Soap

Making soap, and the three things it can legally be

Updated October 2026

On this page10

Getting started The bar itself Soap, cosmetic or drug Making a batch What goes wrong Wrapping and presentation Selling it Growing the operation Tools and directories Beyond the bar

One product forks three ways. The soap exemption in 21 CFR 701.20 requires two things at once: the bulk of the non-volatile matter must be an alkali salt of fatty acids with the detergent properties due to those compounds, AND the product must be labeled, sold and represented only as soap. Pass both and you are exempt soap under CPSC. Say "moisturizing" anywhere and you are a cosmetic under FDA and MoCRA, with an INCI declaration. Say "antibacterial" and you are a drug. The other fact that shapes everything: six weeks of cure means every bar you sell already has to exist.

91 of 91 written. Every page names its source or says it has none.

Getting started

Before there is product.

Is a soap business for you What it costs to start How much time it actually takes Where the oils and the lye come from Equipment for a first batch Your first year, month by month Where the work happens What you have to register, and with whom What protects the maker Turning a recipe into a product Naming it without a problem later

The bar itself

Oils, lye, and what happens between them.

Saponification, and the number behind every recipe Oils, and what each one contributes Lye: sodium and potassium hydroxide Water, and the discount Superfat and lye discount Additives: clays, exfoliants and milk Fragrance and essential oils Color Cure, and what is happening during it

Soap, cosmetic or drug

The three-way determination.

Three categories, not two The exemption, and its two conditions The one word that breaks it If it is a cosmetic If it is a drug Syndet bars, melt and pour, and the composition test Staying exempt on purpose What to say instead

Making a batch

The day it gets made.

Choosing a batch size Weighing, not measuring Making the lye solution Temperatures, and why they matter Emulsion and trace Adding fragrance and color Molding Gel phase and insulation Unmolding and cutting Curing and storing

What goes wrong

Named failures, and when each one shows.

Seizing Ricing Separation and oil pooling Soda ash Dreaded orange spots Glycerine rivers Partial gel Lye pockets and lye heavy soap Sweating and glycerine dew Soft bars and short life The fragrance disappeared

Wrapping and presentation

Where the container decision lives.

Cure racks and airflow Wrap, box or naked Shrink, film and cigar bands Labels on a bar that is still losing water Bottles and pumps for liquid soap What size bar, and the weight problem Tamper evidence How it looks on a shelf Bulk, seconds and ends Case packing and shipping When stock goes off-condition

Selling it

Where the determination reaches the label.

What to charge What the label must carry, in each of the three cases Net weight, and the bar that keeps shrinking What you may legally call it Natural, and the Green Guides Selling at a market Selling online Selling wholesale What your state adds Insurance, and what your policy excludes Who you buy from

Growing the operation

What breaks first.

Making more of it Making batch 80 match batch 1 Equipment at the next size Having somebody else make it The contract The first person you pay What you have to write down

Tools and directories

Things to use rather than read.

Soap, cosmetic or drug? A check The lye calculation, and how to check one The cure log How many bars you will get Working out what to charge When it pays for itself Everything that has to be on the label The words, in the order you meet them

Beyond the bar

The obvious second products.

Liquid soap Shampoo bars Shaving soap Gift sets and collections Making it for somebody else

Written from the federal regulation and agency guidance named on each page, not from a laboratory or a legal practice. Whether a particular product and a particular label make exempt soap, a cosmetic or a drug is a determination about your product, and this is not that determination.