If you're making soap for sale, there are a few basic things you need to know to keep you in compliance with the industry standard required practices.
Labeling Requirements for Soap
Now, we're just going to be talking about soap here...not cosmetics. For your soap to be viewed as soap in the eyes of the governmental labeling laws, your soap must be real soap - made primarily of oils and lye...and it must not make any cosmetic claims like "moisturizing", "exfoliating", or "deodorizing" - it just has to be soap.
This includes melt and pour soap bases too, as long as they are real soap, made primarily with oils and lye.
Soap falls under the jurisdiction of the Consumer Product Safety Commission which requires the following on the label:
- Wording on the package that identifies the product as "Soap"
- Net weight of product
- Name and address of your business
However, most consumers want to know more about the products they are buying. They at least want to know the ingredients. So most soap makers include them on the labels as well. If you're going to list the ingredients, I recommend you list them per the guidelines of the FDA:
- List the ingredients in descending order of predominance (the % of the total formula)
- List them using the most commonly accepted industry standard names
You can list fragrance as just "fragrance" and you can list any ingredients that are less than 1% of the total formula in any order at the end of the list of ingredients.
One More Consideration
The ingredients that you put into your soap pot, unlike those in a lotion or a cream, go through a chemical reaction. Quite literally, the ingredients that you put into the soap pot are not the same as the ingredients that come out of the soap pot. So, you have a choice. You can either label your soap with the ingredients that are there before the saponification process, or the ingredients that are there after the saponification process.
For example, Ann Bramson's Castile Soap Recipe has:
- 9.6 oz. olive oil
- 22.4 oz. beef tallow
- 10.5 oz. water
- 4.2 oz. lye
- 1.4 oz. of fragrance oil
You can list those ingredients as:
Beef tallow, water, olive oil, sodium hydroxide, fragrance or -
Sodium tallowate (the "salt" made from the combination of the tallow and the lye), water, sodium olivate (the "salt" made from the combination of the olive oil and the lye), beef tallow (there's still some remaining in the soap due to superfatting), olive oil (ditto, from the superfatting), glycerin, fragrance.
See the difference? In the first one, you list the original ingredients including the lye. In the second one, it's the ingredients as they actually are in the soap after the saponification process is done. Notice there isn't any lye in the second one.
Some folks do a sort of hybrid of the two, listing (for the recipe above): Saponified beef tallow and olive oil, water, glycerin, and fragrance. It's theoretically correct, in that it's listing the ingredients, but I tend not to like this one. I think the main reason that people use it is that they neither want to list "sodium hydroxide" as an ingredient nor do they want to (or know how to) label it the more complicated second way.
The Bottom Line
Technically we don't have to list the ingredients. We just have to label it "Soap", say how much it weighs and where to find us. But However, people want to know just what is in their products. That's probably the main reason they're buying handcrafted soap, to begin with. So for that reason, it's best to list the ingredients in the clearest and most easily understood method possible, which is usually the first option, listing the ingredients as they are before the saponification process.