We always recommend erring on the side of caution when it comes to making claims about your products. However, you may need to provide cautionary labeling on the product if the product meets the definition of a “hazardous substance” under the Federal Hazardous Substances Act (FHSA) – a law administered by the CPSC. Common cosmetics as defined by the FDA would be lotion, bath gel, bath bombs, bath melts, shampoo, and conditioner to name a few. Stick to descriptors like moisturizing, smoothing, etc. The same goes for cosmetics.

If there are claims that it treats any skin conditions like acne or eczema, it's considered a drug.

If you plan to sell your products, it’s important to research the Food and Drug Administration (FDA) regulations first.
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For a bar of soap that contains saponified oils there wold be no need for SLS. A determination that a product is toxic may be based on the results of animal tests or on human experience. Drugs must meet different requirements. Just Pigments for all you pigments needs. It has to be made of fats/oils and an alkali like lye. ( Log Out / 

CSPS I am just making a guess by the look of the ingredient list. Sec. Your browser's Javascript functionality is turned off. In the regulatory world, traditional soaps made primarily from fats and alkalis are regulated by the CPSC. Post was not sent - check your email addresses! Ultimately, it is the responsibility of a manufacturer or importer of a product to determine whether its product meets the definition of a “hazardous substance” and if so, make sure to fulfill its obligations under the FHSA for appropriate precautionary labeling.

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If it’s moisturizing, it’s a cosmetic.

However, many “soaps” on the market today are, in fact, not just soap. Any views expressed in this communication may be changed or superseded by the Commission. Most store-bought soap has added synthetic detergents, so it's classified as a cosmetic instead of soap.

Manufacturers of children’s soaps must issue a Children’s Product Certificate for their products, verifying compliance with these standards. Market Your Handmade Soap with a Personalized Plan. Change ). If a product is intended to affect the way a person’s body works, or to treat or prevent disease, it’s a drug, but sometimes it is both a cosmetic and a drug depending on its claims. That is a good question and I think you are correct.
These products must bear a permanent tracking label, and they must be tested for total lead content by a CPSC-accepted third party laboratory. It must be labeled and marketed only as soap meant to cleanse. The FDA’s regulations address three conditions: You can read the entire FDA regulation at: 21 CFR §701.20.

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