Wednesday, 24 August 2011

Why read the labels? and what are the requirements?

Why read the labels on your soap? For information of course! 
So you or anyone else can check for allergens. I work with natural ingredients but these can still be allergenic I've had customers allergic to dairy, avocado, lavender and tea tree to name a few.

It also lets you compare different products that you might be looking at. Does it have any of the more expensive oils like olive, almond or some of the butters or are they using lots of cheap oils like soy or canola. Do they use cheap fragrance oils (there are expensive ones too) or some of the more expensive essential oils? This will give you an indication of whether you paying for pretty packaging or good soap.

Front label
I was browsing though the rack of soaps at a gift shop and this one left me shaking my head. According to the label on the front it was moisturising olive oil soap. A bit expensive as you can easily pick up olive oil soap for $5-6 depending on what else is in them but I was in a gift shop.

So while a little expensive it seems reasonable until you turn it over and look at the ingredients. The main oils it contains palm oil and palm kernel oil, no olive oil in sight. This soap would in no way feel like a conditioning pure olive soap. Oh and don't get all excited about triple milled, almost all commercial soap is milled these days so it is nothing particularly special it just sounds good.

Back Label

So just what are the requirements in Australia?
One of the most confusing things I found when I was first looking at selling soap was trying to determine what was required for labelling ingredients here in Australia. Why was I confused you might wonder? Have a look at what is around next time you are out shopping.

I went and walked through the local gift stores and found a multitude of possibilities. Nothing at all, the scent, the ingredients listed as scent and all vegetable oil, saponified oil of xyz, common names ie olive oil, sodium hydroxide, water or full INCI (international nomenclature of cosmetic ingredients) listing.

Anyway I researched and found out that soap is covered by a wide range of different government agencies, so as usual in Australia nothing is straight forward.

To start with soap is considered a cosmetic here and therefore it's labelling is covered by the ACCC

In simple terms all ingredients need to be listed in descending order of quantity at point of sale. Ok, got that one it seems simple enough but that meant that approximately 70% of the soap I saw on my walk around the shops weren't being labelled as required legally in Australia.

Oh another thing for you as a customer to consider is where the ingredient is listed. If it is listed below the sodium hydroxide you are looking at there being less than roughly 12% (it depends on the exact soap recipe) of it in handmade soap.

To make and sell home made soaps we also need to be registered as chemical introducers through NICNAS. Why? Because the reaction to make soap alters it chemically to new compounds and anyone who manufactures or imports chemicals into Australia must be registered. You can check out more here NICNAS . In the long term NICNAS is supposed to be ensuring chemicals in Australia are assessed for their safety. If you just make home made soap and don't sell any you don't need to be registered with NICNAS

OK so we've listed the ingredients and have registered ourselves with NICNAS. Is that enough? Well......... yes but you also have to be careful about any claims you make about your soap as some of these can potentially land you in hot water with the regulators.

You can't claim it is an insect repellant (soap being a wash off product wouldn't work well anyway but I've seen claims it is). If you do it is then covered by  APVMA and you would have to have it tested to prove it's effective and register it. Make those claims without doing this and you are likely to face a whole lot of expensive trouble.

You also are not supposed to make any medical claims like it cures eczema, cancer, insomnia, hives or anything else you can think of. Do so and you need to be dealing with the TGA and registering products through them.

You see why it confusing ;-). After all how hard can it be to just make a bit of soap to sell. Well, more than you would expect it seems.

Oh and while I don't on sell any of my essential oils I know a few who do. Another list you'll need to look if you want to do this is the poisons schedule as some of the common essential oils are covered by this and as such require special labelling and packaging.

Cheers. I just hope I haven't confused you even more.

1 comment:

  1. LOL @the red tape :-) I guess the big commercial boys feel they can ignore the regulations with impunity ...