Re: Question - Soap Labeling

[Guest guest]

If your additives don't make up more than 50% of the bar, and you're not

making any cosmetic claims, you don't have to label. But if you're going to

list one ingredient, you have to list them all, and properly.

Merin

http://www.goodcleansoap.com

Selfishness is not living as one wishes to live, it is asking others to live

as one wishes to live. -- Wilde

> Hi,

> I recently made my first batch of " real " soap (using soap

> noodles) and it's my understanding from the CFSAN site (below) that

> no ingredient labeling is required since there were no detergents

> used and I'm not making a cosmetic/medicinal claim.

> I made shaving bars from the noodles, so they also contain

> bentonite clay, fragrance and a blend of dried herbs (agrimony,

> comfrey, lemon balm, chamomile) - should I include the additive

> information on the label?

[Guest guest]

> I recently made my first batch of " real " soap (using soap

>noodles) and

What ingredient(s) are in your soap noodles?

> it's my understanding from the CFSAN site (below) that

>no ingredient labeling is required since there were no detergents

>used and I'm not making a cosmetic/medicinal claim.

>

> I made shaving bars from the noodles, so they also contain

>bentonite clay, fragrance and a blend of dried herbs (agrimony,

>comfrey, lemon balm, chamomile) - should I include the additive

>information on the label?

The probability that a FDA inspector will come to your home is

incredibly remote. But if he did visit, I think that the FDA inspector

would consider a soap with bentonite clay and a blend of dried herbs

(agrimony, comfrey, lemon balm, chamomile) to be a cosmetic.

IMO, by adding bentonite and the dried herbs your soap is representing

your soap as something more than soap and would be subject to cosmetic

labeling regulations. Which is not a bad thing.

Maurice

--------------------------------------------------------

Maurice O. Hevey

Convergent Cosmetics, Inc.

http://www.ConvergentCosmetics.com

-------------------------------------------------------

[Guest guest]

>What ingredient(s) are in your soap noodles?

>

>The company's response is:

> " The saponified oils (soy, cottonseed, olive oil and coconut oils) ARE the

ingredients. There isn't anything else in the shredded soaps that we sell.

Just pure soap from the oils mentioned. "

Interesting. I was waiting to hear Sodium Soyate, Sodium Olivate and

Sodium Cocoate. Do you think these noodles contain any glycerin,

unsaponified oils and free soy, cottonseed, olive and coconut oils?

There are companies, like Uniqema, that sell pure Sodium Soyate, Sodium

Olivate and Sodium Cocoate to the soap makers around the country.

Maurice

--------------------------------------------------------

Maurice O. Hevey

Convergent Cosmetics, Inc.

http://www.ConvergentCosmetics.com

-------------------------------------------------------

[Guest guest]

>Hi Maurice,

>

>Interesting. I was waiting to hear Sodium Soyate, Sodium Olivate and

>Sodium Cocoate. Do you think these noodles contain any glycerin,

>unsaponified oils and free soy, cottonseed, olive and coconut oils?

>

>Based on the company's response, the answer is NO. I just rc'd this reply from

the company in addition to their earlier reply:

>

> " 'Saponified' means something quite specific. The definition of 'soap' is

lye+water+oils.

>

>There is no such thing as soap without the lye process.

>

>If you say saponified oils, then what exactly that says is lye and water is

added to the listed oils.

>

>There isn't any Lye IN soap, it has been transformed INTO soap.

>

>If you are in the USA, what you put on your label is just as we have it, plus

you add anything you might add to it like milk, fragrance, etc. "

You and your vendor obviously know a lot more about the saponification process

than I do. Good luck!

Maurice

--------------------------------------------------------

Maurice O. Hevey

Convergent Cosmetics, Inc.

http://www.ConvergentCosmetics.com

-------------------------------------------------------

[Guest guest]

Well I have to say that I dissagree.

When you saponify those oils you have " left overs " that are created by the

saponification process. HOw about the glycerin that is in soap? HOw about

the parts of the oils that don't saponify? What about salts that may be left

after saponification? How do you list these? Doesn't sound like a complete

list of ingredients to me. I'd bet that you'd have to have a lab do an

analysis to find out what is in the soap after saponification.

I think it would be much easier and far more accurate to list what WENT IN

before saponification.

FWIW

Sutton

Get REal Soap Co.

>

>

> >Hi Maurice,

> >

> >Interesting. I was waiting to hear Sodium Soyate, Sodium Olivate and

> >Sodium Cocoate. Do you think these noodles contain any glycerin,

> >unsaponified oils and free soy, cottonseed, olive and coconut oils?

> >

> >Based on the company's response, the answer is NO. I just rc'd this

reply from the company in addition to their earlier reply:

> >

> > " 'Saponified' means something quite specific. The definition of 'soap'

is lye+water+oils.

> >

> >There is no such thing as soap without the lye process.

> >

> >If you say saponified oils, then what exactly that says is lye and water

is added to the listed oils.

> >

> >There isn't any Lye IN soap, it has been transformed INTO soap.

> >

> >If you are in the USA, what you put on your label is just as we have it,

plus you add anything you might add to it like milk, fragrance, etc. "

>

> You and your vendor obviously know a lot more about the saponification

process than I do. Good luck!

>

> Maurice

[Guest guest]

Eve, were I you, I would be very certain that the company is telling the

truth. If they are saying there are no unsaponified oils, then that means

they made soap with a zero superfat. They are also not accounting for the

glycerin that was created as a result of the soapmaking process.

Personally, I don't like the " sodium whateverate " method of labeling, which

would include " saponified oils of... " . Based on what I've read (I believe

the post was by Jules but I wouldn't swear to it), if you do that, you have

to account for exactly what got sapped and exactly what didn't. I prefer

the " what went in " method, because I know what I put in there.

Merin

http://www.goodcleansoap.com

Selfishness is not living as one wishes to live, it is asking others to live

as one wishes to live. -- Wilde

> Hi Maurice,

>

> > Interesting. I was waiting to hear Sodium Soyate, Sodium Olivate and

> > Sodium Cocoate. Do you think these noodles contain any glycerin,

> > unsaponified oils and free soy, cottonseed, olive and coconut oils?

>

> Based on the company's response, the answer is NO. I just rc'd this reply

from the company in addition to their earlier reply:

>

> " 'Saponified' means something quite specific. The definition of 'soap' is

lye+water+oils.

>

> There is no such thing as soap without the lye process.

>

> If you say saponified oils, then what exactly that says is lye and water

is added to the listed oils.

>

> There isn't any Lye IN soap, it has been transformed INTO soap.

>

> If you are in the USA, what you put on your label is just as we have it,

plus you add anything you might add to it like milk, fragrance, etc. "

[Guest guest]

That's the thing, Maurice - the only thing I know about cold process

soapmaking is the conflicting information I've read on several

websites, that's why I chose soap noodles instead thinking

an " expert " has already completed the process and all I have to do

is " reconstitute " it.

I thought the source I purchased from was very knowledgable and

reputable until I was informed the only ingredients in the soap

noodles were soy, cottonseed, olive and coconut oils. Then was

instructed, " If you are in the USA, what you put on your label is

just as we have it, plus you add anything you might add to it like

milk, fragrance, etc. " That just didn't sound right based on what

I've read about soapmaking.

Merin/, I agree that the " what went in " ingredient listing

sounds more solid. But according to the company, the only thing

that went in were the oils listed above (+ my additives). I'd like

to know the correct info, but don't feel I'll get anymore from the

company.

Merin, I believe you replied earlier stating that as long as my

herbs remained under 50% of the soap that product labeling wasn't

required.

Soapmakers - How do y'all label YOUR cold process soaps? And is

there a RELIABLE source of information on the net for cold process

soapmaking, soap noodles and making bath products in general?

Thanks for all the help,

Lori

[Guest guest]

Hi Lori

I haven't seen anything that suggests the noodles are handmade soap at

all! How do you 'reconstitute' them?

These noodles sound like a form of commercial soap base, which would

have no glycerin, no mono- or di glycerides or anything else. Just

sodium whateverates. Further, if the company in question manufactures

soap noodles rather than soap, then they would be buying in those

sodium whateverates in their pure form as the ingredients for the soap

noodles. Therefore the labelling is correct both for them and for

you. Even if they manufacture the soap themselves, then you are

buying the soap as an ingredient for your own further manufacture, and

their suggested labelling is still perfectly correct for you.

Otherwise why doesn't everyone using, say polysorbate, have to list

the raw materials that went into the manufacture of that?

Rose

The London Soap Company

I don't see any problem with using the labelling they suggest.

> That's the thing, Maurice - the only thing I know about cold process

> soapmaking is the conflicting information I've read on several

> websites, that's why I chose soap noodles instead thinking

> an " expert " has already completed the process and all I have to do

> is " reconstitute " it.

[Guest guest]

Cosmeticinfo , " londonsoapco " cromptonrt@a...> wrote:

I haven't seen anything that suggests the noodles are handmade soap

at all! How do you 'reconstitute' them?

---------

Hi Rose,

To reconstitute:

1 lb soap noodles

1/2-3/4c whole milk (skim or goat is also ok)

1/2-1 tsp fragrance

1 T dried herbs (optional)

* I added 1T of bentonite clay + ~1-1.5tsp dried herbs

Place noodles and milk in crock pot, deep fat fryer or sauce pan.

Cover and heat to 200 degrees (F) for 1 hour. (I used an oven-proof

non-metallic bowl with glass lid in the oven). Once noodles have

melted, stir in fragrance and herbs, then pour into molds. Once

unmolded, let dry for 2-6 weeks to cure. (I placed mine on a wire

rack - this is the 7th week).

The soaps have come out great, but I have no idea how to properly

label them now.

Lori

[Guest guest]

In a message dated 10/8/2003 5:16:32 PM Pacific Daylight Time,

eve31_nc@... writes:

> Cosmeticinfo , " londonsoapco " cromptonrt@a...> wrote:

> I haven't seen anything that suggests the noodles are handmade soap

> at all! How do you 'reconstitute' them?

> ---------

>

This is rebatching a premade soap product; the soap noodles, which are just

shredded soap, with a liquid and whatever additives you like to put in there.

Beth Day

[Guest guest]

I appreciate this is not a " soap " forum, so I've stayed out 'til

now. Doing a google search,http://vmcfsan.fda.gov/-dms/cos-215.html,

the following information was obtained:

" Soap is a category that needs special explanation. That's because

the regulatory definition of " soap " is different from the way in

which people commonly use the word. Products that meet the definition

of " soap " are exempt from the provisions of the FD & C Act because --

even though Section 201(i)(1) of the act includes " articles...for

cleansing " in the definition of a cosmetic -- Section 201(i)(2)

excludes soap from the definition of a cosmetic. "

How FDA defines " soap "

" Not every product marketed as soap meets FDA's definition of the

term. FDA interprets the term " soap " to apply only when --

" The bulk of the nonvolatile matter in the product consists of an

alkali salt of fatty acids and the product's detergent properties are

due to the alkali-fatty acid compounds, and

The product is labeled, sold, and represented solely as soap [21 CFR

701.20]. "

" If a product intended to cleanse the human body does not meet all

the criteria for soap, as listed above, it is either a cosmetic or a

drug. For example:

If a product --

consists of detergents or primarily of alkali salts of fatty acids

and is intended not only for cleansing but also for other cosmetic

uses, such as beautifying or moisturizing, it is regulated as a

cosmetic.

If a product --

consists of detergents or primarily of alkali salts of fatty acids

and is intended not only for cleansing but also to cure, treat, or

prevent disease or to affect the structure or any function of the

human body, it is regulated as a drug.

If a product --

is intended solely for cleansing the human body and

has the characteristics consumers generally associate with soap,

does not consist primarily of alkali salts of fatty acids,

it may be identified in labeling as soap, but it is regulated as a

cosmetic. "

U. S. Food and Drug Administration

Center for Food Safety and Applied Nutrition

Office of Cosmetics and Colors

July 8, 2002 "

-----

Though I haven't researched it specifically it is my understanding

that Canada does consider soap a cosmetic, so different rules would

apply if one wanted to sell soap there.

Soap & glycerin are a natural byproduct of the soapmaking process.

As long as no claims are made, it's just soap and all you " have "

to do is label it as soap. If any " claims " are made; " moisturizes,

exfoliates, etc. " , then it's a cosmetic and needs to be labelled

accordingly. However, it has always been my understanding that

whether or not any claim is made, it's generally considered polite to

let the buyer know what's in it so they can make an informed decision.

A simple cruise of the mall however, will show you that not all

sellers of natural process soap offer the same courtesy.

As far as soap noodles are concerned, they are simply saponified oils

resulting in soap & glycerin. I've bought them and made them. I've

never sold any soaps made from them as they tend to appear course &

can be difficult to work with. If I wanted to sell them I would label

them as my vendor suggested with the addition of my own ingredients.

Good luck & I hope this helps. Check out the FDA site for more info.

Sue Flood

> Eve, were I you, I would be very certain that the company is

telling the

> truth. If they are saying there are no unsaponified oils, then

that means

> they made soap with a zero superfat. They are also not accounting

for the

> glycerin that was created as a result of the soapmaking process.

>

>

[Guest guest]

Dear Group,

Please excuse if this comes us as a duplicate. I posted a reply

sometime ago & it hasn't shown up, so I'm gonna try it again.

Doing a Google search, I got the following:

http://vm.cfsan.fda.gov/~dms/cos-215.html

" And what if it's " soap " ?

Soap is a category that needs special explanation. That's because the

regulatory definition of " soap " is different from the way in which

people commonly use the word. Products that meet the definition

of " soap " are exempt from the provisions of the FD & C Act because --

even though Section 201(i)(1) of the act includes " articles...for

cleansing " in the definition of a cosmetic -- Section 201(i)(2)

excludes soap from the definition of a cosmetic. "

" How FDA defines " soap "

Not every product marketed as soap meets FDA's definition of the

term. FDA interprets the term " soap " to apply only when --

The bulk of the nonvolatile matter in the product consists of an

alkali salt of fatty acids and the product's detergent properties are

due to the alkali-fatty acid compounds, and

The product is labeled, sold, and represented solely as soap [21 CFR

701.20].

If a cleanser does not meet all of these criteria...

If a product intended to cleanse the human body does not meet all the

criteria for soap, as listed above, it is either a cosmetic or a

drug. For example:

If a product --

consists of detergents or

primarily of alkali salts of fatty acids and

is intended not only for cleansing but also for other cosmetic uses,

such as beautifying or moisturizing,

it is regulated as a cosmetic.

If a product --

consists of detergents or

primarily of alkali salts of fatty acids and

is intended not only for cleansing but also to cure, treat, or

prevent disease or to affect the structure or any function of the

human body,

it is regulated as a drug.

If a product --

is intended solely for cleansing the human body and

has the characteristics consumers generally associate with soap,

does not consist primarily of alkali salts of fatty acids,

it may be identified in labeling as soap, but it is regulated as a

cosmetic.

U. S. Food and Drug Administration

Center for Food Safety and Applied Nutrition

Office of Cosmetics and Colors

July 8, 2002

----------

Canada does consider soap a cosmetic so other rules apply there.

I've bought & made soap noodles before. It's just saponfied oils

resulting in soap & glycerin, run through a cheese grater or a food

processor resulting in something that looks like mozerella

cheese. " Reconsistuting " consists of melting the soap down in either

a double boiler process,microwave, crockpot, or any means rendering

it back to a gelatenous mass. If the soap is " new " or fresh enough,

liquid may not be necessary, but it's just fun to add tea, aloe

juice, hydrosols or goat milk. This can add loads of drying time

before it's even usable. Also, the addition of hydrosols, herbs &

milk can cause spoilage & preservatives might need to be added. I've

never sold any soap made from " noodles " , for these reasons and the

fact that they can be difficult to deal with as well as looking

rather " rustic " when done.

As far as labeling, if I were to sell them I'd do as the vendor

suggests adding my additions to the label. Even if you make no claims

about your soap, it's generally considered polite to advise the

potential buyer of what they may be getting. However, a cruise

of the mall will show you that not all sellers of natural process

soaps extend the same courtesy.

Hope this makes it this time! I'll return to the " wings " and continue

to read this terrific site with interest.

Sue Flood

> > Soapmakers - How do y'all label YOUR cold process soaps? And is

> there a RELIABLE source of information on the net for cold process

> soapmaking, soap noodles and making bath products in general?

>

> Thanks for all the help,

> Lori

[Guest guest]

Actually you do not have to list any ingredients on your soap IF you

are not making " any claims about the soap that it does anything other

than clean " according to the FDA rules.

If you make other claims then your soap becomes a cosmetic according

to the FDA and you must list ingredients that constitute the soap or

the results after the process.

Personally I prefer " what went into " the soap listing, which means

listing the all the oils/fat/butters, water and sodium hydroxide,

etc..

Since your not listing the word " lye " but " sodium hydroxide " then

most consumers are not intimidated with the old myth that it is lye

soap!

Lye got a bad rap from home-crafters in the early 20th century that

made soap that was quite lye heavy and actually burned the skin when

used....I remember that ! LOL!

Modern soap making methods have precise calculations and measurements

for the amounts of lye [sodium hydroxide], that eliminate this excess

lye in the final product-soap.

The vendor of your soap noodles is misinformed as to ingredient

listings mandated by the FDA. And if she is misinformed about that

she may be misinforming you as to the ingredients actually in the

soap noodles too, so buyer beware.

hth

Sherry B

[Guest guest]

I realize what the rules are. My point was that if one chooses to label

ingredients, and labels according to what that manufacturer advised, one

would be in violation of the rules - because the list would not be accurate,

because it would not account for the glycerin or superfatted oils. Hope

that makes sense - it does to me, but then I worked 12 hours today...lol.

Merin

http://www.goodcleansoap.com

Selfishness is not living as one wishes to live, it is asking others to live

as one wishes to live. -- Wilde

> Soap & glycerin are a natural byproduct of the soapmaking process.

> As long as no claims are made, it's just soap and all you " have "

> to do is label it as soap. If any " claims " are made; " moisturizes,

> exfoliates, etc. " , then it's a cosmetic and needs to be labelled

> accordingly. However, it has always been my understanding that

> whether or not any claim is made, it's generally considered polite to

> let the buyer know what's in it so they can make an informed decision.

[Guest guest]

But that's not the case. Combining lye & oils result in soap &

glycerin. Gycerin, is a product, not an additive. So's the soap.

Listing the oils involved would cover any superfatting if indeed

there is any, which is not necessarily the case.

See:

http://vm.cfsan.fda.gov/~dms/cos-215.html

" Soap is a category that needs special explanation. That's because

the regulatory definition of " soap " is different from the way in

which people commonly use the word. Products that meet the definition

of " soap " are exempt from the provisions of the FD & C Act because --

even though Section 201(i)(1) of the act includes " articles...for

cleansing " in the definition of a cosmetic -- Section 201(i)(2)

excludes soap from the definition of a cosmetic. "

Sue Flood

> I realize what the rules are. My point was that if one chooses to

label

> ingredients, and labels according to what that manufacturer

advised, one

> would be in violation of the rules - because the list would not be

accurate,

> because it would not account for the glycerin or superfatted oils.

Hope

>

[Guest guest]

The manufacturer was advising the person to list " saponified oils of

(blah) " . That's true, there are saponified oils of whatever, but there are

also free oils of whatever, and glycerin, and that has to be accounted for

as well. If one labels in the " what went in " manner, they are covered as

you describe below. But if one tries to avoid listing lye on their label by

listing " saponified oils of... " , they are not covered.

Merin

http://www.goodcleansoap.com

Selfishness is not living as one wishes to live, it is asking others to live

as one wishes to live. -- Wilde

> But that's not the case. Combining lye & oils result in soap &

> glycerin. Gycerin, is a product, not an additive. So's the soap.

> Listing the oils involved would cover any superfatting if indeed

> there is any, which is not necessarily the case.

> See:

> http://vm.cfsan.fda.gov/~dms/cos-215.html

[Guest guest]

>That's true, there are saponified oils of whatever, but there are

>also free oils of whatever, and glycerin, and that has to be accounted for

>as well.

and in some cases, whatever unsaponifiables.

Maurice

--------------------------------------------------------

Maurice O. Hevey

Convergent Cosmetics, Inc.

http://www.ConvergentCosmetics.com

-------------------------------------------------------

[Guest guest]

Yeah, that too. There are just too many variables to labeling with " what

came out " , and since I don't have access to the testing facility nor the

funds to make it happen, I just label what went in.

Merin

http://www.goodcleansoap.com

Selfishness is not living as one wishes to live, it is asking others to live

as one wishes to live. -- Wilde

>

>

> >That's true, there are saponified oils of whatever, but there are

> >also free oils of whatever, and glycerin, and that has to be accounted

for

> >as well.

>

> and in some cases, whatever unsaponifiables.

[Guest guest]

The " what went in " labeling would be inaccurate for the simple reason

that " what went in " is not what you have after saponification. By all

means, label anyway your comfort level dictates. I would however,

once again, urge anyone confused about this to check the FDA site and

then go from there.

---------------

http://vm.cfsan.fda.gov/~dms/cos-215.html

And what if it's " soap " ?

Soap is a category that needs special explanation. That's because the

regulatory definition of " soap " is different from the way in which

people commonly use the word. Products that meet the definition

of " soap " are exempt from the provisions of the FD & C Act because --

even though Section 201(i)(1) of the act includes " articles...for

cleansing " in the definition of a cosmetic -- Section 201(i)(2)

excludes soap from the definition of a cosmetic.

How FDA defines " soap "

Not every product marketed as soap meets FDA's definition of the

term. FDA interprets the term " soap " to apply only when --

The bulk of the nonvolatile matter in the product consists of an

alkali salt of fatty acids and the product's detergent properties are

due to the alkali-fatty acid compounds, and

The product is labeled, sold, and represented solely as soap [21 CFR

701.20]. "

Sue Flood

> The manufacturer was advising the person to list " saponified oils of

> (blah) " . That's true, there are saponified oils of whatever, but

there are

> also free oils of whatever, and glycerin, and that has to be

accounted for

> as well. If one labels in the " what went in " manner, they are

covered as

> you describe below. But if one tries to avoid listing lye on their

label by

> listing " saponified oils of... " , they are not covered.

>

>

[Guest guest]

" What went in " is a perfectly valid method of labeling soap, for the same

reason that it's perfectly valid to label a cake with the ingredients you

used to make it.

Merin

http://www.goodcleansoap.com

Selfishness is not living as one wishes to live, it is asking others to live

as one wishes to live. -- Wilde

> The " what went in " labeling would be inaccurate for the simple reason

> that " what went in " is not what you have after saponification. By all

> means, label anyway your comfort level dictates. I would however,

> once again, urge anyone confused about this to check the FDA site and

> then go from there.

[Guest guest]

In a message dated 10/13/2003 10:28:45 AM Central Daylight Time,

smuf56@... writes:

> Are you saying it's correct to start the label with Sodium Hydroxide and

> move

> into INCI terms for the oils?

This would not be correct, either, as in most recipes the sodium hydroxide

quantity would place it within the other INCI names. It is indeed properly

understood to list oils, liquids, and sodium hydroxide as they went in by the

descending-quantity, and gives no misrepresentation.

It would seriously misrepresent the product were one to label the

" what-came-out " and not account for each and every finished element (ie,

unsaponifiables)

by their " finished-product " descending quantity.

If those who prefer to label by " finished-product " have the money for the

analysis of each sodium whateverate (which involves more fatty acids than most

soapmakers know of) and whatever else is there in the appropriate order, great.

Most of us do not have those resources, but do represent our products

appropriately and legally.

-

[Guest guest]

Perhaps we need to clarify what you mean by " what went in " . Are you

saying it's correct to start the label with Sodium Hydroxide and move

into INCI terms for the oils? IF you are, your not telling your

customer anything about what's in your product after saponification.

What went in is not soap & glycerin, nothwithstanding any residual

unsaponified oil. Isn't actual content the point behind labeling to

begin with? IMO soap making isn't at all comparable to cake baking.

Sue Flood

www.scentsorysoapsnsuch.com

> " What went in " is a perfectly valid method of labeling soap, for

the same

> reason that it's perfectly valid to label a cake with the

ingredients you

> used to make it.

>

> Merin

> http://www.goodcleansoap.com

> Selfishness is not living as one wishes to live, it is asking

others to live

> as one wishes to live. -- Wilde

>

>

> > The " what went in " labeling would be inaccurate for the simple

reason

> > that " what went in " is not what you have after saponification. By

all

> > means, label anyway your comfort level dictates. I would however,

> > once again, urge anyone confused about this to check the FDA site

and

> > then go from there.

[Guest guest]

>The " what went in " labeling would be inaccurate for the simple reason

that " what went in " is not what you have after saponification. By all

means, label anyway your comfort level dictates. I would however,

once again, urge anyone confused about this to check the FDA site and

then go from there.<

I seem to need to remind members that this is not a soap list. I don't mind some

soap discussion, but when the same subject starts to drag on and no new

information is forthcoming you either need to drop the subject or take it over

to The Think Tank.

For the record: The list position, meaning Maurice, , and myself, is that

you label with what goes into the soap, not with the saponified method. It gives

the consumer a far more accurate picture of what they are washing with. How can

you accurately label with the saponified method when you are required to list

ingredients in decending order of prominance, and the majority of people have no

idea of what is in their finished bar of soap other than what they have heard or

read on other lists?

The FDA regulates cosmetics. They DO NOT regulate TRUE soap, so why would anyone

want to go to the FDA site for labeling information on a product the the FDA

does not regulate. Think about that one!

Pat.

Peace, Joy, Serenity

House of Scents tm. Body Oils, Fragrance Oils, Incense, Candles, Soap, Etc.

pat@...

http://www.houseofscents.com/