Pet Hygiene Products

Are Pet Hygiene Products Cosmetics? How to Classify Them Correctly

The pet care market continues to grow, bringing new solutions for animal hygiene and grooming. Shampoos, conditioners, perfumes, and similar products are now a common part of many companies' portfolios. However, one question frequently arises: can these products be considered cosmetics from a regulatory perspective?

Although the term "pet cosmetics" is widely used commercially, legislation does not always consider them as such. Both the European Union and the United Kingdom exclude products intended for animals from the legal definition of a cosmetic product. However, the subsequent regulatory classification and the applicable requirements may vary depending on the market in which the product is placed.

Why Are Pet Products Not Considered Cosmetics?

The definition of a cosmetic product set out in Regulation (EC) No. 1223/2009 on cosmetic products refers to substances or mixtures intended to come into contact with specific parts of the human body for the purpose of cleaning, perfuming, protecting, or keeping them in good condition.

This explicit reference to the human body is precisely what excludes products intended for animals from the scope of cosmetic legislation. As a result, a dog shampoo or a cat conditioner, even if it performs a function similar to a cosmetic product intended for people, is not considered a cosmetic product under European legislation.

Furthermore, there is currently no specific definition of a "pet cosmetic" within European Union legislation. Therefore, each product must be assessed individually to determine the regulatory framework that applies to it.

How Are Pet Hygiene Products Classified?

The classification of these products depends on their intended purpose and on the properties attributed to them by the manufacturer.

When products are intended solely for cleaning or caring for an animal, such as certain shampoos or conditioners, they are generally considered animal hygiene or animal care products. However, if therapeutic properties or claims related to parasite control are attributed to them, they may become subject to specific regulatory frameworks, such as legislation governing veterinary medicinal products or, in certain cases, regulations applicable to biocidal products.

Within the European Union, the absence of a specific regulatory framework for so-called "pet cosmetics" may mean that these products need to be assessed under regulatory frameworks applicable to chemical mixtures. Depending on their characteristics, this may involve obligations related to classification and labelling under the CLP Regulation, the preparation of Safety Data Sheets, and, where applicable, the submission of a PCN notification and the assignment of a UFI code. Likewise, imported products may need to be assessed against specific obligations arising from REACH.

Other markets may adopt different regulatory approaches. Therefore, product classification should not be evaluated solely on the basis of composition or intended use, but also by considering the countries in which the product will be marketed and the specific requirements applicable in each jurisdiction.

How to manage products for animals in Chemeter?

Since the classification of products intended for animals depends on factors such as their intended purpose, composition, and marketing claims, having an appropriate document categorisation system is essential.

• Zoosanitary product for animal care
• Zoosanitary product for animal handling
• Zoosanitary product for animal hygiene
• Zoosanitary product for animal hygiene, care and handling
• Veterinary Pharmaceutical Product

These categories help distinguish animal hygiene and care products from products that may fall within the veterinary sector,, In addition, proper classification from the early stages of a product's lifecycle helps maintain more consistent document management and facilitates the identification of applicable requirements in each market. In a regulatory environment where a product's intended purpose or claimed properties can influence its classification, the specific categories available in Chemeter enable companies to organise information in a structured way and clearly differentiate between zoosanitary products and veterinary products.