Is handmade soap a cosmetic? US labeling rules for soap (CPSC vs FDA)
In the US, a bar is regulated as "soap" by the Consumer Product Safety Commission only if it is mainly fat-and-alkali soap, gets its cleaning from that soap, and is sold only as soap. Claims such as moisturizing or deodorizing make it a cosmetic, regulated by the FDA, and claims to treat skin conditions or kill germs make it a drug. Cosmetics have specific label requirements; true soap has far fewer.
Not legal advice. This is a plain-language summary of public guidance, checked October 2026. Rules change and depend on where and how you sell. Read the primary sources linked below, and ask the regulator or a qualified adviser about your products. Soap Ledger helps you keep records; it does not make a label or a product compliant.
The three-part test for "soap"
The FDA's definition (in 21 CFR 701.20 (definition of soap)) treats a product as soap only when all three are true (FDA: Frequently asked questions on soap):
- What it's made of: mostly alkali salts of fatty acids, the material you get when oils react with lye.
- How it cleans: the cleaning comes from those salts. Synthetic detergents mean it isn't soap in this sense, even if the label says "soap".
- How it's sold: labeled and marketed only as soap.
Products that meet the definition are regulated by the CPSC, not the FDA (FDA: Frequently asked questions on soap).
Words that change the category
- Cosmetic: sold for purposes such as moisturizing the skin, making the user smell nice, or deodorizing (FDA: Frequently asked questions on soap).
- Drug: sold to treat or prevent disease, such as treating acne or eczema, or killing germs. A product can be both a cosmetic and a drug and then has to meet both sets of rules (FDA: Frequently asked questions on soap).
CPSC adds a caution: under the Modernization of Cosmetics Regulation Act of 2022 (MoCRA), a product containing ingredients commonly recognized as cosmetic may be treated as a cosmetic even without cosmetic claims, and it suggests asking the FDA if you're unsure (CPSC: Soap business guidance).
If it's true soap (CPSC)
- CPSC has no soap-specific labeling rules. A soap that meets the definition of a hazardous substance needs precautionary labeling, which CPSC says is uncommon for ordinary soap (CPSC: Soap business guidance).
- Soap made mainly for children 12 and under is a children's product, with third-party lead testing, a tracking label and a Children's Product Certificate (CPSC: Soap business guidance).
- If a bar is labeled for cosmetic purposes, 21 CFR 701.20 says it must meet the cosmetic rules, including a net weight statement (21 CFR 701.20 (definition of soap)).
If it's a cosmetic (FDA)
- The label needs the product's identity and net quantity on the front panel, an ingredient list in descending order of predominance, and the name and place of business of the manufacturer, packer or distributor (FDA: Summary of cosmetics labeling requirements).
- Ingredients are named in a set order of preference, and fragrance may be listed as "fragrance" (21 CFR 701.3 (cosmetic ingredient labeling)). See INCI names for handmade soap.
- MoCRA facility registration and product listing: very small businesses (under about $1 million in average annual US cosmetic sales) are generally exempt, unless they make certain product types such as eye-area products; label contact details for adverse event reports, reporting serious adverse events, and keeping records still apply (Registrar Corp: MoCRA small-business exemptions).
Outside the US
- EU: handmade soap is a cosmetic. Labels need, among other things, the responsible person's name and address, nominal content, a batch number or reference, precautions where needed, and the ingredient list (Article 19 of Regulation (EC) No 1223/2009 on cosmetic products (Article 19: labelling); plain-language summary from HPRA (Ireland): cosmetic product labelling). A safety assessment and notification are required before sale.
- Canada: Health Canada treats soap as a cosmetic, including handmade products sold at craft sales; makers notify Health Canada that they are selling the product and give its ingredients (Health Canada: Regulatory information for cosmetics; Health Canada: Guide to completing cosmetic notification forms). Labelling rules are in the Health Canada: Industry guide for the labelling of cosmetics.
How Soap Ledger helps
Soap Ledger keeps the records behind a label (recipe versions, batches, lot numbers and ingredients) and prints batch labels with codes. It does not decide whether your product is soap, a cosmetic or a drug, and it does not certify a label as compliant.
Try it in the lye calculator. The lye calculator lists every ingredient by weight, which is where an ingredient list starts.
Sources
- FDA: Frequently asked questions on soap
- 21 CFR 701.20 (definition of soap)
- CPSC: Soap business guidance
- FDA: Summary of cosmetics labeling requirements
- 21 CFR 701.3 (cosmetic ingredient labeling)
- Registrar Corp: MoCRA small-business exemptions
- Regulation (EC) No 1223/2009 on cosmetic products (Article 19: labelling)
- HPRA (Ireland): cosmetic product labelling
- Health Canada: Regulatory information for cosmetics
- Health Canada: Guide to completing cosmetic notification forms
- Health Canada: Industry guide for the labelling of cosmetics
Written for Soap Ledger in our own words. Numbers in the examples are calculated by Soap Ledger's engine when the page is built. Last updated .