Soap is made through saponification – an alkali substance is added to oil and saponified oil (soap) is produced, along with a number of by products. However, as this involves the creation of a new substance, evidently synthetic, some question whether soap should be classed as organic, and if it is, how its ingredients should be labeled.
Under the current United States Department of Agriculture’s (USDA’s) National Organic Program, soaps made from agricultural ingredients can be classed as organic as long as they comply with the NOP’s organic regulations.
Earlier this summer, NOP published a draft document supporting the decision to certify soap as organic, as long as the raw materials comply with NOP regulations, and attempted to clarify how the product’s ingredients should be labeled.
Cleaning up the labeling system
Theoretically there are two ways of labeling the ingredients in a soap – naming the raw materials or naming the products of the saponification reaction.
According to the NOP, the ingredients list should include the raw materials, synthetic and organic, not those produced by the reaction.
NOP invited public comment on the document and AHPA has publicized its support of organically certifying soap, but it claims that further clarification is still needed on how to label the ingredients in the product.
“Our strong support for extending the NOP to include soap made from agricultural ingredients is consistent with our established position that the OFPA [Organic Food Production Act] is best applied broadly to all organic products based on content and irrespective of end use,” said AHPA President Michael McGuffin.
In its document, NOP gave an example of the proposed labeling system ‘saponified organic oil (organic coconut oil, potassium hydroxide), water, glycerin, beet juice color’.
But this is unacceptable to FDA, the body that regulates soaps, if they make any more than a simple cleansing claim, according to AHPA, as neither the term ‘saponified oil’ nor the term ‘soap’ is accepted on cosmetic labels.
“AHPA encourages NOP to initiate communication with FDA to clarify the issue and we look forward to continuing to work with NOP and FDA on this subject,” said McGuffin