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What regulations apply to selling dog soaps / shampoos / balms etc?

Keri Squibb

What regulations apply to selling dog soaps / shampoos / balms etc?

This is a quick overview of everything I have learnt over the last few years and particularly so in 2022 in which I have spent a lot of money getting some answers once and for all. 
Those of you who sell products such as soap for human use, will be well aware of the legislation you need to follow including getting assessments on your products from a cosmetic chemist, uploading details to a government portal, keeping various records and more.
None of that exists for dog products, the reason being that the legislation is for human skincare and cosmetics, not dogs. So you will not find a chemist that will assess a product as safe in the same way. There are no guidelines in place for them to use as a framework to do so.

How do we decide if a product is for dogs or humans and what legislation applies here in the UK?

Key Considerations
• Where are the products are being placed on the market – EU, UK/GB/NI
• Are the products only used for pets
• Are any claims made or substances used that could be construed as for veterinary or biocidal
purpose e.g., antihistamine or kills fleas
• Are products intended for consumers, professional users or both
That does not mean there are no regs, there is other legislation that does apply.
European Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures (CLP)
Pet soaps and shampoos (that do not make specific claims) are not classed as veterinary products, detergents, biocidal products or cosmetics. CLP is a disapplication regulation, i.e., it applies to ‘everything but’ and this is where our pet products sit - they are classed as a substance or mixture as they don't fit any other title.
 
You may feel your product is touching human skin and therefore you should get a cosmetic assessment for it. There is nothing to stop you doing this but it is not a requirement , and be aware the assessment will not declare your product safe for use on dogs. Unfortunately, there is nothing that is available to do that for you. This doesn't mean the products are unsafe, far from it. The CLP labelling requirements for dog products seem, to me, to be far more risk averse than human products as we will see in a moment.

What exactly is CLP?

CLP stands for Classification, Labelling & Packaging. CLP Regulations state that products with hazardous substances must be labelled accordingly in the EU including the UK. Unfortunately it is not quite as simple as the EU and UK being the same as the hazards triggered by a substance in the EU can differ to that in the UK.
 The regulations require certain information to be included on all CLP labels along with the requirements of the size and shape of that information. This includes:
  • Product identifiers
  • Hazard pictograms
  • Hazard statements
  • Allergen information
  • Signal words
  • Precautionary statements
Hazardous substances include essential oils, fragrance oils and the active matter in surfactants which are the base material of liquid shampoos.
The legislation also states that Safety Data Sheets must be made available under REACH for Business to Business. So if you are selling your products wholesale you must be able to supply your stockists with an SDS. 

Should I be alarmed at the hazard warnings on my dog shampoo ?

No not at all, it is all about understanding that is a different set of legislation which unfortunately is not fit for purpose where dog products are concerned in my eyes. But it is what we have to abide by and we cannot change that. 
To put this in perspective my Soothing and Conditioning Dog Shampoo is incredibly kind and gentle. If it were a human product would require no hazard statements, warnings, pictograms etc just the allergens but because it comes under CLP it has to have a warning symbol and words on, which really do not look very appealing. This is down to the active matter in the detergent (surfactant). One of my colognes now has a warning symbol on, the other doesn't - this is because they contain different essential oils yet the base recipe is the same . The soaps and balms are largely unaffected which is a blessing although you will see allergens listed on the soaps where relevant.

Why have I taken so long to change this and write about it now?

Quite honestly, it has taken me this long and a lot of money to get concrete answers and it is still pretty overwhelming. The company I used for my SDS's and initial CLP have done a lot of research too. I suspect Brexit caused some confusion and it is also an area that has developed over the years.
20 years ago we probably all bathed our dogs in baby shampoo or Fairy Liquid. We have now moved on and many of us like to use dedicated products but the powers that be haven't moved on, which is why we fall under CLP as is an 'everything but' product. 

Will I be doing a course about everything that is required to sell pet products?

No I have no plans to do so. Originally I did but I don't feel I can tell you any more than I have in this blog. The bottom line is if you want to sell pet products, unless you are a CLP specialist, you will not have the knowledge, understanding or expertise to know what you need to put on your labels.  Shampoos/colognes will almost certainly need hazard pictograms but I cannot advise. There are various companies that will do CLP authoring for you and they will use specialist software that they have purchased for this purpose.. The one I used was eye wateringly expensive, mainly because I did not know enough at that time to shop around.
Thank you for taking the time to read this to the end, it is a dry and heavy topic I know but one which I felt I had to do but needed to wait until I had sufficient information to do it justice. 
Disclaimer - this is not a blog about how to label your pet products but my interpretation. Please do take advice from a company that specialises in CLP authoring and SDS sheets.

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1 comment

  • Hi I have just read your very informative info,thank you so much

    so very kind to share your info.

    Marian

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