Is It Really Soap? True Soap, Cleansing Bars and “Antibacterial” Washes

The short answer

In the US, “soap” is a narrow legal category (21 CFR 701.20). A product is true soap only if two things are both true: the bulk of its nonvolatile matter is an alkali salt of fatty acids, with its cleaning action coming from that compound itself, and it is labeled, sold and represented only as soap.

A product that meets both falls outside the FDA’s cosmetic rules. The Consumer Product Safety Commission regulates it instead, under general hazardous-substance law. Most products sold as soap today are cosmetic cleansing bars, and they do carry an ingredient list.

How to tell what you are holding

1. No ingredient list on a bar can simply mean true soap, because none is legally required. It is usually not an oversight.
2. Look for any claim beyond cleaning. A moisturizing, deodorizing, fragrance or antibacterial claim reclassifies the product as a cosmetic or a drug, whatever it is made from.
3. Check the ingredients for an added synthetic detergent. That changes what the bar is made of.
4. Look for a “Drug Facts” panel. If there is one, the product is an over-the-counter drug, and a drug label follows different rules.

What “antibacterial” legally means on the front

In 2016 the FDA issued a final rule on 19 active ingredients, including triclosan and triclocarban, for consumer antiseptic wash products. Its finding was precise: manufacturers had not shown these ingredients to be both safe for long-term daily use and more effective than plain soap and water. Three other ingredients, benzalkonium chloride, benzethonium chloride and chloroxylenol, were given a deferral for more data rather than a finding.

So the word on the front does not settle anything. Which active is named on the Drug Facts panel does. The rule covers rinse-off consumer wash products such as hand soaps, bar soaps and body washes.

When you compare prices

A true soap bar and a cosmetic cleansing bar are different legal categories, not two versions of one product at different prices. The price gap between them may reflect that distinction as much as the formula. Within true soap, price differences come almost entirely from raw material and brand, because there is no compliance cost to separate one tier from another.

What the label cannot tell you

The legal category is not a performance claim, in either direction. It does not tell you which product cleans better or which one you would prefer on your skin.

Materials behind these labels

• True Soap — The legal category itself, and why very few bars on a shelf qualify.
• Triclosan — The best-known active covered by the 2016 rule on antibacterial washes.

Related product types

• Hand sanitizers

What the full volume adds

This page answers one question from Volume Six — Hygiene & Cleansing. The volume goes further:

• Full profiles of true soap, triclosan, ethanol and lactic acid, with the history of each
• What price actually buys at the two extremes of this shelf
• Walkthroughs, including a single bar of soap taken through all six questions and an “antibacterial” soap
• The one-page checklist to print and take shopping

See Volume Six — Hygiene & Cleansing →