Soap Labeling Requirements

Soap labeling requirements depend on the finished product and the claims you make. Before you sell soap, check which label rules apply to its formula and intended use. Use that classification when you prepare the artwork.

A true-soap label and a cosmetic label follow different checklists. Confirm the product category before you decide what information to print.

We supply ready-to-label blends and custom projects for brands. Compare our manufacturing options while you plan the product and packaging.

Quick checklist: A true soap label should generally include 1) the product identity, such as “soap,” 2) the net quantity, and 3) the name and address of the manufacturer, packer, or distributor. If the product is marketed with cosmetic or drug claims, additional labeling rules may apply.

Check business permissions before selling soap as well as the wording on your packaging.

Which of the Soap Labeling Laws Apply to Your Product?

Depending on the product, there are many regulations with which a product's label must comply before it is sold in the United States. The relevant laws governing soap labeling include the following:

• The Fair Packaging and Labeling Act (FPLA), enforced by the Federal Trade Commission (FTC)
• The Federal Hazardous Substances Act (FHSA), enforced by the Consumer Product Safety Commission (CPSC)
• The Federal Food, Drug, and Cosmetic Act (FD&C Act), enforced by the Food and Drug Administration (FDA)

How do you know what laws you need to follow? It depends on the kind of soap you are selling. Today, many commercially manufactured body cleansers marketed as "soap" are synthetic detergent products. They are not true soaps according to the regulatory definition of the word.

FDA defines "soap" as a product made mainly of the "alkali salts of fatty acids," its cleansing properties must come from these ingredients. It must be labeled and marketed only for use as soap. True soaps that meet the regulatory definition are regulated by the Consumer Product Safety Commission (CPSC), and their labels follow FPLA and FHSA rules.

If the product contains synthetic detergents to improve its cleansing power, it is considered a cosmetic, although you can use the word "soap" on the label. The soap is also considered cosmetic from a legal standpoint if manufacturers make such cosmetic claims as "moisturizing," "exfoliating," or "deodorizing." Products intended to treat skin conditions, such as acne or eczema, or prevent diseases by killing germs are considered drugs. The FDA regulates cosmetics and drugs.

True Soap vs. Cosmetic Soap vs. Drug Soap

Most cosmetic products and ingredients don’t need FDA approval before sale. Color additives have separate approval rules. A product that meets the definition of a drug must follow the requirements for drugs. Calling it “soap” doesn’t remove those duties.

Soap Labeling Requirements

CPSC does not have specific labeling requirements for soaps, so the applicable law is The Fair Packaging and Labeling Act (FPLA), which governs the labeling of all consumer products. The FPLA's requirements for labeling consumer products are simple—a label for your soap must include the following details:

• A statement identifying the product as "soap;"
• Information about the manufacturer, packer, or distributor (name and address);
• The net quantity of contents in terms of weight, measure, or numerical count.

You do not have to list the ingredients—the CPSC does not require ingredient declaration for true soaps. You just have to label it as "soap" and inform consumers how much it weighs and where to find your company.

Check Your Label Before Printing

Use the product’s final classification and approved formula when you review the artwork. Check the label on the actual package, not only on a large screen. Ask these questions before you approve a print run:

• Can the shopper identify the product and read its net contents?
• Does the business information identify the manufacturer, packer or distributor?
• Do the ingredient statement and claims match this exact blend?
• Does the organic wording match the product’s certification category?
• Has the final artwork been checked against the rules for this product?

Cosmetic soap needs an ingredient declaration and the other label information required for cosmetics. That requirement follows the product’s legal classification. It doesn’t mean cosmetic ingredients are automatically harmful. Drug products have their own requirements and need a separate review.

If you sell simple soaps, you can skip the ingredients list. But today's consumers are extremely conscious of what they use on their bodies. So, if you include the ingredient list, your customers will surely appreciate this gesture because it shows transparency and makes customers feel safe and cared for.

You can list the ingredients according to the guidelines of the FDA—in descending order of predominance (the percentage of the total formula) and use the most commonly accepted names for ingredients to ensure that you don't deceive or mislead the consumers.

For a cosmetic label, use the ingredient declaration for the finished formula. If water is an ingredient in the finished cosmetic product, include it unless a specific exemption applies. Don’t remove it simply because the product is sold as soap. Confirm the declaration with your manufacturer before approving the artwork.

Cosmetic labels must also provide a domestic address, domestic phone number or electronic contact through which the responsible person can receive adverse event reports. The responsible person is the manufacturer, packer or distributor named on the label. Check the wider cosmetic requirements in our cosmetic labeling guide.

If you order soap at Botanie Soap, you can buy pre-printed ingredient labels. Each label lists the specific blend's ingredients and includes an asterisk next to each organic ingredient. We also offer blank sheet labels in different shapes and work with laser and inkjet printers.

True all-natural soaps like those that we make at Botanie Soap and offer for private-label use are a good option if you want to start selling soap. Order our soap sample set to see what we offer and choose products you could sell under your brand. The sample set includes all our bar soap varieties that we make using time-tested recipes and samples of our different liquid soap bases and scents.

Organic Labeling Requirements

The National Organic Program (NOP) of the United States Department of Agriculture (USDA) has specific rules for what makes a product organic and sets organic labeling standards. According to USDA Organic Regulations, you can only use the term "organic" on labels if your product is certified within the USDA National Organic Program.

If you are not certified, you must not make any organic claim on the principal display panel or use the USDA organic seal anywhere on the package. However, you may identify the certified organic ingredients as organic and the percentage of organic ingredients on the information panel.

Within the NOP, there are three levels of organic certification based on the percentage of a product's organic ingredients vs. total ingredients, excluding water and salt:

• "100% Organic" (contains 100 percent organic ingredients)
• "Organic" (contains a minimum of 95% organic ingredients)
• "Made with Organic ______" (contains at least 70% organically produced ingredients)

Our certified bar and liquid soap blends fall in the “made with organic” category. Their organic percentages vary by blend, so use the documentation for the product you order. Don’t assume every soap has the same organic percentage or that every soap formulation must fall in this category.

So if you buy soap from Botanie Soap to sell under your brand and your company and your products have been listed on Botanie's organic certification, you must strictly follow the USDA organic labeling standards that apply to the Made with Organic category:

• Principal Display Panel (PDP): You may state "made with organic (insert up to 3 ingredients or ingredient categories)". However, you cannot include the USDA organic seal anywhere, represent the finished product as organic, or state that it is "made with organic ingredients."
• Information Panel (IP): Identify organic ingredients (e.g., organic shea butter) or via asterisk or other mark (e.g., rosemary leaf*).

Remember that if you are not on our organic certificate, you cannot use the words "certified organic," make any organic claim on the principal display panel, or use the USDA organic seal anywhere on your packaging. But on your information panel, you may list certified organic ingredients as organic in the ingredient list and the percentage of organic ingredients.

How to Make Labels for Soap

When you start creating the design for your soap labels, have the following tips in mind to make them appealing to customers:

• Choose an appropriate shape and size for the label, depending on the dimensions and packaging of your soap
• Include your name and your logo, and share a few words about your business's mission statement
• Use big fonts to make the soap name visible
• Include some words about the power of the natural scent
• Play with colors—match the color of your label with the color or scent of the soap
• Use stunning images to attract the attention of consumers

Treat label approval as one part of planning a soap product launch.

Approve Your Soap Label With the Right Information

Start with soap labeling requirements for the product you’ll actually sell. Confirm its classification, net contents, business information and any required ingredient declaration. Check organic wording against the approved certification category. If you’re comparing existing blends, use our soap sample sets to review the product before choosing packaging.