So, I finally have my answer. The FDA Compliance Office says I can label my cosmetic soaps in one of two ways: either “AT FORMULATION” or “AT USE.”
“At Formulation” requires the listing of lye, either sodium hydroxide or potassium hydroxide.
“At Use” requires the use of the terms for the salts of the fatty acids that the oils become, for example, sodium cocoate, sodium palmitate.
Either customers have to be educated on the fact that lye reacts completely and is not present in the finished product, or that “chemical sounding names” are really just natural oils converted into soap.
I’m going with “At formulation.”
Any thoughts? Please send me your comments.
