With the growing affection for our pets and increasing attention to their well-being, new products are emerging on the market to help us care for our animals. A significant group of such products consists of pet cosmetics – shampoos, conditioners, or even perfumes. Due to rising customer interest in these products, more and more companies decide to add them to their offer.

If we are considering expanding our product portfolio with cosmetics intended for animals, it is worth asking what requirements we must meet to do so in compliance with the law and what documentation will be needed.

How is the sale of pet cosmetics regulated?

In order to assess the requirements for any product placed on the EU market, we must properly categorize it to determine which EU regulations will apply.

In the case of pet cosmetics, the situation is a bit more complicated than it might seem at first glance. Intuitively, one might assume they are treated the same way as human cosmetics. However, here it is worth referring to the definition of a cosmetic product provided in Regulation (EC) No 1223/2009:

“Cosmetic product” means any substance or mixture intended to be placed in contact with the external parts of the human body (epi dermis, hair system, nails, lips and external genital organs) or with the teeth and the mucous membranes of the oral cavity with a view exclusively or mainly to cleaning them, perfuming them, changing their appearance, protecting them, keeping them in good condition or correcting body odours.

The most important part of this definition is the reference to contact with external parts of the human body. The definition does not include contact with animal bodies, which means that cosmetics intended for animals are not covered by Regulation (EC) No 1223/2009. Despite their common name, such products are not legally treated as cosmetics under EU law.

At the EU level, there is also currently no definition of a “pet cosmetic.” Union legislation does not yet provide separate rules for such products. This means we must look further into regulations that apply to broader groups of products.

If we take a step back and consider what such products actually are, we come to the conclusion that, in the broadest sense, they are chemical mixtures consisting of several substances. This means that, in the absence of more specific rules, we should turn to the CLP Regulation and the REACH Regulation, which govern the placing of chemical mixtures on the EU market.

Pet cosmetics – REACH and CLP

Indeed, if we refer to REACH and CLP, we will not find any exemptions for pet cosmetics. Since no other regulations specifically cover them, we must apply the provisions of these two frameworks.

This means that for such products, just like for other chemical mixtures (such as detergents or air fresheners), it will be necessary to:

• Carry out product classification under the CLP Regulation;

• Prepare appropriate Safety Data Sheets;

• Label the product in compliance with CLP requirements;

• In applicable cases, submit a PCN notification and assign a UFI code;

• For products imported from non-EU countries – pay attention to REACH registration and C&L notification obligations.

With this documentation prepared, we will be able to start selling our products for pets.

Pet cosmetics – what to watch out for

In many pet cosmetics, we encounter products whose functions, beyond cleansing and care, are described by the manufacturer as, for example, medicinal, regenerative, or even insect-repelling.

When placing such products on the market, we must be very cautious with such claims, because relatively simple documentation required under REACH and CLP may suddenly fall under the scope of additional regulations, including:

• Veterinary medicinal products (if, for example, a shampoo is said to support wound healing)

• Biocidal products (if perfumes are also intended to repel ticks)

Such claims would trigger compliance with additional regulations, significantly complicating the process and increasing market-entry costs – something that is better avoided.

Pet cosmetics – summary

In the current legislative framework, pet cosmetics should be treated as “regular” chemical products and documented accordingly. It is likely that specific regulations will emerge in the future to address this issue, but for now there are no additional legal requirements. Any documentation beyond the standard package for chemical mixtures is prepared voluntarily by the supplier or manufacturer.

If you would like to place such products on the market and need support in preparing the documentation, feel free to contact us.