A few thoughts about ingredients listing, especially now that I've gone down the rabbit hole that is FDA regulation and proper labeling. A couple things to keep in mind: very few products actually follow FDA regulations to the letter (even the big-name companies!) and soap can wear different hats in the eyes of the FDA. I know, this is SO exciting right? I hope that this post will clear up a lot of questions folks usually have about the soaps I offer and why they're presented the way that they are.
Soap that is primarily comprised of an alkali salt of a fatty acid ("lye" soap - not primarily made of detergents) can be considered a consumer commodity with few regulations (manufacturer name, size, and place of manufacture is all that's required on that label!). Candles and tarts also fall under this category. Ingredients are not required, so depending on how the soap is presented to the public (in this case, as "just soap") then there can be some liberties taken with the label.
Soap that is intended to moisturize, exfoliate, cleanse, smooth, and is meant to enhance your appearance falls under another category - cosmetics! Here at Orchard Hill Trading Company, we consider our soaps to be cosmetics as far as the FDA is concerned. There is a very strict set of requirements for these labels - font size, placement, and especially proper ingredients listing are all requirements.
With cosmetic labeling, current FDA guidelines require that we list everything in descending order of prominence with INCI (International Nomenclature of Cosmetic Ingredients) names. These names are intended to be recognized internationally and among different cultures. Manufacturers can include the common names of these ingredients in parentheses since many do not readily recognize certain names (example: butyrospermum parkii - what in the world IS that? Sounds dangerous right? It's shea butter!). I often hear that if someone doesn't recognize what's on the label, they won't bother using it. With these FDA regulations in place, it's up to us to educate and inform as to why labels read the way they do.
There is a third category that soap can be classified as: drugs. Soaps that are intended to treat a condition (eczema, acne, psoriasis, dermatitis, etc) are considered drugs as far as the FDA is concerned. Sunscreen also falls under this category. These products must conform to a rigid set of guidelines including clinical testing, submission and approval of a New Drug Application, compliance to a set of active ingredient usage guidelines set by the FDA (called monographs), prohibitively stricter production settings, and if I were to change my formulas in any way, then I would have to start all over with the process. This all amounts to a lot more money and, frankly, a level of responsibility that I don't want to have on my plate since I am not at all formally trained in these areas. If you want advice about your condition, the best advice I can give is that you should visit your doctor and discuss your options with them.
The key here is how the public is intended to perceive your soap. Is it presented as an eczema cure? Just pure soap? An exfoliating scrub? Even if it's not on the label, if a customer is led by the manufacturer to believe it has a certain function, that's what counts with the FDA.
Whew! That was a lot of info. Not terribly fascinating information either, but it might answer a few questions regarding soaps and why I market and present them in the way that I do. Doing things the right way isn't always the easiest, especially when customers ask me why X soapmaker has an eczema soap and I don't. Maybe that soapmaker has undergone the rigorous standards of the FDA. I know I haven't, so I don't make those claims and I can only speak for myself. I hope that this has been helpful!
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