Labelling requirements and standards differ from country to country. Here in New Zealand, soap is listed as a cosmetic product, which falls under the responsibility of the Environmental Protection Authority (EPA). We contacted the EPA to clarify exactly what needs to go on a soap label.
What must be labelled?
All cosmetic products, which includes soap, must be labelled clearly, in english, on its packaging, or as an insert, or as a separate leaflet at the point of sale.
The only exemption to this requirement is for samplers or testers, which do not need to be labelled.
What must be included on the soap label?
The following must be on the label:
- Batch code
- List of ingredients
- Contact details of the supplier/manufacturer
- If applicable, list of hazardous substances, information about its safe use and disposal recommendations
What is not required on the label?
- weight or volume, you can add it on the label, but it is not a legal requirement
- use by date or expiry date, this is only required for products that become hazardous (go off or become mouldy) over time
Your batch code should be able to uniquely identify the items belonging to a particular batch in case there is a problem and needs to be recalled. This unique identifier could be a combination of date and numbers, or a date and product name, or a serial number, or anything in any way that allows you to uniquely identify each batch, allowing you to track down the individual items at a (much) later time in a recall.
List of ingredients
In New Zealand, regulations require that we list the ingredients contained in the product (unlike some other countries, where they list the ingredients used to make the product). This means that, in soap, we do not declare lye (caustic soda, NaOH, sodium hydroxide etc) as an ingredient, instead we need to list the ingredients produced by the chemical reaction: the saponified oils, glycerine, water, remaining oils, as well as all the other ingredients we have added.
“We require that the label must contain a list of ingredients in the final cosmetic product. We do not require a list of the ingredients used in the manufacturing of the cosmetic product on the label.”Lydia Harjadinata, Advisor Hazardous Substances Applications, EPA.
The following must be declared on your label:
- all the ingredients contained in the final product (in other words, not the ingredients used to make the product, but the ingredients contained in the final product)
- colour additives
- fragrance, which must be declared as ‘fragrance’ or ‘perfume’ or by the ingredients in the fragrance
- nano particles must be indicated by the word (nano) in brackets following the name of the ingredient
Ingredients can be declared using their common names or INCI names.
Ingredients need to be listed in descending order (from highest quantity to lowest quantity) by weight, except those in quantities of less than 1%, which can be listed in any order.
The reason for the contact details is in case there is an issue with a product, and you need to be contacted for further information or to follow up, for example, if there needs to be a recall. You do not need to state your private contact details, but you do need to supply some information where you can be reached, for example a business phone number or a physical address. The label must contain enough information for you to be contacted in person or by telephone.
NZ regulations require that, if applicable, cosmetics list hazardous materials, information about its safe use and its disposal.
Usually soap does not contain any hazardous materials, and is in itself non-hazardous. However, you do need to address its safe use.
For soap, this means you need to have something on your labelling along the lines of ‘For external use only. If irritation occurs, discontinue use’.
The other substances that need to be declared are components in fragrances, such as d-limonene, linalool, etc., which can cause irritations. You can find more information about this in the resources below.
Example and template for you to use
You can use the following editable template for your soap labels if you wish: Soap Label NZ – cigar band (Canva free)
Note this uses the free version of Canva, no subscription required, but you will need to sign up. It is the same label as in the image above.
More information and resources
For more information about what your product needs to comply with, here are the official notices and standard:
- the Cosmetic Group Standard
- the Hazardous Substances (Safety Data Sheet) Notice 2017,
- the Hazardous Substances (Packaging) Notice 2017, and
- the Hazardous Substances (Disposal) Notice 2017.
- Hazard classification – HSNO to GHS7 Correllation Table