Teach Soap

I will soon be interested in selling my soap and have lately been scoping out exactly how to do this.

My understanding is that handcrafted soap must conform with the Consumer Product Safety Commission labeling requirements. These include:
1. the word 'soap' on the front panel
2. the net weight located underneath that on the front panel
3. the name of the business on the back panel
4. the address of the business on the back panel

I'm discovering that many soapmakers aren't conforming with the letter of the law on these labeling requirements. That goes for handcrafted soapmakers as well as the 'big boys' in some instances. For example, Pre de Provence has simply the business name stamped on the front with the weight and business address on the back. How do they get away with this?

Further, many handcrafted soaps sold at local farmers markets, on Etsy, etc. have very little information on their packaging (if any!), and almost none have the business address.

A few questions:
Is this just a matter of soapmakers not being aware of the law?
Or, are they aware of the law but it's just not enforced?
Am misunderstanding something (entirely possible)?

I guess the bottom line is that I want to conform with applicable laws, but I want to preserve a clean uncluttered design too.

Why should I conform with unenforced laws that most everybody else seems comfortable with ignoring?

You are correct with everything that needs to be listed on the labels. I put the ingredients on the back as well, even though it isn't required, I find that customers appreciate it a lot and are more likely to buy if they know what's in it.

For us that follow the laws that pertain to labeling and such, it's frustrating when there are so many out there that don't.
Some don't do it because they just don't care, with some it could be that they don't know, but ignorance of the law won't save them from getting in trouble if caught. In the U.S., Consumer Product Safety expects all people selling anything to make sure that their products are safe for consumers and are being legally sold.

Whether or not you choose to conform with the laws that you know you're supposed to be following is a moral decision that you'll have to make.

I can honestly say though that as a consumer, I never buy anything from anyone if I know that they haven't followed the correct labeling laws. Because I figure if they're so careless about something that important, how safe is the product going to be?

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Genny

Don't go by Etsy. Many people there are just hobbyists. They either ignore the laws or don't know any better. According the the FDA, if it is a true soap, it needs no ingredients. I put ingredients on my label because I am proud of the oils/butters that I use. It's also a good idea for those with allergies.

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

Out of curiosity, if you don't have a physical store front, what do you put as the address? I wouldn't be comfortable putting my home address on something like that. And could possibly be a big reason why other people don't either. Unless just giving a City and State suffices, I'd be alright doing that, but a street address of my home, heck no!

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

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Genny

I can't seem to find the relevant information at CPSC.gov

Although I am seeing a lot of stuff about requirements and exemptions from 3rd party testing for certification.

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

If your company is listed in the yellow pages you need only put the city, state and zip on your label and not the physical address. Otherwise, you must list the physical address where the soap is made/your company resides.

The law is the law and compliance is a standard of business. What you do is your business and what anyone else does is their business, but if caught, ignorance of the law is no excuse. As for what people on Etsy do, as Irena said, many are hobbyists and some may provide labels they do not show on Etsy. When I sold there I did not list my ingredients because a few shops always came out with new products right after I did and they always contained my same ingredient list (misspelled words and all), but all my products certainly were sent out with accurate, legal labels. It all boils down to how you choose to do business.

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Remember, it's not just that we weather the storm, but how we dance in the rain.

Tammy

I am pretty pedantic when it comes to rules and laws. I'm just confused because I have ordered from a few larger companies that don't seem like the type who would just ignore government labeling requirements, and yet do nothing that has been listed here. I also can't find any soap labeling requirements on the website for CPSC, but it is kind of confusing to navigate. So I emailed them for my own personal clarification. If they say anything contrary to what has been listed here I'll pass along the information.

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

Evidently you only need to list the company name, city, state and zip code IF you list your company in a local directory like the yellow pages. Cant find the link for that at the moment.

But Sephi has a good point. As I noted in the original post, Pre de Provence does not conform to the law as stated by not posting the weight on the front. Thats just one example. How do they skirt the law like that?

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Genny

Bigger companies do this because they know they can get away with it. If they get caught, they pay the fine and keep on keeping on. They have money in the budget to do this.

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

One of my favorite places to buy shampoo bars is Chagrin Valley Soap & Salve. Everything I've bought from them comes in a brown paper bag with a sticker on it that just says their name and the name of the product. They just do not strike me as the sort of business to do something not above board. I could be wrong of course, but I'm skeptical. The fact that the info on labeling requirements is not easily found makes me even more skeptical. I tried to find it for an hour or more, and could not find anything useful one way or another, not even a confirmation that the above requirements are correct. If it's that hard to find I'd bet a lot of people just don't know. I'm going to go with 50/50 odds it's so obscure for small businesses that most people don't even know it, or that those aren't the actual requirements and people aren't actually doing anything wrong. I'm still hoping the CPSC replies to my email next week sometime. Whatever the requirements are, or lack thereof, it shouldn't be so hard to figure it out. The FDA has their info about it plain as day.

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

The labeling requirements were listed on the FDA website, or so I thought? You don't need an ingredient list, but a product needs to list the weight of the product on the front and contact info on the back.

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

The ONLY thing the FDA says about it is that if it is "true soap" and makes no cosmetic or health claims it doesn't have to have ingredients listed and is otherwise regulated by the CPSC. I couldn't find squat about it on the CPSC site. The closest thing is the regulations about products containing sodium hydroxide, but I don't think finished and usable soap actually have sodium hydroxide in it anymore right? And the regs are about labeling to make sure no one gets poisoned and knows it's hazardous, which also doesn't seem to apply to soap. The best I can take away from what I'm finding is that it's actually unregulated, and so have no labeling requirements. But I emailed them and asked about it to know for sure. If the labeling requirements are there, then at least they can tell me where to find them since I couldn't! lol

This is the FDA page about soap. http://www.fda.gov/Cosmetics/Productand ... 115449.htm

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

It almost seems more like the labeling requirements listed above applies towards melt and pour soaps possibly as they would fall under the kind of soap that the FDA does regulate, but not soap made with lye.

Also, sometimes I repeat myself a lot because I don't readily remember that I've already said it, which is why I've said about 3 times now that I emailed the CPSC Please excuse my redundancy!

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