Soap: Label Requirements

This article applies to soapsold in the United States
and that is exempt from the definition of a cosmetic.

The law covering the labeling of all products is the Fair Packaging and Labeling Act,¹ signed into law in 1966. The Federal Trade Commission administers the FPLA for consumer commodities that are not otherwise regulated. That includes soap that is not a cosmetic regulated by the FDA. See When is Soap Not A Cosmetic?

Product Name

Neither the product name nor the product brand are required on the label.

It is, however, wise to include your product name and brand for the purposes of marketing and branding.

Product Identity

The product identity is what the product IS.

The product identity must be stated by the common or usual name of the product. In the case of a soap that is applied to the human body but is not a cosmetic, the product identity is "soap."² To be exempt from the definition of a cosmetic, it must be labeled and represented only as "soap."

The product identity must beon the FRONT of the packageand be a primary feature of the front panel.³ The type size must be large enough to be easily read and understood by the consumer. It must be placed parallel to the bottom of the package.⁴.

The statement of identity cannot be false, misleading, or deceptive. In particular, ingredients or components which are not present in a substantial or significantly effective amount may not be mentioned in the statement of identity.⁵ For example, if your soap contains only 0.1% shea butter, you could not identify the product as "Shea Butter Soap."

It is acceptable to name an oil or fat in the product identity even when the oil or fat has been saponified into soap in the finished product.⁶

Net Contents

The net content statement tell the consumer how MUCH productt there is in the container or package. The package materials do not count in the amount.

The net contents must be placed on the front of the package and must be stated in fluid ounces and milliliters for liquid products, or in avoirdupois (weight) ounces and grams for solid or semi-solid products.⁷.

The net contents must be reasonably accurate and may not be more than the actual contents.For bar soap it is important to take into account any weight loss that may occur between the time of making/labeling the product and the time it is entered into commerce (sold).

There are additional requirements net contents such as the size of the text, placement of the information, clear space. See Net Contents: General Requirements for a complete discussion.

Business Name and Address

The name of the businessresponsible for the product and the actual physical address must be placed on the label.⁸ It should be the location where business is carried out or the product manufactured.

The business name must be the legal name for the entity. If you are a sole proprietor, you may use a "doing business as" (DBA) so long as it has been registered with your state or county.⁹

The address must include the street address, city, state and zip code.¹⁰ The street addressmay be omitted if it is listed in a readily accessible, widely published and publicly available resource such as printed or online directory, electronic database or website.11If your business address is included in your HSCG online listing, that would be meet the requirements to leave it off the soap label.

The business name and address may be place anywhere on the label. It is not normally placed on the front panel.

For an in-depth discussion of the name and address options, see Business Name & Address on the Product Label

Ingredient Declaration

The requirement to include an ingredient declaration on a product is a cosmetic regulation; it doesn't apply to soap that is not a cosmetic. Putting an ingredient declaration on a soap does not automatically make it a cosmetic.

Since the cosmetic regulations don't apply to a non-cosmetic soap, that means the regulations detailing how to create and display a cosmetic ingredient declaration also don't apply to a non-cosmetic soap.However, there are some more general laws and regulations that DO apply —those having to do with false or misleading advertising.

In other words, just because the cosmetic ingredient declaration regulations don't apply, it doesn't mean you can say whatever you want about the ingredients. You still must be truthful andnon-deceptive in what you say. You can't mislead the consumer. One common way you could mislead the consumer is by putting information on the package that a normal consumer would assume to be a "standard" ingredient declaration (and would therefore assumeit contains all the ingredients) and then omit some ingredients from your presentation.

If you do want to include ingredient information ona soap package, best practice would be either:

1. ) Present the information in an informal, conversational manner which is clearly marketing and wouldn't be confused as a complete and "standard" cosmetic-type ingredient declaration.
   
   For example: "Our soaps are made with olive and coconut oils and enhanced with shea butter" or "Made with saponified olive and coconut oils, and goat milk from our own goat herd."
2. ) Create a cosmetic-compliant ingredient declaration for your soap and use that on the package (even though you don't have to).
3. ) For example: "Ingredients: Water, olive oil, coconut oil, sodium hydroxide, goat milk, lavender oil".
   
   There are some different options for how to create an ingredient declaration for soap since you can use what goes INTO the pot or what comes OUT OF the pot. See Soap: Ingredient Declaration for details.