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?

    1. Author

      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.

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