if you are covered by aromatherapy insurance then you should be OK, but check with your insurers.
If you are selling them to the public you will need to get a license, and you will need to submit your recipes for this. You will also have to label the soap with every ingredient that goes into the soap.
the license usually lasts a year.
if you are selling them to existing clients as part of their after-care, I think you may be able to get away with it. I know I can give a client a blend of essential oils as part of their treatment. But, if someone walked in off the street, I wouldn't be able to sell on.
Now, that was the situation a year or so ago, it may have changed since then.