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Soap and Cosmetic Labeling #HSMGchat
Last week, the Handcrafted Soapmakers Guild welcomed author, past President, and labeling expert Marie Gale into our twitter chat room to share some of her vast experience labeling soap for sale in the US. Read on for highlights of our discussion and check out our post on the HSMG blog.
Storified by HandcraftedSoapGuild · Mon, Aug 27 2012 18:59:32
We started with the obvious….
Q1: Correct labeling…why should a biz owner care? #HSMGchatHandcraftedSoapGuild
and Heather from Honestly Simple Soaps jumped in with a great answer!
@TheSoapGuild Its important to people who have allergies and other sensitivities. #hsmgchatHeather Albrecht
Then, we established that although there are soap exemptions, most soap here in the US falls under cosmetic regulations. Forewarned is forearmed!
Q2: Based on how US soapmakers market their products, how often do you think soap is considered soap and not a cosmetic? #HSMGchatHandcraftedSoapGuild
A2: likely not very often. Labeling includes your marketing info, which almost always turns your soap into a cosmetic! #HSMGchatHandcraftedSoapGuild
Oh! I just re-read that, I meant its probably a considered a cosmetic most of the time – moisturizing/ exfoliating, etc. yes? #hsmgchatHeather Albrecht
The way you package your products definitely impacts your labeling:
I don’t use boxes, that’s a question I had about packaging. I see soaps in stores not enclosed in a package. Is it okay to be open #hsmgchatHeather Albrecht
@HonestVTSoaps yup, it’s okay to be open, but full labeling information has to be available to consumer (even if separate) #HSMGchatHandcraftedSoapGuild
Okay, so just where does that pesky net weight statement go?
Does it matter where the net weight is stated on the packaging? I’ve seen some indicate it on the front, and some on the back. #HSMGchatNoir Naturals
@NoirNaturals good one! Net weight has to be on the front…this is one of the non-negotiable labeling guidelines #HSMGchatHandcraftedSoapGuild
Marie clarified that different levels of government have a different focus when it comes to labeling enforcement:
Q7: Any speculation as to which guidelines the FDA most rigorously enforces? #HSMGchatHandcraftedSoapGuild
A7 – FDA concentrates heavily on drug claims on cosmetics. If they find that, then they are likely to look further. #HSMGchatMarieGale
A7 – LOCAL and STATE agencies are more likely to pick up on incorrect or missing weight or name/address. #HSMGchatMarieGale
Speaking of drug claims….
what counts as a ‘drug claim’ #hsmgchatHeather Albrecht
@HonestVTSoaps Drug claim is that the product will "heal, cure, mitigate or prevent" something physical. #HSMGchatMarieGale
@HonestVTSoaps Cosmetics "cleanse, beautify or promote attractiveness". There’s a big gray area in the middle. #HSMGchatMarieGale
@HonestVTSoaps The bottom line is what the consumer thinks the product will do (or what the FDA thinks the consumer thinks) #HSMGchatMarieGale
so when talking about tea tree oil in your product, for instance, is it okay to mention that it has antibacterial properties? #hsmgchatHeather Albrecht
@HonestVTSoaps Technically, saying an ingredient can cure, mitigate or prevent disease is making a drug claim for the product. #HSMGchatMarieGale
"Antibacterial" is a drug claim, for sure. #HSMGchatMarieGale
Anything WITH or ON the product counts as labeling, so website, signage, the label itself, books displayed with the product … #HSMGchatMarieGale
Best is to say what’s in the product and then let the consumer research it separately. Savvy consumers know what to look for. #HSMGchatMarieGale
At craft shows I’d say, "I can’t legally say that tea tree oil is antibacterial – or that it does anything, but it IS in my soap!" #HSMGchatMarieGale
You can also say things like "we choose our ingredients because of they are known to be healthy and beneficial" – but no specifics #HSMGchatMarieGale
@MarieGale yes, if customers seek you out, they probably know the properties of your ingredients. #HsmgchatTygerheart Fine Soap
@tygerheartsoap great point – consumers are a smart bunch #HSMGchatHandcraftedSoapGuild
Any surprises in the labeling regulation world? Of course!!
So @MarieGale, is there anything that surprises you the most about soap and cosmetic labeling regulations? #HSMGchatHandcraftedSoapGuild
I’m most surprised by the fact that they are so understaffed that they have to concentrate on the most flagrant violations. #HSMGchatMarieGale
FDA seems to concentrate on imports – it’s a "homeland security" thing. #HSMGchatMarieGale
Local and state agencies have been more active over the last few years – possible as a revenue stream. #HSMGchatMarieGale
From enforcement, we move right into another hot topic – soap weight!
Here is a totally off the topic question: how is the weight of a recipe calculated? It will say 58 oz ie. and yield 89 oz of soap? #hsmgchatHeather Albrecht
@HonestVTSoaps Weight of recipe is ALL of the ingredients you put in the pot – oils, water, lye, eo/fo, color, herbs, etc. #HSMGchatMarieGale
@HonestVTSoaps Water percent is the amount of water divided by the total of all ingredients. (Gives a decimal, x by 100 for %) #HSMGchatMarieGale
@MarieGale I figured my soaps are always 17% water so I subtract that. They can’t go below it. #HsmgchatTygerheart Fine Soap
@tygerheartsoap That’s an excellent way to do it. If soap is 17% water, it won’t ever go below that, no matter how dry it gets. #HSMGchatMarieGale
And Heather clarifies differences in procedure for hot processed soap:
yes, how do you calculate the net weight and water evap? I make HP soap, does it make a difference? #hsmgchatHeather Albrecht
@HonestVTSoaps For hot process, you’d need to weigh the batch once made, deduct the weight of all non-water ingredients & then … #HSMGchatMarieGale
@HonestVTSoaps .. that will tell you how much water is left in the soap that could evaporate. Calculate the percentage & use that #HSMGchatMarieGale
From what I’ve seen, water is usually 15 – 20% in CP. In HP, it’s probably less. #HSMGchatMarieGale
If you’re going to sell your soap in a few weeks or months, you can weigh the soap when it comes out of the mold, and then each wk #HSMGchatMarieGale
That will tell you how much it loses over time. That will give you some numbers to work with if you are selling soon. #HSMGchatMarieGale
The net weight needs to be correct when on display and when sold … if it gets less after the customer buys, not your problem. #HSMGchatMarieGale
Also check out Marie’s blog for two methods (
) to help you calculate net weight.
Noir Naturals discovers, calculating the amount of water for soaps made with alternative liquids can get tricky:
How much different is it with goat milk soap that contain no water? #HSMGchatNoir Naturals
@NoirNaturals You’d need to know how much fat and other non-water stuff was in the goat’s milk and add that to the non-water amt #HSMGchatMarieGale
And finally, Carol closes out the evening with a great question for Marie:
@mariegale, your labeling book had been very helpful. What gave u the idea to write it? #HsmgchatTygerheart Fine Soap
@tygerheartsoap The confusion I encountered when trying to label my soap was the first thing. #HSMGchatMarieGale
@tygerheartsoap Then it was the amazing amount of WRONG information I found on the web. #HSMGchatMarieGale
@tygerheartsoap Since I actually LIKE reading regulations (I know, strange), and I like writing, it seemed a natural fit. #HSMGchatMarieGale