Is your soap in compliance with Cosmetic Labeling Requirements?
Wondering what the cosmetic labeling requirements are for your homemade soap? There is not a live stream I have done cutting natural soap where this question doesn’t inevitably appear in the chat. Zakia is your soap good for Acne? Or…my daughter/son has eczema, will your soap help with that? Invariably my answer is always the same. No! The reason for this is simple and its three letters FDA!
Now like many handmade natural soap makers I hear often how my soap has done wonders for people’s skin. I’m always happy to hear them or read them on a testimonial but I never publish them OR repeat them. You see, most soap makers got into handmade soap to control the final bar and carefully select ingredients based on qualities they lend to the final batch of soap. The key is in our ingredients but there is one problem. Soap is meant to clean the moment you step into the category of curing or treating you have created a non-approved drug.
If your soap does anything other than clean, like moisturize, condition, exfoliate etc. it is no longer just a soap but a cosmetic. This requires different standards in accordance with Cosmetic Labeling Requirements.
What to include on your label
To remain in compliance you must include:
- Company Name
- Product Name
- Street Address of Place of Manufacturing
- Weight of the product
- Ingredients in descending order
FDA and Nonapproved Drugs
The FDA has been very clear on soap, cosmetics and drugs. These are three distinct categories our handcrafted products can fall into based on their intended use and what we say in our marketing. I will not attempt to recreate what Marie Gale has published in her book but the standards change for each level. Once you make the claim that your soap cures or treats an ailment your moving it into a drug. Has your soap been tested and approved as a drug? Can your production standards meet those of a pharmeceutical company? If the answer is no, step away from the claims.
What are the consequences of making drug like claims?
Take a look at these 2 recent warnings from the FDA
What to Consider with Cosmetic Labeling Requirements and Product Claims
By making unsubstantiated claims, you open yourself up for inspections, warning letters, fines and more. There isn’t a week that goes by that I don’t get a notice of some bath and body product makers getting their warning letters from the FDA. And trust me the online soaping community loves to put them on full blast as a cautionary tale to other soapers or to throw in a little more shade to their perceived competitors.
Regardless of the reasons the FDA is serious about cracking down on drug claims. Why jeopardize your business for something that you don’t need to incorporate? I know the market seems crowded but that’s a problem with your perception, it’s truly not reality. Your ingredients, your product, your brand does not need to be the latest thread on a soaping facebook group because you get a letter. Focus on quality the rest will come out in the wash.
So does your soap cure acne, alleviate Eczema or treat Rosacea? If it’s not approved by the FDA, your answer should be a resounding NO!
Until next time…