What to say instead
Updated
On this page5
Every claim a soap maker wants to make has a version that describes the product rather than its effect on a person.
Describe the soap, not the skin
That is the whole rule, and it works for the exempt position and reduces risk in the cosmetic one too.
What is in it, how it was made, how it behaves, what it smells like: all properties of the bar.
What it does to skin: a claim.
What is always safe
The ingredients: made with olive oil, shea butter, goat milk, oatmeal. Naming what went in is a fact about the product.
The process: cold process, hand cut, cured for six weeks, made in small batches.
The lather: a thick creamy lather, a dense bubbly lather, a long-lasting bar. Properties of the soap.
The scent.
The appearance.
And the origin: local honey, a named farm's milk, foraged botanicals. The strongest thing a small maker has and entirely claim-free.
The substitutions
"Moisturizing" becomes "made with shea butter and olive oil".
"Gentle on skin" becomes "a mild bar with a creamy lather".
"For dry skin" becomes "a high olive oil bar".
"Nourishing" becomes "superfatted with avocado oil".
"Deodorizing" becomes "scented with tea tree and eucalyptus".
"Healing" has no compliant version. Do not reach for one.
Why the compliant version is better copy
"Moisturizing" is what every bar in the supermarket says and nobody believes.
"Twelve percent shea butter, cured eight weeks, scented with nothing but lavender from the next valley" is specific, checkable and the reason somebody buys a handmade bar rather than a machine-made one.
The rule that keeps you compliant is also the rule that makes you sound like a maker rather than a brand.