Why Can't I Tell You to Use My Dog Balm on Yourself?

This is one of those questions that crops up every now and then, and it's always an interesting, and sometimes lengthy, conversation.

People will look at one of my dog balms or salves and ask, 'Could I use that on myself?' My answer is always the same. The official answer is no. The unofficial answer is yes! The ingredients themselves aren't the issue. The reason I can't recommend it for human use has very little to do with what's actually in the product and a lot more to do with the legislation sitting behind it.

Are Dog Balms and Human Balms Really That Different?

I think the confusion comes from the fact that most people assume dog skincare products and human skincare products are completely different things. In reality, that's often not the case. A balm is a balm. The recipe might vary slightly, and if you're formulating specifically for dogs there are certain ingredients or fragrances you might choose to avoid, but generally speaking we're often working with the same types of oils, butters and botanical ingredients. They're sourced from the same suppliers, manufactured in much the same way and made with the same care and attention to quality.

My Herbal Soothing Salve is probably the product that prompts this question most often as it gets such great results. It was originally developed for dogs and is intended for things like minor cuts, scratches, bites and stings. Long before I stopped doing much retail and moved more towards wholesale and white label, customers would occasionally ask whether they could use it themselves. The reality is that I've used it plenty of times on my own family over the years. When my children were younger, we spent a lot of time at the beach and they would often end up with sore patches around their necks where their wetsuits had rubbed after hours in the water. I've used it after brushing against stinging nettles on dog walks and on the odd bee or wasp sting too. It doesn't magically make the problem disappear, but does take the worst of the sting out.

However, personal use and commercial claims are two completely different things.

Why Can't Dog Products Be Marketed for Human Use?

I can't simply market a dog balm as suitable for humans is because it hasn't gone through the processes required for a cosmetic product.

Human cosmetics are regulated under Regulation (EC) No. 1223/2009, commonly known as the Cosmetics Regulation. If I want to sell a product as a cosmetic (which all human skincare products are) it needs a cosmetic safety assessment, a product information file, notification through the appropriate government portal and compliant ingredient labelling using recognised INCI names. There is quite a lot involved, and rightly so. Consumers should be protected and products should be properly assessed before they reach the market.

Dog products, however, don't sit within that framework. Instead, they generally fall under CLP legislation, which stands for Classification, Labelling and Packaging. That's where things start to become a little less straightforward.

Why Do Some Dog Grooming Products Have Hazard Warning Symbols?

One of the things I spend a lot of time explaining is that a warning symbol doesn't automatically mean a product is dangerous.

In fact, one of the biggest surprises I had when I first started making dog grooming products was discovering just how differently the legislation worked. I remember sending off my liquid shampoo to a CLP authorer and being genuinely shocked when it came back requiring a corrosive warning symbol on the label.

This wasn't an industrial cleaning product or some harsh chemical concoction. It was a gentle dog shampoo made with carefully selected cleansers and designed to be kind to the skin. The company was extremely helpful and explained exactly what had triggered the classification. (It was the surfactants aka cleansing agents). There was nothing wrong with the product and nothing I could do to avoid the outcome. The legislation had been applied correctly. Fragrances and essential oils also both trigger hazard warnings above certain levels too.

What annoyed me though, was that a very similar product formulated and assessed as a human cosmetic would not have ended up carrying a warning symbol at all.

That was probably the point where I started feeling that the current system isn't particularly fit for purpose when it comes to dog grooming and skincare products.

What's the Difference Between Cosmetic Regulations and CLP?

The differences become obvious when you compare the labels.

Human skincare products have to list ingredients in a specific format and comply with a whole host of cosmetic requirements. Dog products don't generally require ingredient listings, although many businesses choose to provide them voluntarily. Instead, there are different requirements around business contact details, hazard statements and, where applicable, safety information.

If products are being supplied business to business, safety data sheets are also required for dog products.

This is why, when somebody says, 'But if the ingredients are identical, why can't you just tell people they can use it?', the answer is actually quite simple. The product hasn't been assessed, registered and managed as a cosmetic product. It's not about whether the ingredients are suitable. It's about whether the product has gone through the correct regulatory process for the claims being made about it. Boring but that is how it is.

Could a Product Be Sold for Both Dogs and Humans?

Potentially, yes. However, to do that properly you would need to comply with both sets of legislation, and that means additional assessments, additional paperwork and additional labelling requirements. You can't simply decide that because something contains lovely oils and butters it can automatically be marketed for human use as well.

Does the Current Legislation Make Sense?

After working in both the cosmetics industry and the dog product industry for many years, my view is that the human cosmetics framework actually works reasonably well.

What I would love to see is a dedicated framework for dog grooming and skincare products rather than forcing them into legislation that was never really designed for them in the first place. I'd like to see ingredient transparency, sensible safety assessments and a system that gives consumers meaningful information without creating unnecessary confusion.

Because confusion is often what happens. People see a warning symbol and assume a product must be dangerous. Others assume that because a product contains natural ingredients it must automatically be safe. The reality, as is so often the case, sits somewhere in the middle.

The Real Challenge Isn't Making the Product

One thing I've learned from both making products and teaching people how to start their own soap and skincare businesses (my other business is The Soap Coach) is that most people think the complicated part is creating the product itself.

That's often the easy bit. Understanding the regulations, complying with the legislation and navigating all the paperwork is usually where things get interesting.

So if you've ever wondered why I can't officially recommend my dog balm for your own skin, now you know. It's not because there's anything mysterious hiding inside the tin. It's because the law dictates what we can and can't do.

Sometimes the official answer really is different from the practical one, and this is one of those situations.