Labeling and regulations for handmade goods

Labeling is where a lot of makers freeze, usually because the internet hands them a pile of conflicting rules that were written for completely different kinds of product. A candle, a bar of soap, a body butter, a loaf of bread, a glazed mug, a pair of earrings, and a printed toy sit under different authorities, and which one governs yours depends less on how it looks than on what it is made of, who uses it, and what you claim it does. This chapter is a map to those authorities so you know which door to knock on. It is general information, not legal advice, and nothing here assesses your product for you: you file and you confirm, using the primary sources named below.

Which lane your product is in

Before the detail, the sorting question. Almost every handmade product lands in one of these lanes, and a few land in two:

• A general consumer product. Candles, most home goods, most printed, cut, and engraved items. Overseen by the Consumer Product Safety Commission, with craft-specific standards on top.
• Food. Baked goods and anything else eaten. State cottage-food law usually decides whether you may sell it at all, and food-labeling rules decide what goes on the package.
• A food-contact article. Ceramics sold as tableware, and any printed or machined item meant to touch food. Judged on what can migrate out of the surface, not on what the object is for.
• A cosmetic. Anything applied to the body with a cosmetic claim, including soap sold with one. Governed by the FDA under MoCRA.
• True soap. A narrow definition that sits outside cosmetics entirely, covered below.
• A children’s product. Not a craft but a category that cuts across all of them, and the strictest one. Jewelry, printed toys, and engraved goods all fall into it the moment they are intended for children.

You do not choose your lane; the product and the claim choose it for you. What you choose is whether you find out before you print a thousand labels.

Candles follow fire-safety labeling, not FDA rules

A candle is a consumer product. It is not a cosmetic, it is not food, and it is not a drug, so it does not follow FDA labeling at all. What it follows is fire-safety practice.

The reference point is the ASTM F2417 fire-safety specification. Standard practice tied to it is a fire-safety caution plus the burn-safety symbols placed on the candle or on something attached to it, alongside your business identity and the net weight (per ASTM F2417). In plain terms, a shopper should be able to see who made it, how much wax is in it, and how to burn it without starting a fire.

The safety language itself comes straight out of the guidance covered in the candle safety and testing chapter: never leave a burning candle unattended, keep it away from anything flammable and out of reach of children and pets, trim the wick before each use, and stop burning when about half an inch of wax remains. That copy belongs on or with the product, not buried in a listing where the buyer never sees it.

A few practical notes on candle labels:

• Put the burn instructions where they survive. A sticker on the bottom of the jar is standard, and it stays with the candle after the box is gone.
• Net weight means the wax, not the vessel. Weigh your fill, not the finished jar.
• Your business identity is your name or brand and a way to reach you. This is also where later record-keeping starts paying off.

The line between true soap and a cosmetic

Soap is where most of the confusion lives, because a bar that looks identical to the one next to it can fall under a completely different agency.

“True soap” has a narrow definition: the cleaning action comes from an alkali salt of fatty acids, and you sell it only as soap. When your product meets that definition and makes no other promise, it is regulated by the Consumer Product Safety Commission, not as an FDA cosmetic (per the FDA “Small Businesses & Homemade Cosmetics” fact sheet and CPSC soap guidance).

The moment you step outside that narrow lane, the category changes:

• Add a cosmetic claim — moisturizing, scent, deodorizing — or add cosmetic ingredients, and the FDA treats it as a cosmetic.
• Make a drug claim, such as treating acne or killing germs, and it becomes a drug, which is a far heavier regulatory category (per the FDA “Small Businesses & Homemade Cosmetics” fact sheet and CPSC soap guidance).

The important thing here is that you decide which lane you are in every time you write a label or a listing. The soap can be chemically identical; the claim is what moves it. If you want the lighter footprint of true soap, keep the claims to “soap” and keep the cosmetic language off the label. The soap adaptation chapter walks through this in the context of an actual soap line.

What MoCRA asks of a small cosmetics maker

If your product is a cosmetic, which includes soap sold with cosmetic claims, the governing law is MoCRA, the Modernization of Cosmetics Regulation Act of 2022.

MoCRA carries a small-business exemption. If your average annual U.S. cosmetic sales over the prior three years are under $1 million, you are a small business exempt from facility registration, product listing, and good-manufacturing-practice rules (per the FDA and Obelis, 2024). That exemption covers a lot of kitchen-table makers, and it is worth knowing you likely have it before you assume you are on the hook for the full regime.

The exemption is narrower than it sounds, though. It exempts you from registration and GMP; it does not exempt you from safety and record-keeping. Even as an exempt small maker, you are still expected to:

• Keep safety substantiation for each product.
• Keep adverse-event records, generally for three years, with a serious adverse event reported by the responsible person within 15 days.
• Meet labeling rules, including a contact channel on the label for adverse-event reports, in effect since December 2024 (per Cosmeservice and the FDA).

That contact channel is the piece newest makers miss. A cosmetic label needs a way for a customer to report a bad reaction, the substance behind the fine print on commercial products. Building that into your label from the start is far easier than reprinting a run later.

None of this is something the tools you use file for you. You are the responsible person; you keep the records and you make the reports. What the record side of your operation should do is make those records easy to hold, which is where a batch record earns its keep, and why the batch records chapter treats them as the backbone of your safety file.

Baked goods: cottage-food law first, then the label

Food has an extra question in front of the labeling one, and it is the one that can stop a business before it starts: are you allowed to sell what you bake, from the kitchen you bake it in?

There is no federal cottage-food law. Every state writes its own, and they differ on nearly everything that matters — which foods qualify (generally shelf-stable items rather than anything needing refrigeration), where you may sell them (direct to the customer is common; wholesale to shops and shipping across state lines often are not), whether there is an annual sales cap, and whether you must register, take a food-safety course, or have the kitchen inspected. Your state’s department of agriculture or health is the authority, and it is the first call to make, ahead of any label design. The costing side of this trade is in pricing baked goods for wholesale, which is also where the line between direct and wholesale selling starts to matter financially.

Once you may sell, the label typically carries the product name, the ingredients listed in descending order by weight, the net quantity, your business name and address, and an allergen declaration. Many states additionally require a statement on the label saying the food was made in a home kitchen that is not subject to state inspection, in wording the state specifies. The FDA’s food-labeling materials cover the general rules; your state covers the home-kitchen wording.

Allergens are the part to get exactly right, because they are the part that hurts someone when it is wrong. The major food allergens must be declared plainly, and the list has grown: sesame was added as the ninth major allergen under the FASTER Act and has been in effect since January 2023 (per the FDA’s food-allergen labeling pages and the FASTER Act). Cross-contact matters too — a shared bowl, a shared oven, or a shared cooling rack can put an allergen into a product whose recipe never contained one, and that is a fact about your kitchen that belongs on your label rather than in your head.

The habit that makes all of this answerable is the same one everywhere else in this chapter: a bake log that records which ingredients and which lots went into which batch. It is what turns “I think that batch was nut-free” into something you can actually stand behind.

Ceramics: food-contact surfaces and what can leach out

A mug is not regulated like a sculpture. The moment a piece is sold as tableware — anything meant to hold food or drink — it becomes a food-contact article, and the question stops being how it looks and becomes what can migrate out of the fired surface into what someone eats. Lead and cadmium are the two that matter most, and both can come from glazes and from some colorants and decals.

The FDA publishes limits for leachable lead and cadmium in ceramic ware, measured by a specified laboratory leach test, with different limits by article type — a flat plate, a small hollow bowl, a cup or mug, and a pitcher are treated differently (per the FDA’s guidance on lead and cadmium in ceramic ware). Confirm the current limit for the article type you actually make rather than working from a number you read on a forum. Some states add their own duties on top; California’s Proposition 65 has specific requirements for lead in tableware sold there.

Three practical points, none of which this playbook can settle for you:

• Glaze safety is a property of the fired result, not of the recipe. A glaze formulated for food contact still has to be fired to the range its supplier specifies. Underfiring, a poor fit that crazes, or a glaze layered over another can change what the surface does.
• Buy from suppliers who publish what is in a glaze and what it is formulated for, and keep that documentation with the batch record for the pieces you used it on.
• Testing is done by a laboratory, not by you and not by a tool. If you are selling tableware at any volume, leach testing is a real cost of the business, in the same way third-party testing is for a children’s product.

Work that is not intended for food should say so. Decorative ceramicware is expected to carry a conspicuous statement that it is not for food use, so a buyer cannot mistake a display piece for a dinner plate. The costing side of firing and glaze is in pricing pottery and ceramics.

Jewelry: heavy-metal limits, especially for children

Jewelry is worn against skin, and small parts end up in children’s mouths, so its rules focus on toxic metals rather than on labeling.

Under the CPSIA, children’s jewelry carries strict limits on lead in both the substrate and the surface coating, a limit on cadmium, and limits on nickel release for items worn against skin or through a piercing. Children’s products additionally require third-party testing at an accepted laboratory and a Children’s Product Certificate stating what they were tested against (per CPSC CPSIA and ASTM F2923). The jewelry chapter carries the current limits and the sourcing habits that keep you inside them.

Two things newer makers miss. First, adult jewelry is not automatically outside the rules: several states restrict lead and cadmium in adult pieces as well, so “it’s for adults” does not settle the question by itself — it depends on your materials and on where your customers are. Second, the certificate is yours to issue, on the strength of a laboratory’s testing. No supplier’s word and no software issues it for you, which is why knowing your material composition, from suppliers who will tell you, is the whole foundation.

Printed, cut, and engraved goods inherit the rules of what they are

3D printing, laser work, and CNC work have no regulatory category of their own, and that is the point worth internalizing. The rules follow what the object is and who uses it, not how it was made. An engraved cutting board is a kitchen item; a printed figurine sold as a toy is a children’s product; an acrylic sign is a general consumer good. Same shop, three different regimes.

The baseline for all of them is general consumer-product duty under the CPSC: the product must be safe for its intended and reasonably foreseeable use, and you are expected to report a substantial product hazard if you learn of one. Products subject to a specific safety rule also carry a general certificate of conformity.

Two inheritances are worth planning for before you take an order:

• Anything intended for children picks up the children’s-product regime in full: lead and phthalate limits, small-parts and choking-hazard rules, tracking labels on the product and its packaging, third-party testing, and a Children’s Product Certificate. A printed toy is a toy. The costing chapters for these crafts are pricing 3D prints and pricing laser and CNC work; the certification cost belongs in those numbers, not in a surprise later.
• Anything intended for food contact picks up the food-contact rules, and printed parts deserve particular thought. Many filaments, resins, and colorants are not made for food use, uncured resin is not, and the layer lines that make a print recognizable are also places bacteria can sit where cleaning cannot reach. Confirm with the FDA’s food-contact material rules and with the material supplier before you sell a printed item meant to touch food.

One more, outside the safety picture but in the same spirit: cutting or engraving somebody else’s protected design is its own legal problem, and “the customer sent me the file” is not an answer that helps you.

Keep the record so the rule is answerable

Whatever category you land in, the common thread is that a label rule is only useful if you can back it up. A candle’s net weight comes from a batch you actually weighed. A cosmetic’s safety substantiation and adverse-event trail come from records you actually kept. A soap maker’s claim to be “true soap” is only credible if the formulation matches. An allergen statement is only as good as the log of what went into that batch and what else was on the bench that day. A tableware glaze is only defensible if you know which glaze and which firing the piece came out of.

That is the quiet reason record-keeping and labeling are the same job seen from two angles. The dated log of what went into a batch (recipe, materials, lots, yield) is what lets you stand behind the label if anyone ever asks. A maker inventory tool can hold that trail for you, but the discipline is yours: write it down at the time, not from memory later. And the trail is all it is — no tool files with an agency on your behalf, assesses your product, or certifies anything about it. Those acts are yours.

Confirm with the authority, every time

Requirements change, they vary by product and by the claims you make, and they vary by where you sell. Treat this chapter as a directory of the right doors to knock on, not a verdict on your product:

• For soap and cosmetics: the FDA cosmetics pages and its “Small Businesses & Homemade Cosmetics” fact sheet.
• For true soap, for candles, and for general consumer goods including printed, cut, and engraved items: the Consumer Product Safety Commission.
• For candle fire-safety labeling: the ASTM F2417 fire-safety specification.
• For baked goods: your state’s department of agriculture or health for cottage-food rules, and the FDA’s food-labeling and food-allergen materials for what goes on the package.
• For ceramics intended to hold food: the FDA’s guidance on lead and cadmium in ceramic ware, plus any state rule where you sell.
• For jewelry and for anything intended for children: the Consumer Product Safety Commission, the CPSIA, and ASTM F2923 for children’s jewelry.

Before you rely on anything for your own products and claims, confirm the current requirements directly with the agency, or with a professional who works in this area. Nothing in this chapter is legal advice: it is a starting map, and the last step is always yours.