What a plain soap may say

Cleaning claims

Cleans, washes, lifts grease, cuts through baked-on food, rinses clean, leaves no residue. These describe what the product does mechanically and none of them is a germ claim. They are also what buyers actually care about for a dish soap.

Sensory and cosmetic claims

Gentle on hands, lightly scented, free of a named ingredient, rich lather. A cosmetic may say how it feels and smells and what it leaves out, which covers most of the positioning a small brand wants.

Composition claims, if they are true

Made without a particular surfactant, plant-derived, a named percentage of something. These are checkable facts rather than performance claims, and checkable is a good place to compete.

Where the line sits

The moment a claim is about microorganisms rather than dirt, it moves. Hygienically clean, germ-free, protects against bacteria are all the regulated side of that line even though they sound like ordinary marketing.

Be careful with imagery too

Illustrations of germs, hospital or laboratory imagery, and visual comparisons implying microbial reduction make the claim without the words. The overall impression is what counts.

Write the list before the artwork

Every claim you intend to make, in one document, checked once. It is the same control the supplements and sun properties arrive at, because it is the same class of failure in three different statutes.

Performance claims still need to be true

Cuts grease and rinses clean are not regulated the way a germ claim is, and they are still claims a buyer relies on and an advertising authority can look at. Outside the drug and pesticide regimes you are still in ordinary truthfulness territory.

Free-from claims cut both ways

Naming what a product leaves out is checkable and popular, and it implies something about the ingredient you excluded. That is fine when the exclusion is a genuine formulation choice and awkward when it is only positioning.

References