Teach Soap

After the CP soap is made and properly superfatted there is no lye left. I was told that you either list the ingredients as what goes into "baking a cake" or what it becomes. Since there is no easy or inexpensive way to find which oils and butters saponified and at what actual %, it's easier to list what goes into the soap. I was also told that MP glycerin soap base is a cosmetic and as such has to have ingredients listed. The exception to this MP rule is if the MP soap is a true soap.

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Irena
Closed minds are like faulty parachutes; they refuse to open.

You have discovered the same thing I have. The FDA says one thing, the CPSC another. How do you decide whom to follow ? A quick round of Rock, Paper, Scissors ?

As I understand it ... (there's your warning ! ) the FDA IS a governmental agency. The CPSC is NOT, although they do have a lot of clout. And they RECOMMEND that soap ingredients be listed. But they have no enforcement authority.

As for the addresses ... I am a beekeeper by trade, selling honey and candles. Since I produce a food product, I listed my addy, which is my home. And, I have indeed had people simply show up at odd hours to buy honey, AND candles. I live in a small town in a rural area, so that's of less concern than it might otherwise be, but still ... I took my address off the label, added my business phone, and put the word out to please NOT drop by, as I might be working the hives and miss you. Sorry you drove all the way out to see me, and I wasn't there. I was working the hives in the back of the pasture and didn't know you were coming ... It solved itself. I live in rural TX and folks around here take personal protection seriously, and tend to be well-armed. It's inadvisable to surprise people too often ! I was told that as long as people can contact me with a problem, I am okay. The phone number does that.

I'm going to stick with a 'courtesy' label -- here's what I used for oils and additives, and let it go. If folks ask, use it as an excuse to educate them. You have no idea how many people want USDA 'organic' honey, and are shocked to learn that if it's so labeled, it's IMPORTED and NOT a product of the USA ... (another off topic thread ! ) If someone makes a stink, you prolly don't want their business anyway.

Good Luck !
HoneyLady

The Fair Packaging and Labeling Act requires the following on all "household consumer commodities", which true soap does fall under:

a statement identifying the commodity, e.g., detergent, sponges, etc.;
the name and place of business of the manufacturer, packer, or distributor;
and the net quantity of contents in terms of weight, measure, or numerical count (measurement must be in both metric and inch/pound units).

http://www.ftc.gov/os/statutes/fpla/outline.html

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Genny

Thank you Genny!

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"Effective questioning brings insight which fuels curiosity which cultivates wisdom"

Hrm, "name and place", so you don't have to put your entire address on there? That would be a bit of a relief!

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~~Heather~~
Mad [soaping] Scientist

I would hope so, but the wording is vague. It could mean the address, or be more general to just the city, state. I really dislike the thought of putting my home address down. But I suppose it wouldn't be a big deal for a little while since it's not like any fresh started business is going to have gobs of sale volume. I'm just too private. And where I live some people DO run businesses out of their homes that people actually go to.

No wonder I couldn't find the info on the CPSC government site though, lol. Now I'm REALLY curious what they'll tell me. That's the only annoying thing about internet research for me. Sometimes if you don't use just the right words and terms, you could never find the right thing. Nothing I tried searching ever brought up the FTC or the FPLA.

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"Effective questioning brings insight which fuels curiosity which cultivates wisdom"

I read Genny's like and am still confused ... which is no comment on Genny ! I can be confused all by myself, TYVM.

It says the FTC's Label Act applies to DETERGENTS. Then it says the *FDA* administers the Label Act with respect to cosmetics, etc. (And soap is a cosmetic, right ? )Then there is a list of exemptions which does NOT specifically include soap.

BUT, I read that to mean that since the FDA already regulates soap (circa 1978, ? ) that rule trumps the FTC Act (1967) .

My guess is, it really depends on precisely whom you speak to, and what sort of day they have had when you speak to them.

Don't forget the other really important caveat when dealing with any authority ... " It is always better to ask forgiveness than permission. "
HoneyLady

My soap is not a detergent, so I'm going according to the FDA.

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Irena
Closed minds are like faulty parachutes; they refuse to open.

Check out www.mariegale.com
She has book available on soap and cosmetic labeling.

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Linda
I know the voices in my head aren't real, but they sure have some great ideas!

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Genny

It's my understanding that you need the entire street address. This is what WSP & BB was petitioning to change to allow a PO Box for the address.

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Linda
I know the voices in my head aren't real, but they sure have some great ideas!

Um, yeah. I don't want my full address on my products. That's like having a HUGE "I HAVE LYE, PLEASE BREAK INTO MY HOUSE" sign >.<

My current label has the "city" (its a township, not really a city), state and zip. As well as website. I don't have a home phone/business phone, so I don't have a number on it.

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~~Heather~~
Mad [soaping] Scientist

I'm more confused than ever! The FDA specifically says true soap is not regulated by them but by CPSC in the link Sephi provided. In reading an FPLA introduction, it listed "The following products, and miscellaneous others, do not fall under FPLA jurisdiction:" so while soap wasn't mentioned it didn't say what the miscellaneous others were or where the list can be found. The CPSC info I could find related more to childrens clothing, bicycle helmets, etc and I couldn't get it to anything that specifically shows regulations for soap. YIKES!

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Linda

I learn so much when I can't leave well enough alone!

This actually makes me NOT want to sell soap =/

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~~Heather~~
Mad [soaping] Scientist

The only clear mention of soap was this from the FDA's site.

Soap is a category that needs special explanation. That's because the regulatory definition of "soap" is different from the way in which people commonly use the word. Products that meet the definition of "soap" are exempt from the provisions of the FD&C Act because—even though Section 201(i)(1) of the act includes "articles...for cleansing" in the definition of a cosmetic—Section 201(i)(2) excludes soap from the definition of a cosmetic.

How FDA defines "soap"

Not every product marketed as soap meets FDA's definition of the term. FDA interprets the term "soap" to apply only when

the bulk of the nonvolatile matter in the product consists of an alkali salt of fatty acids and the product's detergent properties are due to the alkali-fatty acid compounds, and
the product is labeled, sold, and represented solely as soap [21 CFR 701.2017].

Products that meet this definition of soap are regulated by the Consumer Product Safety Commission18 disclaimer icon 19 (CPSC), not by FDA. Please direct questions about these products, such as safety and labeling requirements, to CPSC.

I'm finding CPSC hopelessly disorganized and confusing. The response to the petition just responded but they aren't getting around to it anytime soon. *sigh*

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Linda

I learn so much when I can't leave well enough alone!