Bath bomb label requirements (US, 2026)
Bath bombs look like a craft product, but to the FDA they are cosmetics — and bubble-producing ones are the rare handmade product with a federally mandated, word-for-word warning. Here is what a US bath bomb label actually needs.
1. A bath bomb is a cosmetic — no soap exemption
The "true soap" exemption (21 CFR 701.20) only covers products whose cleaning action comes from saponified oils and which are sold only as soap. A bath bomb is citric acid + baking soda + fragrance, intended to scent and condition the bath — a cosmetic under the FD&C Act, so the full FDA cosmetic label applies: identity, net weight, complete ingredient declaration, business name and address, and the MoCRA contact line.
2. The ingredient list (the part most makers skip)
- All ingredients in descending order of predominance by weight — for most bombs that means Sodium Bicarbonate first, then Citric Acid (21 CFR 701.3);
- Ingredients at 1% or less may follow in any order; color additives go last;
- Use INCI names: Sodium Bicarbonate, not “baking soda”; Butyrospermum Parkii (Shea) Butter, not “shea butter”;
- Fragrance oils may be declared simply as “Fragrance”;
- Letter height at least 1/16" — or 1/32" if the package has under 12 in² of labeling surface (21 CFR 701.3).
3. The warning almost everyone misses: foaming bath products
If your bomb produces foam or bubbles using a detergent/surfactant (SLSa, SCI, coco betaine — i.e. bubble bars and "bubble bombs"), 21 CFR 740.11 requires this caution, verbatim in substance:
“Caution — Use only as directed. Excessive use or prolonged exposure may cause irritation to skin and urinary tract. Discontinue use if rash, redness or itching occurs. Consult your physician if irritation persists. Keep out of reach of children.”
Products labeled for adult-only use can adjust the children's phrase per the regulation, but the warning itself is not optional. A plain fizzing bomb with no foaming surfactant is not a “foaming detergent bath product” — but the moment you add bubbles, this applies.
Separately, if you haven't adequately substantiated the safety of the product, 21 CFR 740.10 requires: “Warning — The safety of this product has not been determined.”
4. Colorants: approved additives only
- Anything added to color the bomb (or the bathwater) must be an FDA-approved color additive — FD&C certified dyes (the water-soluble bath colors), iron oxides, micas, titanium dioxide (21 CFR Part 73 and the certified-color lists);
- Botanical powders (beet, spirulina, turmeric) used for color are not approved color additives;
- “Cosmetic grade” on a supplier listing is not the test — the additive must be on FDA's lists for the use.
5. Net weight, identity, business line, MoCRA
- Identity ("bath bomb" / "bath fizzy") on the front panel;
- Net weight in dual units — e.g. Net Wt 4.5 oz (128 g) — bottom 30% of the front panel, type size scaled to label area (21 CFR 701.13);
- Business name & place of business, with “Distributed by…” if applicable (21 CFR 701.12);
- MoCRA contact line — since Dec 29, 2024, a US address, US phone, or monitored website/email for adverse-event reports (FD&C §609(a)). The small-business exemption does not cover this.
6. Shrink-wrapped naked bombs still need labels
“No room on the product” doesn't waive the rules — use a tag, wrap band, or box. If you sell at markets from a bulk basket, the required information has to be available to the buyer at the point of sale.
Generate it instead of memorizing it
The Inkurate generator applies every rule above to your recipe — INCI ordering, the 740.11 foaming-bath check, colorant screening, net-contents formatting, the MoCRA line — and cites the regulation for each element. The preview is free.