Is my soap label legal? The 7-point self-check
You can check a handmade soap or skincare label against the US federal rules in about two minutes. Grab one of your labels and walk down this list — each point cites the actual regulation, and the failures listed are the ones inspectors and marketplace reviews actually catch.
First: which rulebook are you under?
Everything depends on one question. Is your product true soap — saponified oils, cleaning by the alkali–fatty-acid salts, sold only as soap (21 CFR 701.20)? Then it's a CPSC/FPLA product and the checklist is short. Say “moisturizing,” “exfoliating,” “soothing,” “deodorizing” anywhere on the label or listing, or use a melt-and-pour/syndet base, and it's an FDA cosmetic — the full checklist applies. Say “treats eczema/acne,” “antibacterial,” “SPF” and it's a drug — none of this checklist is enough, and that's out of scope for handmade sellers without an OTC monograph.
The 7-point check
- 1 · Identity, on the front. The product says what it is — “Handmade Soap,” “Body Butter,” “Sugar Scrub” — on the principal display panel (21 CFR 701.11). A pretty product name alone (“Lavender Dreams”) is not an identity.
- 2 · Net contents, dual units, bottom 30%. “Net Wt 4.5 oz (128 g)” — both US and metric units, in the bottom 30% of the front panel, minimum type size scaled to label area (21 CFR 701.13; FPLA). Solids declare weight; liquids declare fluid volume. The jar's printed capacity is not your net weight.
- 3 · Ingredient list in the legal order (cosmetics only). INCI names, descending order of predominance; ingredients ≤1% may follow in any order; color additives last; fragrance blends may be declared as “Fragrance” (21 CFR 701.3). “Olive oil, coconut oil…” in recipe order is the single most common fail. Full ordering guide →
- 4 · Business name and address. Your business name and place of business; street address may be omitted only if you're listed in a current directory; “Distributed by…” qualifier if you don't manufacture it (21 CFR 701.12).
- 5 · The MoCRA contact line — the 2024 rule most labels still miss. Every cosmetic label needs a US address, US phone number, or website/email through which you can receive adverse-event reports (FD&C §609(a), in force since Dec 29, 2024). The $1M small-business exemption covers facility registration and product listing — not this line. MoCRA guide →
- 6 · Warnings, where triggered. If you haven't adequately substantiated the product's safety, 21 CFR 740.10 requires the verbatim warning “Warning — The safety of this product has not been determined.” Foaming bath products have their own required caution (21 CFR 740.11).
- 7 · Colorants from the approved list only. Cosmetic colorants must be FDA-approved color additives (21 CFR Part 73 / certified colors) — and some (ultramarines, chromium greens) are illegal in lip products. Botanical powders and candle/soap dyes are not approved cosmetic colorants.
If you sell online, the listing counts too
Intended use is judged by everything you say — the Etsy description, the market-stall sign, the Instagram caption. A perfectly labeled bar becomes a cosmetic (or a drug) the moment the listing makes the claim. Check your wording everywhere, not just on the paper.
Check it in 60 seconds instead
The Inkurate generator runs this exact checklist against your recipe and label details — classification, INCI ordering, net-contents format, the MoCRA line, conditional warnings, colorant legality — and cites the regulation for every element. The preview is free, there's no signup, and your recipe never leaves your browser.