Why Organic Labels Don’t Tell the Whole Story
We received an email from a customer who had found another company selling “organic soap.”
“Their label says organic soap right on the front, and yours only says Made with certified organic Lavender, Coconut Milk, and Shea Butter. So I assume your soap is not really organic.”
It’s a fair question — and an important one.
“Organic” has become one of the most powerful (and often misunderstood and misused) words in personal care.
But in the United States, it is not just a feel-good term—it is a legal term, defined and regulated by the USDA’s National Organic Program (NOP).
The NOP sets strict rules for how the word “organic” can be used on labels, websites, and marketing materials.
And this is where things get complicated—especially when it comes to soap.
Why Soap Is Different
Did you know there is actually a legal definition of the word "soap"?
According to the FDA, a product can only be called “soap” if it’s made from the alkali salts of fatty acids — simply put, oils or fats combined with lye.
It cannot contain synthetic detergents or laboratory‑made surfactants.
This is why many mass‑market bars made with synthetic detergents are labeled as “beauty bars,” “cleansing bars,” or “bath bars.” They are not legally soap.
And if the only claim on the label is cleansing, it is not regulated as a cosmetic.
But the moment you claim anything beyond cleansing — like moisturizing — it becomes a cosmetic and falls under FDA oversight.
To understand how organic labels apply to soap, we need to look at how a real soap bar is made.
How Real Soap Is Made
A true cold‑process soap is created through saponification, a natural chemical reaction between fatty acids (from oils and butters) and sodium hydroxide (lye) dissolved in a liquid.
This reaction transforms everything into soap molecules, glycerin, and a small amount of water.
No lye remains in the finished bar — it has been completely transformed during saponification.
Because here is the key:
The USDA still requires that lye be included when calculating the percentage of organic ingredients. And that one rule has a big impact.
Understanding this chemistry is essential to understanding why most real soaps cannot meet the USDA’s highest organic labeling tiers.
👉 Learn More: Dive into The Chemistry of Natural Soap Making
Why Real Soap Rarely Qualifies as “Organic” (95%+)
When the USDA determines whether a soap can be labeled “organic” (95%+), it calculates the percentage of organic ingredients by weight.
- Water is excluded
- Salt is excluded
- Everything else (including the lye) is included
In a typical cold‑process recipe, lye makes up roughly 10–15% of the total formula. Water makes up another significant portion.
Even though no lye remains in the finished bar, the USDA requires lye to be counted in the formula when calculating organic percentages — and water must be excluded entirely.
This creates a mathematical problem.
Because lye is not organic—and because water is excluded—the percentage of organic ingredients drops below the 95% threshold required to use the USDA Organic Seal, even if every oil, botanical, or essential oil is certified organic.
That’s why most authentic, traditionally made soap bars — including ours — fall into the “Made With Organic Ingredients” category (70–94.9% organic).
But What About Bar Soaps That Carry the USDA Seal?
You may have seen soap bars labeled “organic” with the USDA seal, which means they claim to be 95%+ organic. So how is that possible?
The answer usually comes down to how the formula is calculated.
Some soapmakers replace the water in their recipe with an organic liquid—like aloe juice, coconut water, or fruit juice.
And here’s why that matters: when the USDA calculates the percentage of organic ingredients, plain water is excluded, but organic juice is counted as an organic ingredient.
So when water is swapped for apple juice, that liquid suddenly becomes an “organic ingredient” in the eyes of the USDA—even though it’s 80 to 90% water. This shift can raise the organic percentage high enough to reach the 95% threshold required for the USDA Organic Seal.
A finished bar of cold process soap is a solid, crystalline structure made of soap molecules, naturally occurring glycerin, and a small amount of water.
During saponification, the sugars and acids in fruit juice don’t remain as “juice.” In the finished bar, you’re left with soap, glycerin, water, and trace sugars—not a meaningful amount of fruit juice.
Those sugars can boost lather by helping the soap interact with water more easily—but they also need to be carefully balanced. Too much sugar can cause the soap to overheat during production or create a softer bar that doesn’t last as long.
The soap itself is not “more organic.”
Replacing water with organic juice changes the math, not the soap. The organic percentage goes up because the USDA counts organic juice but not water, and the relative percentage of lye goes down.
And that is why what you see on the label doesn’t tell the whole story.
Our Experience
We have spent decades working with organic ingredients—fruit juices, botanicals, and essential oils—while formulating with a higher superfat.
Superfatting means adding more oils or butters than the lye can convert into soap; while many soapmakers use about 5%, we use much more.
Together, these choices increase the organic portion of the formula and decrease the relative percentage of lye.
Even so, we’ve never been able to create a high-quality, hard, well-lathering, long-lasting bar with more than about 93% organic content.
Perhaps other soapmakers have found ways to push that higher.
For us, the goal has never been to adjust a formula to meet a number—it’s to create a bar of soap that performs beautifully and stays true to its ingredients.
So what does all of this actually look like on a label? And how do you know what those claims really mean?
Understanding Organic Labeling
The USDA uses a three-tiered labeling system based on the percentage of certified organic ingredients in a product. Water and salt (NaCl) are excluded from that calculation, which is especially important when we talk about soap.
Below, you’ll see three bars of soap from our fictitious company, Ida’s Organics — each one showing a different type of USDA organic label. Ida is trying to figure out which label is the proper one for her soap.
Before we look at them, there’s one key point:
A company does not get to decide whether its products are organic — the USDA does. And it does not choose its labeling tier — the USDA does.
To use the word “organic” on a product—or in a company or brand name—a business must be USDA certified and meet the requirements of the National Organic Program.
Only companies whose entire product line qualifies for the "100% Organic" or "Organic" (95%+) tiers may use the word ‘organic’ in their brand name or company name. If even one product falls below those levels, the company cannot legally use “organic” in its name.
So let’s look at the three soap bars and see what each label means — and how well Ida’s imaginary company follows the rules.
1. 100% Organic
This means exactly what it says.
Products can only be labeled “100% Organic” if every ingredient (excluding water and salt) is certified 100% organic. And even 99.99% is not enough. They:
- May display the USDA Organic Seal
- May use the phrase “100% Organic” on the front label
- May call the product organic (organic soap)
How well did Ida’s Organics follow the rules? Not well.
A true 100% organic bar soap does not exist.
Real soap — as legally defined by the FDA — requires sodium hydroxide (lye).
Lye is allowed under NOP rules, but organic lye does not exist. So even if every plant oil, butter, herb, and essential oil is organic, no real soap can qualify for the “100% Organic” label.
And because Ida’s company sells some products that do not fall into the top two USDA tiers, she would not be allowed to use the name Ida’s Organics at all.
2. Organic (95–99.9% Organic Ingredients)
Products in this tier contain 95–99.9% certified organic ingredients (excluding water and salt). They:
- May use the USDA Organic Seal
- May use the word
"organic" to describe the product that meets the criteria. (organic soap)
How well did Ida’s Organics follow the rules? Again, not well.
Ida told us her soap recipes require at least 7% lye. Since lye must be counted in the formula — and is not an agricultural ingredient — her soap cannot reach the 95% threshold, even if everything else is organic.
And once again, because her company sells products that fall below the top two tiers, she cannot legally use the word “organic” in her company name.
If Ida could make a 95% organic soap bars, she could use the USDA seal and call the soap organic. And if her entire product line qualified for the top two tiers, she could use “organic” in her company name.
But that’s not the case here.
3. Made With ... (70–94.9% Organic Ingredients)
Products labeled “Made with Organic ___” contain 70–94.9% certified organic ingredients (excluding water and salt). They:
- Cannot use the USDA organic seal
- Cannot use the word “organic” as a product claim (for example, “organic soap”)
- May list up to three organic" ingredients on the front of the label
- May display the certifier’s logo (ours is OEFFA)
- Must identify the certifying agent on the label — "certified by. . . "
How well did Ida do this time?
She finally got it right.
- The label does not call the product “organic soap.”
- It uses the certifier’s seal (OEFFA) instead of the USDA seal.
- And her company name does not include the word “organic.”
Even though all the oils, butters, herbs, and essential oils are certified organic, the presence of lye keeps this soap in the “Made With Organic Ingredients” tier — which is exactly where real cold process soap belongs.
So while Ida cannot call her company Ida’s Organics and she can’t call her soap ‘organic,’ she can call it exactly what it is—a real bar of soap made with certified organic ingredients.
Looking Beyond the Label
Organic labeling and symbols may give us a framework, but they don’t capture the full story of cold-process soap.
Understanding how real soap is made—and how organic tiers work—helps you look beyond the seal and focus on what truly matters: the ingredients, the process, and the integrity behind each bar.
Because even without the top USDA tier labels, a bar made with real skill, real chemistry, and real certified organic ingredients delivers what counts — a mild, rich, moisturizing soap that feels creamy in your hands, offers a magnificent, long-lasting lather, and leaves your skin feeling clean, soft, and healthy.
Organic rules may define the label, but craftsmanship defines the soap.
Take the Guesswork Out of Organic Claims
The USDA Organic Integrity Database is a public directory of all certified organic operations. It’s an easy way to check whether a company and its products are truly certified organic. Simply enter a company name under “Operation Name” to begin your search.
Find the Perfect Organic Soap for You
What Do All of the Organic Labels Mean?
A Few Words About Organic Soap and Shampoo
Why Did We Become a Certified Organic Company
This article was originally published in 2014 and updated in 2021. It has since been further refined to improve clarity and expand on key details. The principles and standards discussed remain the same.
