What the FDA defines as ‘soap’


Today we are facing a potential pandemic with the rise of the coronavirus. The scare behind the increasing and rapid spread of the coronavirus has even world leaders hesitant of shaking hands with each other. CDC and other disease prevention programs are calling for people to make sure they wash their hands at all times to prevent spreading the virus. Doctors recommend that the best way to fully wash your hands is to sing ‘Happy Birthday’ in your head while washing your hands with soap and water. Considering water is a neutral agent in this equation, what is in the ingredients of soap that could prevent someone from getting the coronavirus. 

As we know soap cleanses surfaces and makes things, ‘cleaner’. When soap is added to water the processes work together to rid surfaces of bacteria and other ‘icky’ things. According to the Cleaning Institute, certain ingredients are added to soap to increase the effectiveness of soap and adjust the pH (to either control or modify the pH to make it safer and gentler for use). But with ingredient content now under magnification due to potentially harmful effects to human health, how is the FDA regulating soap ingredient content?

According to the FDA, there are two ways to define soap, ‘Ordinary soap’ and ‘Detergents’. Like anything on the market, the FDA has a different regulation strategy with their definition of what soap is and has different requirements. The FDA’s regulatory definition of soap comes in three parts. For the first part, it’s ‘what it’s made of’, according to the FDA for a soap to be regulated as a ‘soap’ the product must be composed of mainly the ‘alkali salts of fatty acids’ which is the combination of fats or oils and alkali such as lye. The next part is ‘what ingredients cause it’s cleansing action’, and in the eyes of the FDA in order to be regulated as a soap ‘alkali salts of fatty acids’ must be the only materials that result in the product’s cleaning action. And the final part is the FDA’s favorite tidbit to throw in when regulating things is the ‘intended use’. To be regulated as a soap it must be labeled and marketed only for use of soap.

’Ordinary soap’ is created by combining fats or oils and they are mixed with an alkali such as lye. The fats and oils which could be made from natural sources such as animals, vegetables or minerals are degraded into fatty-free acids which then are combined with alkali to form crude soap. When the lye reacts with the oils and turns into what starts out as liquid then forms into blocks of soap and if made properly, no lye remains, making this soap ‘organic’ and ‘natural’. There are very few soaps like this on the market unless your market is a farmers market or a totally ‘green’ market.

Most soaps bought in stores are considered ‘detergents’. ‘Detergents’ or ‘body cleansers’ whether they’re in solid or liquid form are actually synthetic products. These types of soaps are more popular amongst consumers because they make suds more easily in water and don’t form gummy deposits. According to the FDA ‘detergents’ do not meet the regulatory definition of ‘soap’, rather a cosmetic but legally companies can still sell these products like soap.

Depending on how the FDA defines soap products results in different regulation procedures. If a product meets the regulatory definition of a soap meaning its organically based, it will be regulated by a separate entity which is the Consumer Product Safety Commission, not the FDA. While if the soap is considered a cosmetic like most commercial soaps that are actually ‘detergents’, it’s regulated by the FDA but doesn’t need FDA approval before going on the market except for any color additives. In this case, it is up to the sole responsibility of the company to include ingredient content to the consumers and whether the company decides to properly label the products.

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