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Beyond the bar

Shampoo bars

By Dwight Davis, Founder

Updated

On this page5

The most requested adjacent product and the one where the category question bites hardest.

Two products with one name

A soap-based shampoo bar is real soap, formulated for hair.

A syndet shampoo bar is a solid synthetic detergent product that contains no soap at all.

They are sold side by side under the same name and they sit in different categories, which is why this page exists.

A true soap shampoo bar

Made the same way as any bar, with an oil blend chosen for lather and mildness.

It is alkaline, which is the well-known complaint: hair behaves differently after an alkaline wash, and an acidic rinse is the usual answer.

It can be exempt soap if it passes both conditions, and that is the trap: "shampoo" describes what it is for, and marketing it for hair condition is a cosmetic claim.

A syndet shampoo bar

Built from synthetic surfactants, pH adjustable, and it performs much more like liquid shampoo.

It fails the composition condition of the soap exemption, because the detergent properties are not due to alkali salts of fatty acids.

So it is a cosmetic, with an INCI declaration and MoCRA obligations, whatever it is called.

It is also a different manufacturing process, bought as surfactant raw materials and pressed or extruded rather than saponified.

The claim problem

Shampoo bars attract exactly the claims that move a product out of the exemption: volumizing, nourishing, strengthening, repairing.

Anti-dandruff moves it further, to a drug, because that is offered to treat a condition.

Which means most shampoo bars on the market are cosmetics, and the honest planning assumption is that yours will be too.

Build the cosmetic label from the start rather than discovering it after the print run.

References

21 CFR 701.20. FDA interprets "soap" to apply only to articles where the bulk of the non-volatile matter consists of an alkali salt of fatty acids, the detergent properties are due to those alkali-fatty acid compounds, and the product is labeled, sold and represented only as soap. ecfr.gov
US Food and Drug Administration. Is It a Cosmetic, a Drug, or Both? (Or Is It Soap?). How intended use, established by claims, decides which of the three a product is. fda.gov
INCI nomenclature for cosmetic ingredient declaration in descending order of predominance, which applies to a soap that is a cosmetic and not to exempt soap. fda.gov
US Food and Drug Administration. Registration & Listing of Cosmetic Product Facilities and Products under MoCRA, including the small-business exemptions and what they do not cover. fda.gov
Written from the federal regulation and FDA and CPSC 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.