In this label review we take a look at three very similar foaming hand soaps marketed by Bath and Body Works, comparing the marketing claims, formulations and whether or not they are soaps exempt from the definition of a cosmetic.

A product identified as “soap” that is applied to the human body is, by default, a cosmetic UNLESS it meets the definition of “soap” which is exempt from the definition of a cosmetic.

To be exempt from the definition of a cosmetic and therefore NOT covered by the cosmetic regulations, a soap must:

• mainly consist of the alkali salt of fatty acids (be a lye/oil soap)
• get its cleansing properties from the alkali salt of fatty acids (not added detergents)
• be marketed only as “soap”
• have no claims that it will have any cosmetic benefits (moisturizing, exfoliating, etc)