If you want to sell soap in the US, you first have to know the answer to an important question…
“How do you label soap?” In the United States the minimum information required on a true soap label is: The word “Soap”; Net Weight; and Name & Address of Maker.
There is even a little flexibility on the ‘name and address of maker’ part…
With the Web basically replacing phone directories, the laws surrounding label information have changed with the times.
Years ago, you would have to list the soap manufacturer’s:
- Name (person or company responsible for making the soap)
- Street Address
- City
- State
- Zip Code
However, about 95% of US handmade soap manufacturers work out of their home. That means people would be putting very personal information into print for anyone to see. To address this, the US Federal Government allows an exemption as follows…
Soap Label Address Exemption
As long as your physical street address of manufacture is easily locatable on the website operating under your business name, you do not have to place the street address on the label.
This helps ensure your privacy in print. However, most people are not comfortable placing that info on the Web.
For my part, once Google really took off in the early 2000’s it’s relatively easy to find anyone’s address if you spend a few minutes of determined search. That said, placing your company address on your company website is probably not a huge deal for most entrepreneurs.
Do You List Soap Ingredients?
If your soap qualifies as “true soap”, you do not need to list any ingredients. The word “soap” on the label counts as the only ingredient needed. You also do not need the word “ingredients” to appear on the label.
I like to list all ingredients on my soap labels because it seems like the right thing to do. As a consumer I would never buy food that does not list ingredients. Why would I smother the largest organ of my body with something unknown? I wouldn’t.
What is ‘True Soap’?
We have seen the term “true soap” several times without defining it in any depth. Let’s fix that now…
What most consumers don’t realize is that there is “soap” and there is “true soap”. Further, they are NOT necessarily the same thing.
Just about anything that cleans can loosely be called “soap”. This means products loaded with chemical detergents can be referred to as soap – as long as they do not use the designation “true soap” AND they list all of their ingredients on the label.
True soap, on the other hand, is considered a natural cleaner and is exempt from ingredient listing requirements on labels.
The True Soap designation was created to easily identify non-detergent-based soap, making no cosmetic or medicinal claims.
To be considered true soap, your product only needs to meet three simple requirements as follow:
- It must be primarily made of “alkali salts of fatty acids”. This is the result of saponified oils.
- You cannot add any detergents.
- The “alkali salts of fatty acids” must be the only cleaning agent in the product.
- Only the saponified fats and oils can be used in the cleaning process. Added detergents make your product technically a cosmetic.
- The word “soap” must be plainly identified on the label AND its only stated purpose can be to clean.
- If you state that your soap is “deodorizing”, it is now a cosmetic. If you say it relieves itchy skin, it is now considered a drug.
Heads’ Up!
Although you know that your made from scratch soap qualifies as true soap – check any melt and pour you use.
If your melt and pour soap base references “big bubbles” it probably has artificial detergent in it. If this is the case, it does not quality as true soap and must be labeled as a cosmetic. This really boils down to ensuring you list all ingredients in order from greatest to least on the label.
All manufacturers and suppliers of melt and pour should clearly identify their bases as natural or detergent based. If it contains detergent, it is not true soap.
Soap Labeling Video by Marie Gale
Marie Gale is an expert on soap and cosmetic labeling. Following is a 7-minute-long video that explains labeling needs.
Why is the True Soap Designation Important?
True soap is an earned title that means your product meets the requirements of pure cleaning soap with no ulterior motives, artificial detergents or medicinal claims. More and more people are learning what true soap is and why it is important.
Products qualifying as true soap are NOT governed by the US Food and Drug Administration. Instead, true soap falls under the oversight of the Consumer Product Safety Commission (CPSC).
The Don’ts of True Soap Labeling
- Do not identify your soap as anything but soap.
- It is NOT a moisturizing bar.
- It is not a deodorizing bar.
- It is not an exfoliating bar.
- It is SOAP and only soap.
- Do not add any language that can be interpreted as medicinal in nature.
- It is not an eczema reliever.
- It is not identified as “good for your skin”.
- It is not identified as full of vitamins.
- It is SOAP and its ONLY purpose is cleaning.
- Do not list any special ingredient properties that cannot be backed up in writing.
- If you choose to list ingredients, only use terms such as “organic” if you have certified proof of the authenticity of organic origin.
- If you make claims of any kind with ingredients – be ready to prove those claims.
What Soap Ingredients Do I List?
If you use any detergents or do anything else that disqualifies your product as true soap, you must list all ingredients clearly on the label. These should be listed in order of greatest volume to least, in descending order.
Here is the ingredient list for Lever 2000:
Sodium Tallowate, Sodium Cocoate or Sodium Palm Kernelate, Water, Stearic Acid, Cocamidopropyl, Betaine, Sodium Chloride, Fragrance, Sodium Methyl 2-Sulfolaurate, Petrolatum, Sodium Stearate, Disodium 2-Sulfolaurate, Glycerin, Sodium Sulfate, Helianthus Annuus (Sunflower) Seed Oil, Tocopheryl Acetate (Vitamin E Acetate), Tetrasodium EDTA, Tetrasodium Etidronate, Titanium Dioxide.
As true soap you do not need to list any ingredients. If you choose to however, you can list the ‘before’ or ‘after’ ingredients. These are also ‘into the pot’ (before) and ‘out of the pot’ (after).
Here are the ingredients in my favorite handmade “Coconut Shea Butter” soap:
Coconut Oil, Shea Butter, Olive Oil, Water, Sodium Hydroxide (Lye)
Into the Pot and Out of the Pot (Before and After) Ingredients
US Federal labeling laws provide some level of flexibility when labeling your soaps. You can either list what goes into making the soap or the products that result after saponification.
Some people like to list what comes out of the pot because they do not need to list Sodium Hydroxide (Lye). This is because the lye gets used up during the saponification and is no longer present in the soap product.
I prefer to list everything that goes into my soap so there is no misunderstanding about any aspect of the product.
The method you select is up to you. And, of course, you do not even need to list ingredients if yours is true soap.
Should I List Essential Oils and Fragrances?
Technically, you can choose to list all essential oils individually or as a singular or blended “fragrance”. Please keep in mind however that essential oils can do more than generate a scent. Some people have allergies to certain essential oils and others are not recommended for people with certain conditions or circumstances such as pregnancy.
Please list any and all essential oils used in your soap, plainly and visibly on your label.
Common Sense and Common Courtesy When Labeling Soap
When designing my soap labels, I like to put myself in the shoes of the buyer. This means my labels list anything I think would be important to anyone considering my soaps.
Of course, I like pretty fonts and nice images, but I value honest marketing and a clear understanding of the contents far more.
Consider this when labeling…
- It wasn’t until 1994, when I was in my early twenties, that the Nutritional Facts panel started appearing on packaged foods.
- When my mother was in her twenties there were not even laws about having nutritional information posted on food items in the US.
- When her mother was in her twenties, there were no regulations about disclosing any artificial flavoring, coloring, or chemical preservatives on product labels of everyday food items.
- The Food, Drug and Cosmetic Act took care of this in 1938. But before that you were often ingesting items later determined to be poisonous – and the makers did not even have to tell you.
Can you imagine buying something today that did not clearly state every ingredient, provide any potential warnings or other information that could help you avoid becoming ill by the product’s use?
This was everyday reality for our mothers and grandmothers. Let’s not put others in that situation.
In Closing
I hope you enjoyed this post on labeling your soap. Doing so properly will help ensure a positive reputation in the industry and make your customers love you even more!
Now that you have it labeled, check this post to see how to sell it: How Do I Sell My Homemade Soap?
Happy soaping!