Soap making is a fun and rewarding business, but it can also be complex, especially when it comes to labeling requirements. As a soap maker, you want to make sure your products are compliant, truthful, and safe for your customers. Proper labeling is essential for building trust and reputation in the soap making industry.
In this post, I will guide you through the essential labeling requirements for your handmade soap products, including ingredient lists, warnings, and product claims. By the end of this post, you will have a better understanding of the importance of labeling and how to stay compliant and protect your customers.
Is your soap in compliance with Cosmetic Labeling Requirements?
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 soap makers my customers send me testimonials that my soap has done wonders for their 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 instead it is a cosmetic. This requires different standards in accordance with Cosmetic Labeling Requirements.
Essential Labeling Requirements
How to list ingredients
An ingredient list is a critical part of your soap labeling. It lets your customers know what is in the soap they are using and if they have any allergies or sensitivities to any of the ingredients. The ingredient list should be accurate and complete, listing all the ingredients in descending order based on their weight.
Making Product claims
Product claims are statements about the benefits, characteristics, and qualities of your soap. They can be about the scent, texture, or moisturizing properties of your soap, for example. You can say things like cleansing, conditioning, moisturizing, improves appearance but you CAN NOT say healing and curing.
When making product claims, it is crucial to be truthful and verifiable. You don’t want to make exaggerated claims or promises you can’t keep. Your customers will appreciate honesty, and you will build trust and credibility in your brand.
Regulations and compliance
There are several regulatory agencies and laws governing soap labeling, including the FDA and the Consumer Product Safety Commission. It is important to stay compliant with these regulations to avoid any legal consequences or fines.
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 you are moving it into a drug. Has your soap been tested and approved as a drug? Can your production standards meet those of a pharmaceutical company? If the answer is no, step away from the claims.
Compliance with labeling requirements shows that you take your business and your customers seriously. It also helps you establish your brand as professional, trustworthy, and reliable.
Key Elements for your product label
Listed below are the baseline elements that should be included on all product labels.
- Company Name
- Product Name
- Street Address of Place of Manufacturing
- Weight of the product
- Ingredients in descending order
Design and Formatting Considerations
Design and formatting play a significant role in soap labeling. Marie’s book goes over the technical requirements for font size, weight requirements and more. Aside from these aspects you want your label to be attractive, easy to read, and clearly showcase your branding. The design should reflect the personality and values of your brand, and the font should be large enough to be easily read.
Think of your label as the face of your soap. Just like a person, it should be well-groomed, clean, and attractive. It should also be easy to understand and convey the information your customers need.
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
What are the consequences of making drug like claims?
Take a look at these 2 recent warnings from the FDA. These were companies that failed to follow the regulations and guidelines for proper labeling or making unsubstantiated claims on the benefits of their products.
What to Consider with Cosmetic Label 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!
Advice for new Business Owners
I’d like to start out by saying congratulations on starting your journey. You have figured out how to make the product and you are now moving into making sure you have a sustainable business. Spend just as much time on the packaging and labeling to ensure you have a viable business that is in compliance. additionally the labeling is what makes the first impression for your customers. Remember first impressions are lasting impressions, put your best foot forward with a proper label that showcases you are truly a professional.
Until next time…
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