One of the biggest frustrations for me as a soap maker is when someone asks if I have a soap for a particular medical condition (i.e. acne, eczema, etc.). I am not frustrated with my customer, just the situation. Let me explain.
There are three different ways soap can be marketed.
1. Soap can be marketed as soap! If the soap is labeled, sold and represented solely as soap (i.e. it cleans) - it is soap! Soap, marketed as soap, has basic labeling requirements. The ingredients are not even required to be on the label. The Federal Trade Commission (FTC) is the regulating authority.
2. Soap can also be marketed as a cosmetic! If I said anything about how my soap imparts a fragrance, makes the user more attractive, acts as a deodorant, or moisturizes the skin, then the soap just became a cosmetic. Cosmetics have very specific labeling requirements and cannot use certain ingredients. They are not required to be registered (but may be). Cosmetics are regulated by FTC and U.S. Food & Drug Administration (FDCA).
3. Finally, soap can also be marketed as a drug. If any claims are made about using a soap for acne or eczema or any issue, your soap is now considered a drug. If you say it can cure, treat or prevent something, your soap is a drug. Drugs are regulated by FTC and FDCA. Drugs require premarket approval, mandatory registration, as well as very specific labeling requirements.
It gets very tricky to stay within the confines of marketing my soap as just soap! So, I do label my soap with the more strict labeling requirements for cosmetics so I can use fun words like moisturizing!
So, if I look a little uncomfortable if you ask me if I have a soap to clear up your teenagers acne, hopefully you now understand why! I know there are a lot of companies out there that are not following the rules. That is their problem, not mine. It is very difficult to be in regulation but I am doing the best I can and trying not to pay attention to what others are doing.
I highly suggest you do your own research on what ingredients can be used for certain conditions. That way when you are shopping, you can just ask the soap maker if they have any soap that contains the ingredient you want.
P.S. This is a very simplistic explanation of a very complex set of rules! If you are a soap maker, I suggest you delve deeper into the regulations than this simplistic explanation!
In becoming compliant with the cosmetic labeling regulations, I am slowly renaming many soaps. Here are some that have already been changed. I may still have some soaps with the old name as I did not repackage them.
- Raspberry Patchouli is now Believe
- Lemongrass is now Refined By Fire
- Blackberry Almond is now Fruit of the Spirit
- Black Raspberry Vanilla is now Whosoever
- Lily of the Valley is now Devotion
- Orange & Clove is now Pure