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Cosmetics inspection

Handmade soap inspection in India

A handmade soap inspection weighs bars against the declared weight after curing, cuts a sample bar to look for lye pockets and air holes, and checks surfaces for sweating, cracks, soda ash and orange rancid spots. Wrappers, labels and batch codes are checked against each market's artwork. Free alkali and microbiology are lab tests.

Typical products
Cold-process and hot-process bars from vegetable oils and lye; melt-and-pour glycerin bars; herbal, clay and charcoal bars; gift sets
Where it's made in India
No export cluster is verified, so we name none
Key rules
US 21 CFR 701.20 (true soap is regulated by CPSC, not FDA); EU Cosmetics Regulation 1223/2009 (soap is a cosmetic); India Cosmetics Rules 2020
Typical AQL
General II; 0 critical, 2.5 major, 4.0 minor; one bar per sample cut open

How handmade soap is made, and why it changes after cutting

Handmade soap is made in three ways, and each has its own weak points:

  • Cold process. Oils such as coconut, olive or palm are mixed with sodium hydroxide solution, poured into moulds, cut into bars and left to cure for several weeks. During curing, water evaporates and the bar loses weight and hardens. Bars packed too early are soft, heavy at packing and light on arrival.
  • Hot process. The same mix is cooked until the reaction is complete, then packed into moulds. Curing is shorter, but the surface is rougher and harder to keep uniform.
  • Melt and pour. A ready-made glycerin base is melted, coloured, scented and poured. Many bases contain synthetic detergents, which matters for how the product is classed in the US.

In India, soap is a cosmetic under the Cosmetics Rules, 2020, so the maker needs a cosmetics manufacturing licence. The Rules' Ninth Schedule ties toilet soap (IS 2888), transparent toilet soap (IS 11303) and bathing bars (IS 13498) to Indian Standards. Herbs, clays, charcoal and essential oils are added for colour and scent, and each one can bleed, speckle or shorten shelf life.

Soap or cosmetic: the label decides the rulebook

MarketRuleWhat it means for a bar
United States21 CFR 701.20A bar is "soap", outside the cosmetic definition, only if most of its non-volatile matter is alkali salts of fatty acids, its cleaning comes from those salts, and it is labelled and sold only as soap. Such true soap is regulated by the CPSC
United StatesFDA intended useA claim such as moisturising or deodorising makes the bar a cosmetic, with full cosmetic labelling. Antibacterial or acne claims make it a drug. Detergent-based bars are cosmetics even if called soap
United StatesCPSC children's productsA soap made mainly for children 12 and under needs a tracking label, third-party lead testing and a Children's Product Certificate; see CPSIA
EURegulation 1223/2009Toilet soaps are named among cosmetic products in the Regulation's recitals. Every bar needs an EU responsible person, a safety report, CPNP notification and Article 19 labelling, including the ingredient list and nominal weight
Great BritainUK cosmetics rulesNotification through the UK's Submit Cosmetic Product Notifications service and a UK responsible person's address on the pack

So one artwork rarely fits both markets. A bar labelled "nourishing shea soap" is a cosmetic in the US as well as the EU. The CPSC also notes that cosmetic ingredients alone may bring a bar under FDA. The inspector reads every claim on the wrapper against the version approved for the market on the order.

What we check on handmade soap

CheckHow it is checkedWhat fails
Bar weightUnwrapped and wrapped bars weighed on a calibrated scale; cutting date recorded to judge remaining lossBelow the declared weight, or so close to it that further curing will take it under
Cure and hardnessThumb pressure and edge test; days since cutting checked against the agreed cureSoft bars, bars packed before the agreed cure time
Cross-sectionOne sampled bar cut throughWhite pockets or liquid spots (possible unreacted lye), air holes, unmixed colour
SurfaceBars inspected under lightBeads of moisture (sweating), white soda ash, cracks, orange spots
OdourAgainst the retained sampleRancid or crayon-like odour, scent faded
Shape and stampSize with a calliper; logo stamp against the sampleUneven cutting, chipped corners, blurred stamp
WrappingShrink film, paper band or box; seal and fitOpen seals, film wrinkled over the label, box crushed
Labels and codesClaims, ingredient names, weight, batch code, origin and responsible person against artwork for each marketUnapproved claims, missing batch code, wrong market address

Common handmade soap defects and how they are classed

DefectTypical causeClass
Pockets of unreacted lye in the barPoor mixing or wrong weighing of the lyeCritical
Treatment claim on the wrapper, such as "cures eczema"Marketing copy not checked per marketCritical
Orange rancid spotsOxidised oils, too much unsaturated oil, heatMajor
Short weightPacked before curing finished; no allowance for lossMajor
Sweating or wet wrappersGlycerin drawing moisture in humid storageMajor
Cracked or broken barsOverheating in the mould, rough handlingMajor
Soda ash on the surfaceAir contact during early curingMinor
Faint or off-centre stampStamping too late or unevenlyMinor

Your defect list decides the final class. Free alkali, pH and microbiology are measured by an accredited lab on bars we seal; see lab testing coordination.

Packing, transit and your purchase order

Soap reacts to its surroundings. Bars sealed tight in film while still curing sweat and stay soft; bars packed loose in a humid monsoon warehouse pick up moisture; bars in a hot container lose scent and can spot. Heavy cartons crush the bottom layer of boxed soap. The inspector checks that bars were cured for the agreed time before wrapping, that cartons are dry and not overfilled, and that pallets are not stacked beyond the carton's strength.

Put these in your purchase order:

  • Method (cold, hot or melt and pour) and the oil blend.
  • Minimum cure time before wrapping, and weight at packing including a loss allowance.
  • Declared net weight and tolerance, and how it is printed for each market.
  • Approved claims per market; ingredient list approved by your safety assessor.
  • Fragrance or essential oil, with its IFRA certificate and safety data sheet.
  • Wrapping type and carton spec; batch code format.
  • The lab, the tests and the number of sealed bars per batch.

Soaps scented with essential oils share risks with essential oil orders. Book an inspection.

Sources

  1. 21 CFR 701.20, soap
  2. FDA: Is it a cosmetic, a drug, or both? (Or is it soap?)
  3. CPSC: Soap business guidance
  4. Regulation (EC) No 1223/2009 on cosmetic products (EUR-Lex)
  5. CDSCO: Cosmetics Rules, 2020
  6. GOV.UK: Submit a cosmetic product notification

Frequently asked questions

Why do our soaps weigh less when they arrive?

Handmade soap keeps losing water after cutting, faster in dry heat. If bars are packed early or weighed only at packing, they can arrive under the declared weight. Agree a cure time and a weight at packing with an allowance, and the inspector checks both.

What are the drops of liquid on our soap bars?

Usually glycerin dew, or sweating. Glycerin in handmade soap draws moisture from humid air. It is not harmful, but it wets wrappers and looks poor. Drier storage, curing before wrapping and breathable wraps reduce it.

Is handmade soap regulated by the FDA?

Not if it is true soap under 21 CFR 701.20 and labelled and sold only as soap: then the CPSC regulates it. Cosmetic claims, cosmetic ingredients or a detergent base can bring it under FDA as a cosmetic, and treatment claims make it a drug.

Do soaps sold in the EU need a responsible person?

Yes. Soap is a cosmetic in the EU, so it needs an EU responsible person, a safety report, notification through CPNP and full Article 19 labelling. Your importer or an appointed agent usually takes that role.

Can you check pH or free alkali at the factory?

Not to a lab standard. The inspector cuts bars to look for lye pockets and can do an indicator screen if you ask, but free alkali and pH for your file come from an accredited lab on sealed samples.

Know before it ships

Tell us the product, the factory's city and your ready date. We confirm the inspector, the notice time and the price before you book.

Book an inspection