Expert Coaching & Consultation
HSCG expert on Business growth
Benjamin Aaron is the HSCG Expert in Business Concepts.
Benjamin Aaron’s entrepreneurial efforts in the handcrafted soap and skin care industry lead him to establishing a retail storefront and a wholesale distribution that reached across the continent and beyond.
Later Benjamin moved on to co-founding and directing a 501(c)3 not-for-profit organization with his wife, Amanda Gail Aaron, called The Lovin’ Soap Project. The mission is to empower women in developing nations with an artisan manufacturing trade: soap and skin care production. The Lovin’ Soap Project solves two of the biggest problems in the developing world; 1) the general lack of hygiene knowledge and implementation and 2) the lack of economic opportunity for women. The Lovin’ Soap Project has conducted artisan manufacturing and business workshop training in Haiti, Uganda, Senegal, India, Tibet, Fiji, and Kenya. To find out more about the project, visit www.lovinsoapproject.org.
With the experiences and knowledge attained from running a successful for-profit soap and skin care company, along with training of dozens of individuals around the world, Benjamin offers his unique perspective on business and artisan manufacturing at www.lovinsoap.com, one of our industries biggest and most practical resources for soap and skin care production and business knowledge.
Benjamin has authored the following books:
For information one-on-one business coaching and consultation with Benjamin, email him at email@example.com.
Benjamin lives with his family in Cocoa Beach, FL. His favorite pastimes are traveling, reading, writing, being on the beach and going on adventures with his wife and children.
HSCG expert on Essential Oils
Regina Bauscher and her husband Steve own and operate Honey Sweetie Acres in Goshen, OH.
Running a successful Agri-business dedicated to producing nature-based skin care. The Bauscher’s have experienced double-digit business growth for the last few years and believe this is directly result of their commitment to helping customers “clean-up” their skin care.
After a career in environmental laboratory work, followed by an Investor Relations role for a Fortune 500 chemical company, Regina’s career fed her curiosity in Essential Oils. Furthering her education, Regina became a certified aromatherapist and continues to pursue in-depth training through the National Association of Holistic Aromatherapy and the Tisserand Institute.
This dedication to quality even extends to their herd of 35 Nigerian Dwarf Dairy Goats, achieving two national championships and multiple top 5 rankings. Her passion is educating consumers on what constitutes clean skin care which includes the safe handling and application of essential oils
HSCG expert on MP & Hybrid Soap
Sharon is the HSCG expert in the area of Melt & Pour and Hybrid (CP/MP) Soap.
Owner of The Great Lakes Natural Soap Company and Places, Sharon is a 15-year soapmaking veteran, soapmaking teacher and speaker. Sharon currently serves as Secretary on the HSCG Board of Directors, as well as being a founder and former President of the Great Lakes Local Chapter. Certified in both MP and CP/HP Soapmaking, Cosmetic making, and an HSCG Certified Soapmaking Teacher, she teaches a full slate of soap and cosmetic classes. Sharon has been a Speaker at every conference since 2014, on topics such as Advanced Melt & Pour Techniques and Hybrid Soaps.
Sharon lives in Canton, Michigan (a suburb of Detroit) with her husband, teenage son and three large, furry dogs. Her family travels whenever possible and spends a lot of time hiking, fishing, swimming and enjoying the outdoors at their cabin in the woods in northern Michigan.
HSCG expert on Product labeling
Marie Gale has amassed nearly 20 years in the handcrafted soap and cosmetic industry. During this time she has had her own soap and cosmetic business selling her products retail, wholesale and private label; served on the Board of Directors and as President of the Handcrafted Soap and Cosmetic Guild, and written three books for the handcrafted soap and cosmetic industry. Her preeminent book, Soap and Cosmetic Labeling, has become an indespensible mainstay for those who want to comply with US labeling requirements.
In addition to speaking engagements addressing soap and cosmetic labeling, her website (www.mariegale.com) provides a wealth of information about labeling and legislation. Marie works remotely as the Webmaster for the HSCG. She and her husband reside in Washington State (just outside of Seattle) with their Doberman, Duke, and orange-tabby cat, George. In her spare time, Marie is researching her family tree.
Lori Nova Endres
HSCG expert on Teaching Classes
Lori Nova Endres, founder & co-owner of www.TheNovaStudio.com, has been a supoorter and proud member of the HSCG since 2005. She has been a presenter at five past conferences on topics ranging from cold process swirling and color soap, to crockpot hot process, to all-natural perfume making.
Her most recent presentation was on how to Make Money Teaching Classes, at our 2017 Conference in Las Vegas. In response to the growing interest in teaching DIY classes, Lori created and published several free resources to help up and coming teachers and an online video course called Make Money Teaching Classes, sharing what she's learned over the last two decades of teaching classes.
Teaching public speaking courses during grad school in 1999 was Lori's first "real" experience teaching, and she was hooked! After obtaining a master's degree in Speech Communication in 2000, she learned to make natural bath and body products to have unique gifts for family and friends. While looking for a job teaching college-level Speech Communication courses, Lori began teaching soapmaking classes in her tiny kitchen in 2001. It seemed only natural to cmbine her passion for this new hobby with her training and love for teaching.
In 2002, Lori opened "The Lavender Room", in Berkeley, CA, and taught classes part-time on weekends. As the demand for her classes grew, she took a huge leap and made teaching crafty classes her full-time career. Lori opened "The Nova Studio" in Point Richmond, CA in 2003 - that featured not only her classes, but also related topics by over a dozen other talented teachers.
For the next 13 years, Lori taught over 1,000 eager students how to make their own natural soap and handmade bath/body products. The Nova Studio was a true gathering place, dedicated to sharing knowledge and teaching classes. It was the longest running dedicated teaching facility with a sole focus on soap, bath and body products, perhaps most well know for their multi-day soap and product making "Boot Camps".
In 2013, she partnered with manager Cassie Durant and fellow teacher Ruth Esteves to form "The Nova Studio, LLC". In 2015, they made the tough decision to close the physical location when Lori's family moved to Louisiana for her husband's job. Since that time, the company and website www.TheNovaStudio.com have continued on and are still going strong (16 years and counting).
The current focus is expanding their "Learn from Home" online learning opportunities, as they continue their mission of ocnnecting students from around the world with some of the best teachers in our industry. They offer live and recorded eClasses (video courses), class handouts, consulting sessions, and many helpful resources for makers.
In 2018, Lori and her family relocated to Beavercreek, OH. In addtion to teaching in-person classes and private lessons in Ohio, Lori also does private consulting on a variety of topics. She loves working with other entrepreneurs, helping them grow their businesses and succeed.
Q & A
Benjamin is available to answer questions submitted by HSCG members concerning Business growth. Use the form below to submit your question. Before submitting a question, please check the existing articles, FAQ and the previously asked and answered questions.
Sorry! Submission of questions to our expert is only available to current HSCG Members. If you are a member, please log in and then submit your question.
Q & A
Regina is available to answer questions submitted by HSCG members concerning Essential Oils. Use the form below to submit your question. Before submitting a question, please check the existing articles, FAQ and the previously asked and answered questions.
Sorry! Submission of questions to our expert is only available to current HSCG Members. If you are a member, please log in and then submit your question.
Q & A
Sharon is available to answer questions submitted by HSCG members concerning MP & Hybrid Soap. Use the form below to submit your question. Before submitting a question, please check the existing articles, FAQ and the previously asked and answered questions.
Sorry! Submission of questions to our expert is only available to current HSCG Members. If you are a member, please log in and then submit your question.
Q & A
Marie is available to answer questions submitted by HSCG members concerning Product labeling . Use the form below to submit your question. Before submitting a question, please check the existing articles, FAQ and the previously asked and answered questions.
Lori Nova Endres
Q & A
Lori is available to answer questions submitted by HSCG members concerning Teaching Classes. Use the form below to submit your question. Before submitting a question, please check the existing articles, FAQ and the previously asked and answered questions.
Answering your Questions
As a general rule how long will an essential scent last in a cold process soap? Thank you!
I apologize for the delay. HSCG had trouble with my experts portal and I could not get into answer until now. Please forgive the delay.
How long an EO will last in cold process is dependent upon the oil used primarily. Citrus oils will lose their scent the fastest, no matter the type. Lemon, Lime, Tangerine, Bergamot....they all will fade usually within 2 - 3 months.
The less volatile the oil, the longer the scent will stay and there are some that are good for a year or more. Some that will stay are Lavender, Spearmint, Eucalyptus, Clove, Citronella, Patchouli, Cedarwood, Frankincense. But it takes at least 5% essential oil in the recipe. If you use 1 - 2% you will not have a lasting scent.
Of course the recipe you use will also affect the EO longevity. If you use heavy butters, like cocoa butter, it can mask EO to a certain degree, reducing the scent. All EO's will have a "slight" scent alteration because of the alkali reaction. Some EO's actually saponify in soap and others do not.
So it is a complex answer with many variables. But overall, with the exception of citrus, you should still be able to detect a scent at 9 months to a year in an EO soap that is made correctly.
Hope this helps!
Honey Sweetie Acres
Hello Regina, I have recently started making cold process soap. Most of the research I've done on essential oils in soap state the use is 1 ounce per pound of soap, or, some calculators state the use is 3% of the total oils in the soap. My test batch recipe is 32 ounces of oil. 3% is about an ounce of EO. By the time my soap cures, there is very little scent. I use primarily USDA certified organic EOs; if not organic, then therapeutic grade. Can I use more EO so the scent will be stronger? Thank you. Mary
Thanks for the question. Because it is a wash-off product, essential oil safety guidelines will allow up to 5%-7% depending on which oil is used. There are some where more caution and dilution is necessary.
If you are using any of the citruses however, they have much lighter molecules and are more aromatic. Aromatic meaning high evaporation rather than more scent. You will lose the scent much faster in any citrus oil. It is a fact that we don't like, but have to respect.
Your recipe will also have an effect. If you are using any butters that are raw and still have a scent of their own (raw cocoa butter), it can mask the EO scent to some degree.
Of course, do a test to see if your EO reacts with alkali, because if it does the batch can accelerate significantly, which can challenge you even if the scent is great.
Some essential oils are simply not meant for soap, either because of cost or because of potential for irritation.
Let me know if you have any other questions!
Hi there! Not sure if this question should go to you or not - but here goes! We are looking into making our own teas, extracts, etc from our herb garden. I have seen several cold process soap recipes that add extracts but I'm having trouble figuring out if these are alcohol based or glycerin based and which step they should be added in (although so far I've read that light trace is the time). Can you help? I can make extracts using either medium I just don't want to end up destroying a test batch or blowing up my lye because I added the wrong type at the wrong time! Any help would be appreciated, Michelle
When I make soaps with teas and plant extracts, I add them into the lye base and do not use alcohol (we avoid it whenever we can). For example, instead of plain water in with lye I will use the tea as the entire water replacement. But I steep the tea to be quite strong if I am using it in soap.
Extracts are tricky and it depends what it is how it is made. We typically do either a water or an oil infusion, simpler to work with in the soap we have found. Too much glycerin will give you rivers. I don't know if you are using goat milk or not and if so, that is where you have to watch our using too much glycerin.
The infused oil will replace all or just a portion of your oils in the recipe. Therapuetic benefit can be obtained with a lessor amount than trying to get the scent from an infusion alone.
Does this help?
I have struggled with Lemongrass EO in cold process soap - often batches are spotty (DOS). I have tried soaping at lower temps. I have changed formulation -- and still having issues. Is there a particular fixed oil that could be interacting with the Lemongrass? Other recommendations you could offer (besides discontinuing the soap)? Thanks in advance
Sorry for the delay in responding, I was out of the country for the last two weeks. I have not experienced the problem you describe with Lemongrass. A couple things to consider:
1). Is the Lemongrass batch fresh or is it aged? With aging can come oxidation and the oil does not perform well in soap once that has happened.
2). Did you get a Certificate of Analysis with the Lemongrass? Lemongrass is frequently adulterated with Citral and you can also get strange results from a high level of that.
3). Never use Lemongrass above a 5% level in your recipe.
4). A good fixative is Atlas Cedarwood and/or Balsam Pine, but of course, it will impact the true lemongrass fragrance.
As I have said I have never had an issue with Lemongrass bars having spots myself, so all that really leaves is the recipe. If you don't mind sharing your ingredients, I can take a look at that.
Hi Regina, In one of your comments, you advised that some essential oils saponify in cold process soap making. Do you by chance happen to have access to any studies that show this? I’ve gone through Kevin Dunn’s Scientific Soapmaking and I’ve yet to encounter an essential oil that actually saponifies when lye is added to them directly. My brain can’t wrap around the possibility of saponification of essential oils as they are not lipid oils. That’s not to say that it can’t happen, as I’ve only tested personally the essentials I have on hand. Which is not a complete list by any means. Any research you have come across that addresses this would be greatly appreciated. Thank you for your time. Kris Boggs
Thanks for the note! It was a published interview between Kevin Dunn and Robert Tisserand and can be found online. Also in a personal conversation, I had with Kevin he pointed out that a form of saponification was possible and gave the example of the Linalool in Lavender being converted into linalyl acetate, which is the more fragrant compound. So essentials oils can undergo a "change". Saponification is also possible because some essential oils do actually contain plant "FATS", they are not entirely aromatics. Kevin did not cite any specific research studies on it. Tisserand states that little research has gone into how essential oils react in anything. For example, we don't know how they react when mixed with synthetic fragrances, because there has not been any definitive research on that topic. Scientists" are more interested in "constituents" because focusing on one ingredient is far less expensive to research. Constituents that have health benefits are of interest to the medical community. Sadly, Tisserand is one of the few reliable sources for essential oil research, but he has focused on therapuetic applications and not soap. That was part of the reason for the interview between them. Kevin spent more time directly on soap.
So to put it simply, any plant "fats" in the essential oils can saponify, but that does not mean 100% of the essential oil will saponify. Make sense?
Hope this helps!
Hey Regina, I hope all is well your way. I have a question I have been looking every where for the answer. When you add vitamin e to an anhydrous product how long can that extend the shelf life? I currently add the vitamin e at 1%. Is there any way to know how long the vitamin e will extend the life of the oils, butters, and essential oils? Thanks so much for your time, and best wishes to you and yours. K. Manaa
Hi Kristen: I apologize for the delay. We have been swamped with the production of hand sanitizer. (Go figure). I just saw the alert email on this.
The answer is, it depends on the type of anhydrous product you are using. Typically 1% is a good amount and most guidelines indicate it will extend the life for 6 months. I don't count on it for an entire year myself because of the interaction of other ingredients. We keep test samples of each product and make note of changes in appearance, texture, consistency, smell, etc. over time. Keeping these is part of Good Manufacturing Practices as you can not always count on a formulation to perform exactly as expected. Hope this helps!
I feel like I use alot of essential oil in my soaps, and then have it come out very mild? Which isn't great for the consumer because it makes the price go up, then the smell isn't as strong as they would like it to be either over time. Is there a way I can blend essential oils to have it smell stronger without using as much?
At what % of the recipe are you using essential oils? It somewhat depends on the oil and not all oils are as skin safe as others. It also depends on the quality of the oil. Do you require COA's on all your essential oils from your suppliers?
Due to the nature of soap and the fact that "some" of the EO's are saponified you can use higher than 1-2%, that is why I ask what you are using.
Citrus oils are very difficult to keep the scent "alive". They are a smaller, lighter molecule so they evaporate faster. Blending them with another citrus does not help very much.
The heavier the density of the oil, the longer it will last (ie: Patchouli).
Are you doing cold process or hot process? The scent will diminish faster in hot process due to the temperature and increased evaporation rate.
So there are many factors in getting a scent to remain. Are you using any butters in your recipe? Butters help retain the EO scent as well.
Let me know your percentages and your process. I can offer suggestions. Thanks for asking!!
What would be the essential oil recommended percentage in Castile liquid soap? I find using pure essential oil in my bar soaps produce a less fragrant soap than using my synthetic-essential blends. I would like to try it in my liquid but want the correct percentage. Thank you!
Thanks for the note. I recommend staying within the 1.5-3.0% essential oils when adding to liquid castile soap. This way we avoid any potential skin reactions with customers. I find this level is aromatic enough without the use of synthetics. I don't' recommend blending them together although I know many people do. Essential oils can react very negatively with fragrance oils that have a petroleum origin, and since they have protection as trade secrets, it is hard to find that out. Hope this helps!
Is Liberty Natural Products a safe place to buy essential oils?
Thanks for the note. Liberty Naturals appears to have a well developed website covering many regulatory issues. A Certificate of Analysis is available with each oil. However, it is incumbent upon you to make sure that the oil will fit your needs by examining the constituents on the COA. If you are purchasing organic oils, be sure to get a copy of their Organic Certification. They say they have it, you just want it on file in your business if you use organic oils. At this point, I do not see any cause for concern. I have personally never used them, but I would not hesitate to purchase as long as I can get the documents. Hope this helps!
Answering your Questions
Hi Sharon! Is it usual for low sweat M&P soap to darken when used in layers with Cold Process?
I have not found this to be the case, and I use low sweat MP exclusively when making hybrid soaps. I do find that all clear MP soap looks darker when combined with cold processed soap, just because the light is blocked when layering. Other reasons could be bleeding colorants, or browning caused by the fragrance oil used.
I am researching for future melt n' pour classes and I would love any advise on how to cool the soap so it can be unfolded quickly. These are make and take/sip n' soap type classes. I have been teaching CP soap making for years but I would like to expand into this less caustic type of classes. Thank you.
I teach this type of class now, and here's what I have found works well. Teach the minimum they need to know to make their soaps at the beginning of the class and have students get their soaps in the mold as early as possible. Then use the remaining class time, while the soaps are setting up, to teach about bases, colors, fragrances, technique, etc. (and enjoy the wine!). Instruct students to keep their soap base as cool as possible, and not to overheat. Use relatively shallow molds, or tell students to only fill large molds halfway. I also provide a lot of different color soap chunks they can use as embeds, which also hardens the soap faster. And if you have access to fans, these help a lot to cool and harden the soaps.
Hope this helps!
Answering your Questions
What's the best way to incorporate batch numbers on products? A separate label or should it be on the product label itself. Is it okay if it is handwritten? Sheri
In big companies, the batch number is included on the label or stamped onto the container when it is filled. For handcrafters, you have several options...
If you make the labels yourself and only print enough for each batch when it is done, then including the batch number when you print should be relatively easy. That looks the cleanest.
If you have labels printed in advance and you have room, you can leave a space for the batch number and then either stick on a label with the batch number or write in the batch number. Keep in mind that if the labels are printed professionally and are on glossy paper or have a UV coating, you won't be able to easily write on the label.
In either case, another option would be to print little stand-alone labels that say "batch number 12345" and stick those on the container/package somewhere.
Handwriting the batch number is fine, so long as it is readable. If you are thinking about taking that option, take into consideration whether a handwritten addition to the label would be appropriate for your brand and your selected target customer base.
Marie, Enjoyed your class. Trying to implement GMP and can't find recommendations re: how long to retain samples of soap, lip balm, bath bombs, lotion, and salts. The only thing I found was a European recommendation that said 1 year after expiration, which makes soap and salts problematic, and we don't usually put expiration dates on the other products. What is your best recommendation? Thank you. Anne
General rule is that retain samples should be kept for 1 year past the end of the shelf life.
For soaps that can last a pretty long time, I'd say keeping 1 year past the reasonable time that a person would hold on to them or use them should be okay.
Nearly all other cosmetic products - particularly those that could be affected by environment/humidity (bath bombs, bath salts), that contain preservatives (lotions, creams), or that have other potential degradation over time (scent dissipation) SHOULD have an expiration date. Even if you don't put it on the package (which I would recommend doing), you should have a standard within your GMP. Kep the retain samples 1 year past that date.
I recently started to use lake colors in my bath bombs, and I am having trouble finding a correct answer on how to properly label them. Can I simply use "RED 40" or do I need to label "FD&C Red 40 Aluminum Lake" or someone had even recently told me I needed to put "FD&C RED 40 LAKE BATCH #12345678. It's safe to say I am more than confused. Any insight you have will be GREATLY appreciated!
You can just use Red 40. You don' tneed to specify the batch number (that is only necessary for manufacturers who are providing the ingredient, not for consumer products).
I am surprised that you are using lakes in your bath bombs since lakes, by definition, are not water soluable.
Hi Marie - Can you point me to the Florida statute that states that home based businesses cant make any product other than soap? For example - no lotions, scrubs, etc. Thanks. Joan King
It's Florida Statutes (here: http://www.flsenate.gov/Laws/Statutes/2013/Chapter499/All):
499.01 Permits: Says "Prior to operating, a permit is required for each person and establishment that intends to operate as: .... a cosmetic manufacturer"
499.012(1)(a) which says "An establishment that is a place of residence may not receive a permit and may not operate under this part."
Cosmetic is defined in 499.003(13)(a): "an article, with the exception of soap, that is intended to be rubbed, poured, sprinkled, or sprayed on; introduced into; or otherwise applied to the human body or any part thereof for cleansing, beautifying, promoting attractiveness, or altering the appearance."
The cosmetic manufacturing laws apply to making any type of cosmetics, which includes lotions, scrubs, fizzies, lip balm, lotion bars, cream, etc. It also includes soap that is marketed as a cosmetic (that is, it claims to do more than just clean, such as moisturize, etc.).
If you are manufacturing soap that is exempt from the definition of a cosmetic (which means that it is the alkali salt of fatty acids and is labeled and marketed only as "soap"), then the cosmetic manufacturing laws don't apply.
We have a 3 store health food chain in nj that carries our bar soap. We have our bar weight listed on our box, but as you know with soap, that weight changes based on cure, cut, etc. So no 2 bars are exactly alike in weight, and our listed weight has to be a blended average. I need help in how to address this, as its jeopardizing our account. I cannot find anything in the NJ weights and measures that even says they can govern this. Help!!!!
The "blended average" is not allowed in the US. That's sort of what the "e" estimated symbol is used for the the EU, but we don't have that option in the US.
The weight on the box is supposed to be the actual and accurate net weight of the product, but there is provision of "reasonable variance" due to evaporation, manufacturing practices, and the like. But even so, the stated net weight CANNOT be more than the actual weight of the product.
With soap, because of the evaporation issue and the unknown variable of how long it will stay on the shelf until purchased, you'll need to calculate the LOWEST weight it COULD be when the consumer purchases.
You can make that calculation mathematically by adding up the weight of all the ingredients EXCEPT the water (for the batch and then divide by the number of bars in the batch).
You can also make that calculation empirically by figuring out the longest amount of time until the product is sold, and then measuring the weight of a bar that has been sitting around in a similar environment for at least that long.
I should have been more specific. Our soaps always weigh more than the weight on the box. What the NJ weights and measures are giving our customer grief over is that it varies, and is not exactly what is on the box on every bar. 1. Do they have the ability to even govern this, i cannot find anything that gives them legal power over soap. 2. Where is the federal law that specifies soap labeling that i can provide to the client? I cant find that.
Generally the Department or Division of Weights and Measures is the one that has authority over the measurement of what it in a package, and the labeling of the packages. New Jersey adopted the Uniform Weights and Measures Regulation and the Uniform Weighmaster Law suggested by the National Insitutes of Standards and Technology Handbook 130. The 2019 version can be found here, but according to the NIST website, they adopted an earlier version. So, in answer to your first question, the NJ Weights and Measures does have legal power over soap because it is a consumer commodity.
The New Jersey packaging and labeling regulations, which can be found here (see page 5). The NJ regulations are easy --- they say to see the NIST Handbook 130, 2018 edition, at IV.A.6 and IV.A.7. The actual text (as of 2019) can be found here, on pages 63-74. The key provisions that apply to your question are :
- 6.3: A declaration of the net quantity shall appear on the principal display panel.
- 6.12: Quantity declaration cannot have supplemental statement (such as "miminum" or "when packed")
- 6.15: The average quantity of contents in the packages of a particular lot, shipment, or delivery shall at least equal the declared quantity, and no unreasonable shortage in any package shall be permitted even though overages in other packages in the same shipment, delivery, or lot compensate for such shortage.
As for the federal regulations for labeling soap - they are found in 16 CFR 500. The paragraphs applicable here are probably 500.25 and 500.26.
I hope that helps you work it out with the NJ Weights and measures and your customer.
I need to create a Material Data Safety Sheet for one of my Customers. I have one for each ingredient in our file, but is there a template that you can create one with your own recipe?
Generally a Safety Data Sheet is for occupational safety and health. It's not for the consumer, but to provide safety information for someone that is working with a chemical or substance in a manufacturing type environment. For finished products, you shouldn't need to provide an SDS. Consider Amazon. They don't require SDS sheets for all of the products they are selling!
If your product is one that the customer is using to make something else, you may need to provide a safety data sheet. Wikipedia has an excellent article on Safety Data Sheets that lays out the requirements SDS sheets (and you can see that they are geared to chemical substances).
If you are wholesaling a product for retail sale, it may be that you need to educate your customer rather than actually make an SDS for your product.
Hi..I bought your book bundle at the conference and watched your video on soap math. I am planning on taking the basic certification and on practice tests and am having difficulty on the math problems. Do you have any video on this or a book I can buy or do you have a class etc? Where are you located?? Sarina
I am located in Washington State, near Seattle. At present I don't offer any classes.
The basic CP/HP Soapmaker certification test requires two kinds of math:
First, calculating the right amount of lye. You aren't required to know the SAP values, they are provided. You just need to know how to do the multiplication and move the decimal point. But first you need to understand what the SAP value is - and that should explain what needs to be multiplied and why. My recommendation: study up on what the SAP value is and how it is used.
Second, calculating the amounts of an oil when you have the percentage and the total (or the amount of another oil for which you know the percentage). For these questions, study up on what percentages are and how to use them to caluclate relative amounts.
Until we get more tutorials up on the website, I am sure you can find something online.
Hi Marie- I am curious to learn more about regulatory requirements when it comes to labeling our soaps. For example, in this recipe (Olive Oil, Sustainable Palm Oil, Water, Coconut Oil, Lye, Shea Butter, Fragrance, Kaolin Clay, Salt), do we have to call out water and lye on the label even when saying saponified oils of...? Thanks, Tom
If the soap is being marketed and labeled ONLY as soap (that is there are NO claims that it will do anything else such as moisturize or soothe), then the cosmetic ingredient declaration requirements don't apply. In that case, you are free to use whatever terminology you want to describe the product and its ingredients, provided only that the information isn't false or misleading.
If the soap is being marketed as a COSMETIC, then the cosmetic regulations DO apply. For cosmetics, the ingredients must be correctly identified. You can list what goes INTO the pot, which would be oils (not "saponified ___"), water, sodium hydroxide and any other additives. Or you can clist what comes OUT of the pot, which would be the saponified oils - which must be identified as sodium ___ate (ie sodium oliveate, sodium palmate, etc), and the additives.
If you are listing the ingredients for a soap exempt from the definition of a cosmetic in a way that is NOT in accordance with the cosmetic regulations, I suggest present it differently so the consumer doesn't assume to understand it in the same way as a cosmetic ingredient declaration
I make and sell a Magnesium Oil that is applied topically and contains magnesium chloride, water and an essential oil blend. Does this product qualify as a nutritional supplement and if so what regulations apply to this? Lately, I've been worried that maybe I am not in compliance with this particular product. Here is my product: https://www.willaminasunshine.com/products/magnesium-oil
Your page says that magnewium benefits the body in many ways. Everything you listed is a physical issue and involves treating, mitigating or preventing disease or altering the function or structure of the body. That definitely disqualifies it from being a cosmetic.
I don't know if it could be considered a nutritional supplement (since it is topically applied) and nutritional supplements are normally ingested. IF it does qualify as a nutritional supplement, there are many, many requirements for supplements and limitations on what you can and can't say. There are also required GMP regulations, facility licensing and approval and other requirements. (Nutritional supplement requirements are a hybrid of the food regulations and the drug regulations.)
Finally, the HSCG insurance doesn't cover nutritional supplements.
You might want to rethink the way you are promoting the product.
Hi Marie, no research has turned up any answers to this question: I have moved my business (and myself) to a new location. I have money invested in old labels (over $1500) with previous business address. Is there ANY possible use for packaging with an old label or is this just outright violation? Can I clearance those soaps, etc? Inquiring minds... I do want to be compliant and I would never sell to stores with old labels. Just wondering before I dump the $$$ in the trash. Thanks, Vanessa
There isn't anything specific in the regulations, but there seems to be a general agreement that there should be a certain amount of time to use up old labels. WORST case is that some inspector is going to tell you that you can't use them; BEST case is that you can use them up quickly, so it's not an issue. While you are using up the labels, be sure there is a forward or some way for people to get ahold of you if they contact you at the previous business address.
Hi Marie, I was wondering if Fizzy Bath Bombs have any special labeling requirements, or are they just treated as regular cosmetics? I would assume so, since I don't seem them listed in your labeling book (3rd edition). Also, do you think Shower Steamers would be treated as a cosmetic too (as far as labeling is concerned), even though it's not something that is intended to contact your skin? Thanks in advance!
Fizzy Bath Bombs don't have any special labeling requirements UNLESS it would be considered a "foaming detergent bath product". In that case, it would need a bubble bath warning. I think if the fizzy is using a surfactant that creates bubbles (not just a citric/soda reaction) then it might be a bubble bath and need the warning.
I would think that a shower steamer would be a cosmetic ... the idea is that the STEAM is coming in contact with the body and doing something. That's a little different than a room freshener or a potpourri. To be on the safe side, I'd suggest labeling as a cosmetic (which really means only putting the ingredient declaration on it) ... all other labeling requirements apply either way.
Hi Marie, Years ago I saw a loophole for using the word organic on the hair products (I make hair gel, shampoo, etc.). As long as I market less than $5000 worth of product annually and adhere to all of the certification standards in the production with the ability to pass a random inspection at any point, you could use the word organic on your labels. What I have never figure out is what they mean by "marketing." For example, I have the same all my products on two websites. For eas lets say they all cost $20 and I have 10 products on each site, so $400 worth of products with the word organic on it. Am I getting this correctly or am I totally missing the mark here? Heres the resource I found: https://www.ams.usda.gov/grades-standards/organic-labeling-standards Thank you! April
The wording on that website page is a little deceptive. When they say "market less than $5,000", they actually mean that the company has an annual revenue from organic sales of less than $5,000. The actual code for that is here: https://www.ecfr.gov/cgi-bin/retrieveECFR?gp=&&r=SUBPART&n=sp7.3.205.b - 205.101(a) - which says:
"(a) Exemptions. (1) A production or handling operation that sells agricultural products as “organic” but whose gross agricultural income from organic sales totals $5,000 or less annually is exempt from certification under subpart E of this part and from submitting an organic system plan for acceptance or approval under §205.201 but must comply with the applicable organic production and handling requirements of subpart C of this part and the labeling requirements of §205.310. The products from such operations shall not be used as ingredients identified as organic in processed products produced by another handling operation."
So it is a loophole, just not quite as big as you might have thought.
Marie, Does your labeling book contain a list of words that cosmetic makers should and should not use when naming/labeling and describing their products ? For example, Don't say: healing. Do say: calming. Or are you aware of another resource that would help me get the terminology correct? Thank you!
There is no set of words that is always correct. It comes down to the intended use - are you saying the product will change the function or structure of the body (that's a drug), or saying that it will just improve the appearance (cosmetic).
"Healing" nearly always implies that it will alter the function or structure of the body somehow. "Moisturizing" is usually considered to be only surface appearance change. "Calming" could be a general descriptive word (more cosmetic) ... unless you are referencing calming someone who is in a psychotic rage, or calming in order to overcome insomina, or calming red inflamed areas of the skin. All those would be claims that the product would alter the function or structure of the body (making it an unapproved new drug).
It's not about the actual words themselves, it's about what your consumer thinks your product it intended to be used for after they have read those words.
Marie, Is it legal to use the words "Aromatherapy Oil" on the label? I am concerned about the word "aromatherapy," as the FDA has mentioned that word on their site in a dubious manner (in quotes), but I couldn't figure out if that actual word is taboo or if the manner in which some aromatherapy products are described is the actual problem. Thank you!
"Aromatherapy" is a broad term with no real specific claim. The FDA is, I think, concerned about the "therapy" part of it. Within the field of aromatherapy it is very easy to fall over into the therapy part and end up claiming that the product is intended to treat, cure, mitigate, prevent or diagnose a disease or the alter the function or structure of the body (which causes the product to be an unapproved new drug).
The word "aromatherapy" or "aromatherapy oil" is unlikely to be a drug claim on it's own.
Remember though, that the claims for the product don't have to be on the label itself. they could be on any accompanying material including signage, brochures, verbal statements, website copy ... even a book placed on your table in your craft booth.
Hi Marie, I'm a cp soap maker opening a zero waste store. On my quest to source liquid shampoo, body wash, conditioner, pet wash and baby wash I found a company that provided me with, in my opinion, an unacceptable list of ingredients. I asked for clarification. Here is the list of two of their products: Distilled water, Organic* Oil Blend including Sunflower* and Olive*, Kosher Certified Vegetable Glycerin*, Soy Protein*, Cetearyl Alcohol, Vitamins A/B3/B5/C/E, Aloe*, Jojoba*, Glyceryl Stearate, Panthenol, *, Plant Based gel agent 100% paraben-free, Rosemary Seed Extract Distilled Water, Organic Hemp Oil, Organic Sunflower Oil, Coco Betaine, Cetearyl Alcohol , Soy Protein, Vitamin E, Xanthan Gum*, Aloe Vera*, Citric Acid*, Plant Based gel agent 100% paraben-free, Rosemary Seed Extract My biggest quip, aside from the extra *, is that they list ALOE in one and ALOE VERA in the other- from doing my own sourcing I have not been able to find aloe..anything that does not have a preservative like sodium benzoate or something else added to it. I asked for the proper INCI name of the MSDS or whatever document they have for that ingredient. This is their response to my request for transparency: All ingredients are on the web site or in the file I sent you. However, soap is not regulated by the FDA so we do not wish to be under stringent guidelines of any sort. If that is the case, then we might not be the best match for you. We make everything by hand and when we use aloe, that's what it is - aloe. That said, we occasionally buy 'systems' of raw materials that are added and we can not always vouch for them, except to say we do our best. QUESTION ONE: Am I being unreasonable? Our mission for this store is based on our feelings around the importance of transparency and we want to present a list of ingredients in the store that is compliant as well as honest. QUESTION TWO: Are they correct in regards to what they say about the FDA? Is shampoo considered soap in the same way CP soap is? Conditioner is a cosmetic, right? I have tested the product and I like it. It's the most natural thing I've found white label on the market, and I would like to carry it. Any advice would be greatly appreciated. Thank you so much.
First, SOAP MAY be exempt from the definition of a cosmetic IF the bulk of it is the alkali salt of fatty acids (lye/oil) AND the detergent properties come from the alkali salt of fatty acids AND it is only marketed and sold as "soap".
Conditioner, shampoo (even "soap" sold as shampoo) and baby wash (even if "soap) are cosmetics. Soap, if any claims to beautify or improve attractiveness are made, is a cosmetic.
From a professional manufacturer, I would expect a complete list of ingredients for the product, correctly identified according to the cosmetic ingredient dictionary. "Plant based gel agent 100% paraben free" is not a suitable ingredient name. You can check for the correct name in the Ingredient Lookup on the HSCG website.
From the response you received, I would gather that they purchase some sort of bulk base to which they add additional ingredients, and they may not get all the data or know how to put there ingredients into the correct order. Not that that makes it acceptable, but it might be understandable.
As you expand your business, my advice would be to ensure that each step in both your business and product development practices is set up in a way that makes it so you can (and do) follow the existing regulations now, and can also expand and still do so.
As an example, it is legal to sell soap (that is exempt from the definition of a cosmetic) and not put an ingredient declaration on it. But down the road, what if you want to repackage or remarket that soap in a different way (maybe claiming that it is "moisturizing")? THEN you would need to have all the ingredients, in compliance with the cosmetic regulations. If you don't have the correct ingredient declaration, then you would be limited in how you market the product.
For example, if you decide to sell soap that is ONLY soap (and therefore doesn't require
We are making a hand sanitizer with the following ingredients: 62% Organic Cane Alchol, Glycerin and Essential Oil. As far as labeling, can we call it "hand sanitizers" or should we avoid that phrase even if we make no claims as to its 99.9 effectiveness. What can we get away with without having to pay for special federal regulations, etc. Thank you!
Hand sanitizers and other anti-bacterial products are considered over the counter drugs. they must be manufactured by a licensed and inspected drug manufacturing facility and meet specific requirements (and testing) to verify their effectiveness against multiple different types of microbes.
As a small manufacturer, you are not qualified nor licensed to make any type of sanitizer for sale to the public. Any product you make cannot be labeled in any way that indicates that it is an antimicrobial of any kind.
Hi Marie, I started my soap making business this year and thought I had all my bases covered. Until I posted a label that I'm working up on Face Book and asked for feed back. I called "Deer Tallow Soap". I had a person post that it was illegal to name a soap based on it's ingredient(s). Is that true. It is true that I can only call it "Handmade or Handcrafted Soap"? Other items on the front of the label are my logo and sometimes pictures and net weight. I also list the ingredients, in descending order by amount, on the back along with the Business name, city, state, zip and lot number, my labels wrap around my soap. Am I OK? What should I change? Thank you, Paulette
There are two parts on the front of the label which often get confused (and often are just plain confusing): NAME of the product and the INDENITY of the product.
The NAME is what it's called - usually something unique to make it stand out from other products in the same category, or from other similar products by the same company. Tide laundry detergent. Kleenex tissues. It is the name that could, theoretically, get a trademark.
The IDENTITY is what it IS. Tide laundry detergent. Kleenex tissues. Aveno hand soap. Method dishwashing liquid.
Where it gets a little tricky is that for cosmetics, the FDA says that the name cannot contain an ingredient (if there are two or more ingredients in the product). So something like "Magic Shea Butter hand cream" wouldn't fly.
Then the FTC (which governs soap that is exempt from the definition of a cosmetic) says that an ingredient can't be included in the IDENTITY of a product unless it's present at "functional amounts" (which is not defined).
The term "Deer Tallow Soap" could be interpreted to be the NAME or the IDENTITY or BOTH --- depending on how it's presented on the label.
My general suggestion is to skip all the confusion and put the ingredient(s) you want to highlight on the front as MARKETING TEXT --- not part of either the name OR the identity. This is made up, but: Woodland Wonders natural handcrafted soap made with Deer Tallow.
- NAME: Woodland Wonders
- IDENTITY: natural handcrafted soap
- MARKETING: made with deer tallow (could have more explanation or marketing)
The key is to make sure that the marketing text is CLEARLY not part of the name or identity by placement, font, color, etc. I asked an FDA agent about that and he said "it would be evaluated on a case by case basis - there are no specific standards".
Hey Marie, I have tried to look this up and have gotten several different answers so I thought I would ask the expert. When making products that have well-researched benefits like magnesium, turmeric, or even some oils can we add those facts to posts or sales descriptions without crossing that line into the drug category? In no way do I want to make a medical claim about my product but like my buyers to understand why I have added it into my recipe.
Any statements that the product or the ingredients can/will/might alter the function or structure of the body gives the product the intended use of a drug ... thereby making it an unapproved new drug. If you added those ingredients because of potential benefits that could alter the function or structure of the body, then your original intention for the product was such that it IS an unapproved new drug.
Only cosmetics can be made without prior approval from the FDA. I strongly suggest that you review the intended use of your product and the definition of a cosmetic and make sure you stay within the legal limits.
On the other hand, there is nothing saying you can't include those ingredients --- you just can say that they (or the product) will alter the function or structure of the body. You could say something along the lines that you have "carefully selected" your ingredients top create the best possible product... but you have to rely on your customers knowing or looking up the benefits somewhere else.
Hello! I currently make cold process soap and occasionally use melt and pour soaps for embeds. What is the best way to list the ingredients for these soaps? It seems as though the ingredient list would be extremely long to fit on the label. Thanks!
You still need to list all of the ingredient - even if that does make a long label. The good news is that if you are using the MP for embeds, most of the ingredients in the MP will probably be 1% or less of the whole, so you can list them in any order after the ingredients present at more than 1%. Any any ingredients in the MP that are already in the CP don't need to be additionally listed.
Hello Marie! I actually have a question about Shampoo Bars. I have been asked to make them but have held back. The reason is, I thought I read in either one of your books or in this website that Shampoo Bars had to be tested for a year before selling according to the FDA. Since I see numerous sellers making & selling Sydnet & SCI bars online, I wonder if I have this information wrong? Thank you Karen
A shampoo bar is a cosmetic and, at a federal level, it doesn't require any pre-approval or official testing before being sold. That said, you obviously are responsible for ensuring that your product is safe to use.
As it is a cosmetic, you can't make any claims that it would treat or cure anything (like dandruff, for example). Otherwise, there are no real restrictions.
If you are in Florida, or another state that requires cosmetic manufacturers to get registered or licensed, you would need to follow the state regulations for your manufacturing --- but the product itself doesn't require any pre-approval.
How does one label infused oils, such as olive oil infused with calendula flowers?
An infused oil is a "blended ingredient'. List the component parts - olive oils and calendula extract. The calendula extract is what is left of the calendula after you take the flower petals out of the oil.
Normally the amount of actual extact is less than 1% of the whole, so it can be listed in any order with other ingredients that are present at 1% or less. The olive oil would be listed in the order based on the percentage of the olive oil in the whole formulation (in descending order of predominance).
Hello Marie, If I decide to add the ingredients to a true soap label, even though it's not a requirement. I know it should then follow the FDA labeling rules, but for the colorant section can I just put something like "natural, and FD&C or D&C approved colorants" or would it still have to follow the FDA regulations and have to be the way it would on a cosmetic label (ie titanium dioxide, FD&C Blue 1, FD&C Red 40). Thank you! -Aleks
If you decide to add the ingredients to a soap that is exempt from the definition of a cosmetic, the cosmetic regulations don't apply. That said, you need to make sure that you aren't misleading the consumer in any way. If the ingredient declaration LOOKS enough like a normal cosmetic ingredient declaration that the consumer expects it to provide the same information, then it might be considered misleading if you omit information.
My personal opinion is that if you are going to place the ingredients on the label in a way that looks like a cosmetic ingredient declaration, then it should be a complete listing of ingredients with the ingredients identified in the standard way. If I were to look at an ingredient listing on a soap and saw that it had wrongly identified ingredients (like "natural colorants" or "FD&C approved colors") ... I'd run. If you're going to list them, why not use the correct names?
By the way, the correct names to list the colors you mentioned are Blue 1 and Red 40 (you don't need to put the "FC&C" or "D&C").
Hi Marie! I am preparing to start selling cold process soap in a local metaphysical shop. We have created bars using certain colors, herbs, and FO/EO in mind to market them as magical tools to use in shower or bath. I would like to market it as just soap so I do not have to disclose what herbs I used in my "magical blend" as I would like to keep that information proprietary. My concern is that I cannot just sell it as soap but that by making the claim for the magical uses I would fall under the cosmetic category. I also want to make sure that I am not falling into another area where I need to make caution. By law we have to post that we make no claims that the spells we create will work and everything is for "entertainment purposes" only. Would I need to add that to my labels? I also have a website where I sell these soaps and other soaps without the magical intent. Could I just disclose it there? I am new to selling, just launched the website a couple of months ago and this will be my first in-person point of sale. I am in Los Angeles, CA. My website is www.elementalvegan.com. Thank you so much for your help. Linda Snovak
I think whether the soap falls into the cosmetic category depends on what claims you are making for the soaps themselves. If the claims show that the intended use is to beautify or improve attractiveness, then they would be cosmetics.
If the "spells" are "for entertainment purposes only" then don't think they would be claims for the effectiveness or intended use of the soap. I am unfamiliar with the requirment for the disclaimer for the spells.
(Before I start a massive relabeling project as well as letting one of my private label customers know about fixing their labels:) You recently posted that Rosemary Oleoresin Extract should be properly listed as Rosemary Leaf Oil. I looked at the product information sheet at Majestic Mountain Sage (my supplier) and they list the INCI name as 'Triglycerides of Caprylic/Capric Acid, Rosmarinus Officinalis (Rosemary) Leaf Extract, Mono- and Diglycerides'. Is Rosemary Leaf Extract an acceptable designation for my labels?
It's a little hard to determine exactly what the MMS product is. The Cosmetic Ingredient Dictionary doesn't contain "Triglycerides of Caprylic/Capric Acid" or "Monoglycerides" or "Diglycerides".
The CID does contain "Caprylic/Capric Triglyceride" which is defined as "the mixed triester of glycerine and captylic and captic acids" (also known as fractionated coconut oil).
I would guess that what you are getting from MMS is rosemary leaf extract in fractionated coconut oil (more than 50% coconut oil, based on the placement of the ingredients).
If that is the case, then your ingredient declaration should list Caprylic/Capric Triglyceride and rosemary leaf extract. You should check with them, though, just to be sure.
Hey Marie! So I followed your suggestion and emailed MMS, this is how they replied: "You have a good question. Since we source both Rosemary Oleoresin products from the food industry, they have different terminology. Therefore, I have included the compositions for both below. Hopefully, this will help you." (They have a 2% and 5% version.) I use the 5% product so: 75-85% Sunflower Oil, High Oleic INCI: Helianthus Annuus (Sunflower) Seed Oil 15-25% extractives of rosemary INCI: Rosmarinus Officinalis (Rosemary) Leaf Extract So, I would list as: Sunflower Seed Oil, Rosemary Leaf Extract in the appropriate place, yes? Thanks for the help, you are awesome!!
Yes - list both in the ingredient declaration, based on their percentage of the whole.
Example: Your formulation calls for 2% of the MMS product. That would end up being 1.5-1.7% sunflower oil and .3-.5% rosemary extract.
As a note, ingredients present at 1% or more must be listed in descending order of predominance. Ingredients present at 1% or less may be listed in any order following those present at 1% or more. (Makes it easier for ingredients with very small percentages --- you just need to know if it's more or less than 1% in order to place it correctly.)
Hello, Marie. I was told that you may be able to give some insight or point me in the correct direction. I make Spa products, soap, salts, scrubs, etc. I sell online as well as at events. I am looking for an NAICS code for my business. In reviewing the information on NAICS codes, I do not want to get stuck on manufacturing as who regulates manufacturing of these products - where they can be manufactured, in what type of facility, etc. Any help you can give is greatly appreciated. - H.B.
Manufacturing is probably the right NAICS code category. I wouldn't worry about cross-over on regulation because of the code you choose. There's an excellent article in the HSCG How-To Library - NAICS Codes.
Hello Marie, regarding EPA registration for insect repellants... I have the 2015 list of "active ingredients eligible for miminal risk pesticide products". Am I correct that Lemon Eucalyptus oil is NOT exempt from FIFRA so to include Lemon Eucalyptus Oil in a product labeled as an insect repellant, it must be registered by the EPA? If so, do you have an understanding of the process to register an insect repellant - the cost, bureaucracy, time required? Thank you!
Correct - Lemon Eucalyptus oil is NOT included in the list of "minimum risk pesticides" ... so it is not considered a proven safe pesticide by the EPA.
The pesticide approval process is a big deal. You can probably imagine what requirements are if you think about a company inventing, testing, and proving toxicity levels and safety for the plant pesticides you see in the garden department of Lowe's or Home Depot. There are details on the EPA website for the new pesticide approval process, but I haven't studied up on them.
It would probably be easier to petition for the inclusion of Lemon Eucalyptus oil in the minimum risk pesticide list, but it would still need proof (by scientific study) of effectiveness and safety. I don't know what the process is for getting items on the minimum risk list is.
Question regarding preservatives. Is it correct to just include the INCI ingredients of a preservative and not the common name? For example Optiphen is phenoxyethanol, Caprylyl Glycol. Can I just list the INCI for this ingredient? Thanks!
For preservatives you need to list all of the ingredients of the preservative - NOT the brand name. So for optiphen, your ingredient declaration would include "phenoxyethanol, caprylyl glycol".
Hello Marie, I am using a 7 oz glass jar for Bath Salts. Can I use a round label on the bottom of the jar with all the information?
A label can be used on the bottom for the data required on an informational panel (the ingredients, directions and business name and address). You still need a label on the principal display panel (the front) that gives the name of the product, what it is and the net weight.
Hi Marie, on the ingredients do I write Lavender essential oil, or just essential oil? Also, I am a hobbyist, do I write my name, last name, address and phone after writing ingredients and directions on the back panel? Thank you so much.
You can list the essential oil by exact name ("Lavender Oil") or you can just state "fragrance" (that's your call).
If you are selling your products, you need your "business name" (if you have not registered a business name with your state, then it's your personal name) and your full address (street, city, state and zipcode). Phone is not required, but there's no reason you can't include it if you want to.
You also need (if you are selling) the net weight (for solid products) or volume (liquid products) on the front of the product.
Hi- I have the opportunity to obtain a large quantity of organic olive oil with trace (less than 1%) organic essential oils (but up to 50 different ones- and I won't know which ones are included out of the 50+/-). I'm obviously not able to put 50 essential oils on my labels, and I'm wondering how/ if I can make this work? I make salves to donate, but I also would like to use the olive oil (with trace EO's) for other products. Any advice?
If there is enough of the essential oils to give a fragrance, you could identify them as "fragrance" in the ingredient declaration.
However, they might actually qualify as incidental ingredients, under definition 1: "A substance that has no technical or functional effect in the cosmetic but is present by reason of having been incorporated into the cosmetic as an ingredient of another cosmetic ingredient."
K.F. again. So because there's less than 1% of the trace essential oils in the olive oil, I don't need to list the "trace essential oils" at all? Thanks!
No, it's not because it's less than 1% of the trace essential oils. It's because the trace essential oils appear to be incidental ingredients to the products you are making with the olive oil. One of the definitions of an incidental ingredient (the one which might fit here) is:
Substances that have no technical or functional effect in the cosmetic but are present by reason of having been incorporated into the cosmetic as an ingredient of another cosmetic ingredient.
Components that meet the definition of an "incidental ingredient" do not need to be included in the ingredient declaration.
Of course, generally incidental ingredients ARE less than 1%, but that's not the reason they can be omitted from the ingredient declaration.
hi- this is KF. thanks for your earlier response. i do have a few more follow-up questions: If the oil blend that i'm using with the trace EO's does not have a fragrance, then I just list it on the label as "certified organic extra virgin olive oil with trace incidental essential oils"? Is that legit? is that how (legally) I can word it on the label and be correct? thanks
That wouldn't be legit. It really sounds like they would be considered "incidental ingredients". In that case you just omit them entirely from the ingredient declaration .. you'd just list "olive oil" (no "certified organic extra virgin" (descriptors shouldn't be included in the ingredient declaration). You can asterisk the olive oil and note below the ingredient declaration as a footnote that it's organic.
Answering your Questions
You mentioned in your podcast on figuring out your time for teaching a class you should send the students home with a "finished product" as in ready to give as a gift. How would you di this with CP soap as it can't really be unmolded an cut? I had tought about sending them home with a small "loaf" in a lidded plastic food container with instructions on how to unmold & cut it at home..
Hi Tom, ahhh great question! When I said that, I was thinking about what we sent students home with for about 90% of our classes - finished products, nicely packaged & ready to use or gift. For soap made from scratch, that's certainly the exception & much more difficult. For our 2-day soapmaking bootcamps at The Nova Studio, we used to have a batch of the exact same soap (recipe, color, scent, & additives) all made & fully cured (ready to use). Students would get a bar of that & also a bar of the batch made in class (Saturday about noon) that was unmolded & cut at the very end of the bootcamp (Sunday about 5pm) to take home & cure. Having a batch pre-made & cured obviously involves more time/effort on the part of the teacher, but I love that students didn't have to wait to use at least one bar. For teachers of a single CP soap class that's 2-3 hours long (for example), doing what you suggested is the way to go. A small loaf type (reusable) plastic container that would hold the equivalent of a few bars, or you can also purchase clamshell type molds (that have a lid) for individual bars. I hope this helps to clarify what I said - and good catch... thanks for listening to the podcast first! ~Lori
I am trying to take the basic certification classes for soap making but having difficulty with math problems on the test.. do you do any consultation on just the math portion?
Hi Sarina, thanks for your question! This isn't exactly in my wheelhouse, since it doesn't involve teaching or product making, but I have taken/passed both the certification tests for soapmaking, so I could definitely help you with studying for the test.
Before I suggest a private consultation however, I want to make sure you've seen & reviewed all the resources the HSCG has available. It took me a little while to find them, but they can be found on the "Certification Program" page (be sure you're logged in first) here: https://www.soapguild.org/members/certification/overview.php
On the right-hand sidebar in blue, look for "Soapmaking Certification" and click on "Basic." That will open up this page: https://www.soapguild.org/members/certification/soap/basic/basic-overview.php
If you scroll down, under the title "Study Materials" you'll find two links. One to "Basic Terms & Definitions" https://www.soapguild.org/members/certification/soap/basic/basic-terms.php and another to "Basic References & Resources" https://www.soapguild.org/members/certification/soap/basic/basic-references.php
On that last page/link, you will find a link to a video called "Math for Soap & Cosmetic Handcrafters" by Marie Gale that might be helpful to you: https://www.soapguild.org/how-to/make-soap/math-and-measuring.php
You will also find practice tests for each test/topic on the blue sidebar (right-hand side). The one for CP/HP Basic Practice Test is here: https://www.soapguild.org/members/certification/soap/basic/basic-cp-test-US.php
For anyone wanting to pass the test, I recommend you do as many practice tests as possible, noting/studying the questions you get wrong for further study. I believe the questions are randomly included in the practice tests, so the more you take, the more questions you can see/study.
Hope this is helpful! Feel free to contact me at firstname.lastname@example.org - and if you'd like to book a video/phone consult at the HSCG discounted rate, you can do so through the my expert page here.
I am new to the guild and have a specific question regarding the making of bath bombs. Does the process need to have a hard compression for functionality? I purchased a hand press which obviously compresses the product. Visually, I'm not happy with the appearance. I do have silicone molds (mirror image to get a complete shape) that I use for soap making. I have found that I do get the desired shape, but they fizz out pretty quickly. Not sure if that is a result of non-compression. I simply fill the two sides, lightly pat together then put the molds together and hold with rubber bands. In advance, thank you for the consideration
Hi Bill! This "expert page" is dedicated to questions/answers on Teaching Bath & Body Product Making. Since your question is off topic (and I have your email address), I'll just email you directly & offer some guidance on your Fizzy Bath Bomb question. Look for it in the next hour. It will be coming from email@example.com