What Constitutes 'True Soap'?
To be regulated as true soap under the CPSC, a product must meet three strict criteria. First, the bulk of the non-volatile matter must consist of alkali salts of fatty acids (the result of saponification). Second, those alkali salts must be the only ingredients causing the product's cleaning action.
Third, and most importantly, the product must be marketed exclusively as soap. It cannot make any cosmetic claims about improving the skin, moisturizing, or altering appearance.
True Soap Labeling Requirements (CPSC)
If your product qualifies as true soap, the labeling requirements are relatively lenient. The CPSC requires a clear statement of identity (the word 'soap'), the net quantity of contents in US Customary and metric units, and the name and place of business of the manufacturer, packer, or distributor.
Crucially, true soap does not legally require a full ingredient list. However, most soap makers choose to include one voluntarily for transparency and consumer safety regarding allergens.
When Does Soap Become a Cosmetic? (FDA)
The moment you claim your soap 'moisturizes,' 'softens skin,' 'deodorizes,' or 'soothes,' the FDA classifies it as a cosmetic. This triggers a much stricter set of labeling regulations under the Fair Packaging and Labeling Act (FPLA).
Cosmetics must feature a complete ingredient list using standard INCI (International Nomenclature of Cosmetic Ingredients) names. Ingredients must be listed in descending order of predominance by weight, with ingredients making up less than 1% listed in any order at the end.
- Requires full INCI ingredient list.
- Descending order of predominance by weight.
- Color additives must be listed at the end regardless of amount.
When Does Soap Become a Drug?
If a soap is marketed to treat or prevent a disease, or alter the structure or function of the body, it is classified as a drug. Claiming a soap cures acne, treats eczema, or acts as an antibacterial agent places it in this category.
Drug labeling requires a specialized 'Drug Facts' panel, listing active ingredients separately from inactive ingredients, alongside specific usage directions and warnings.
Frequently asked questions
Does true soap require an ingredient list under CPSC rules?
No, if a product meets the strict definition of true soap without making cosmetic claims, an ingredient list is not legally mandated, though it is highly recommended.
Can I call my true soap 'healing' or 'moisturizing'?
No, making therapeutic or cosmetic claims instantly reclassifies the product under FDA jurisdiction, subjecting it to full cosmetic or drug labeling laws.
How do I list lye on a cosmetic soap label?
You can list the individual starting ingredients (e.g., Sodium Hydroxide and Olive Oil) or the resulting saponified compounds (e.g., Sodium Olivate).
Do I need to list essential oils on the label?
If the product is classified as a cosmetic, essential oils must be included in the INCI ingredient list.