Yes, and this is a common classification issue. Many products sold commercially as 'soap' are technically synthetic detergents because they contain no true soap (fatty acid salts). CBP classifies based on chemical composition, not marketing language, so a product labeled 'soap' may be correctly classified under HTS 3402 rather than 3401 if it lacks fatty acid salt content.

Retail detergents must comply with FTC labeling rules and, for products making environmental or safety claims, relevant EPA program standards. Phosphate content restrictions also apply in many states, so importers distributing nationally should verify formulation compliance with state-level chemical regulations before committing to large inventory positions.