Soap in general I would think is OK, but if it's carved or molded into a shape that would be intended for children you may have a problem. To my mind there's almost zero possibility that soap would have lead in it, but the way CPSC has been defining things you never know...although if you have any liquid items that would be sold in bottles they may fall under CPSIA, because I think one of the concerns about phthalates was that it was found in plastic bottles.
There's another angle I hadn't thought of before, I don't do bath & body products but for those who do, are you supposed to get the phthalate testing done on your packaging too? I would think that would be one thing the manufacturer/supplier is supposed to do...