Labeling Requirements for Soap
For your soap to be viewed as soap in the eyes of the governmental labeling laws, it must be real soap—which means it is made primarily of oils and lye. Additionally, it must not make any cosmetic claims, such as “moisturizing,” “exfoliating,” or “deodorizing.” It just has to be soap. This includes melt and pour soap bases, too. Soap falls under the jurisdiction of the Consumer Product Safety Commission, which requires the following on the label:
Soap Ingredients
Technically, you do not have to list the ingredients. You just have to label it “soap,” say how much it weighs, and where to find your company. But, in order to make sales and drive a good business, you have to give people what they want to know—and they want to know what is in these types of products. It is likely the main reason your potential customers are buying handcrafted soap to begin with. Therefore, most soap makers include the ingredients on the labels. If you’re going to list the ingredients, list them per the guidelines of the FDA: list the ingredients in descending order of predominance (the percentage of the total formula), and use 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 percent of the total formula in any order at the end of the list of ingredients.
Before-and-After Ingredients List
If you plan to list ingredients, you have a choice of listing the ingredients before processing or the transformed ingredients after saponification or soap-making. 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 in are not the same ingredients that come out. For example, Ann Bramson’s Castile Soap recipe has:
9.6 oz. olive oil22.4 oz. beef tallow10.5 oz. water4.2 oz. lye1.4 oz. of fragrance oil
You can list those ingredients as beef tallow, water, olive oil, sodium hydroxide, and fragrance, which are the ingredients before the process. Alternatively, you can list the ingredients as 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, and fragrance. See the difference? In the first one, you list the original ingredients, including the lye (sodium hydroxide). 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 or sodium hydroxide in the second one. It is best to list the ingredients in the clearest and most easily understood method possible, which is usually the first option by listing the ingredients as they are before the saponification process.
Ingredients List Hybrid
When making ingredients lists, some soap-makers do a sort of hybrid of the two methods listed above. For example, for the same Castile soap recipe, you may see saponified beef tallow and olive oil, water, glycerin, and fragrance. It’s theoretically correct, in that it’s listing the ingredients. The main reason that people use this list is that they do not want to list sodium hydroxide as an ingredient and they do not know how to label it in the more complicated second way.
