Soap Production Process
First, animal and vegetable fats and oils are saponified with alkali to produce sodium fatty acids. This process is the core step of the saponification reaction, but it is also the primary raw material for soap.
Second, other surfactants, functional additives, etc., may or may not be added as needed. There is a wide variety of these additives, which can be selected according to the characteristics of the product and market demand.
Then, different forms of soap are produced after milling, cooling molding, and other processes. These soaps not only have cleaning efficacy but also have moisturizing, antibacterial, deodorant, and other functions, which can meet the needs of different consumers.
Finally, for the fatty acid sodium salts used in the manufacture of soaps, different raw materials and formulations can produce other properties, such as sodium laurate, sodium stearate, sodium myristate, sodium oleate, and so on. These different fatty acid sodium salts can be applied to different types of soaps to meet market needs.
Does soap meet the definition of cosmetic? Does it implement registration and filing management according to cosmetics?
From the point of view of how soap is used (applied by friction), where it is applied (on the surface of the human body), and what it is mainly used for (cleaning), soap has the essential attributes of a cosmetic and meets the definition of a cosmetic. However, according to the second paragraph of Article 77 of the Regulation on the Supervision and Administration of Cosmetics, soaps are not fully applicable to the Regulation.
First, generally used for cleaning and other ordinary purposes of soap, such as regular washing products used only for human surface cleaning, should be managed by the general daily chemical products without needing registration and management by the unique cosmetics. However, if the soap claims to have special cosmetic effects, such as “whitening, sunscreen,” etc., it should be registered by the management of unique cosmetics. This is because this type of cosmetics has special effects; its safety and efficacy need to be more rigorously assessed and managed.
Therefore, whether the soap meets the definition of cosmetics and whether it is necessary to implement the registration of cosmetics by the record management, according to its specific use, application site, and primary purpose determined. If the soap is only used for cleaning and other everyday purposes, by the general management of daily chemical products; if it is claimed to have special cosmetic effects, by implementing exceptional cosmetics registration management.
Is “Liquid soap” not a cosmetic?
Currently, on the market for human “liquid soap” products, the name contains “soap,” but does not meet the QB / T 2485-2008 on the definition of soap. Although the name includes “soap,” it does not meet the definition of soap in QB/T 2485-2008, but it is similar to shower gel, hand sanitizer, and other products. These products usually contain detergents, moisturizers, preservatives, and other ingredients with cleaning, moisturizing, and antibacterial effects, suitable for human cleansing and maintenance. Therefore, combined with the product’s process formula, method of use, purpose, use of parts, and other determinations, it may still belong to cosmetics.
In QB / T 2485-2008, soap is defined as a solid cleaning cosmetics. The main ingredients are soap and surfactants, which have cleaning, moisturizing, and antibacterial effects. The “liquid soap,” “soap,” and other products in the composition and efficacy of soap are different. Therefore, these products may not belong to the soap category, but more similar to body wash, hand sanitizer and other products.
However, the classification of these “liquid soap” products must also be based on specific formulations, methods of use, purpose, and other factors to make a comprehensive judgment. If the formulation, method of use, and purpose of body wash, hand sanitizer, and other products are similar, they may be categorized as cosmetics. However, if they are more identical to soaps in formulation, method of use, and purpose, they may be considered a new type of cleansing cosmetic.
Do I need to obtain a manufacturing license to produce soap?
Whether or not a license is required to manufacture soap is a complex issue that requires consideration of several factors. First and foremost, soap is a standard household product, and its production process does not require particularly stringent licensing requirements. However, if the soap claims to have special cosmetic effects, such as whitening, sunscreen, etc., you must follow the “Cosmetic Supervision and Administration Regulations” to obtain the appropriate production license.
In addition, soap production also needs to comply with a series of quality control standards, including selecting raw materials, processing technology, finished product testing, and other aspects. These standards apply not only to the soap itself but also to the special effects claimed by it. Therefore, companies producing soaps need to strictly comply with relevant regulations and standards and obtain the appropriate production license to ensure the quality and efficacy of soaps.
How do you file cosmetics that must be used with instruments?
Answer: Except for brushes, air mattresses, perm tools, etc., which are only used as auxiliary rubbing tools, cosmetic products that must be used in conjunction with instruments or tools should be evaluated for safety under the conditions of use in conjunction with the instruments or tools in the product safety assessment process. To ensure product safety and compliance, such cosmetics are required to provide the following information when filing:
1. a detailed ingredient list of the product, including all materials and accessories used in conjunction with the instrument or tool;
2. specifications and instructions for use of the instruments or tools used in conjunction with the product, including conditions of use and operating procedures;
3. an assessment report on the safety and efficacy of the product in combination with the instrument or tool to be used;
4. a description of the product’s potential risks and side effects when used in conjunction with the device or instrument.
In evaluating the safety and efficacy of such cosmetics, various factors need to be taken into account, such as the chemical nature of the ingredients, compatibility, permeability, and effects on the skin in the long term, as well as the safety of the materials and accessories of the device or instrument used in conjunction with the product, the conditions of use, and the procedure for use. In principle, instruments or tools used in conjunction with cosmetics should not have cosmetic functions, should not participate in the reproduction process, and should not change the mode of action and mechanism of action between cosmetics and skin.