The global pet care market has undergone a process of changing over the last few years, in particular after the COVID-19 pandemic and the recognition of all positive benefits that pets can bring to their owners. Hence, companion animals are more and more perceived as family members, and this perspective shift, known as "pet humanization", has reshaped or created new expectations around hygiene, grooming and aesthetic care (1).

Shampoos, conditioners, perfumes, wipes and “skin care” products formulated specifically for animals are getting closer to human cosmetic products, for example by being dermatology-inspired. This trend is reflected in the creation of sulphate-free or mild surfactants cleansers, hypoallergenic formulations, or even products for sensitive skin and for itch relief (2). Other trends space from the use of organic, CBD and other wellness-oriented ingredients (3).

Yet, from a regulatory perspective, these products occupy an uncomfortable grey zone. In the European Union and in most major markets worldwide, pet care cosmetics are not recognised as a distinct legal category, nor are they fully captured by existing product legislation.

This "empty" regulatory space raises important questions. How should the safety of these products be ensured, for animals and for the humans who oversee them? Which legal frameworks apply in the absence of sector-specific rules? And how are authorities beginning to respond to a market that has outpaced regulation?

In the European Union, the classification of pet hygiene and care products is shaped more by exclusion than by explicit inclusion. Regulation (EC) No 1223/2009 on cosmetic products provides a clear and restrictive definition of what constitutes a cosmetic: “any substance or mixture intended to be placed in contact with the external parts of the human body (epidermis, 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 odors;” (4)

The reference to the human body is decisive. Products intended for animals, regardless of their function or formulation, fall outside the scope of the Cosmetics Regulation.

A similar logic applies to detergents. Article 2 of Regulation (EC) No 648/2004 defines detergents as substances or preparations containing soaps or surfactants intended for washing and cleaning processes, primarily in relation to textiles, dishes, and surfaces (5).

Although pet shampoos are, from a formulation perspective, often indistinguishable from other human cleansing products, animals are not considered substrates or surfaces within the meaning of the regulation. This interpretation has been formally confirmed by the European Commission in its 2023 version of “Questions and agreed answers concerning the correct implementation of Regulation (EC) No 648/2004 on detergents”, which explicitly states that products for washing pets or washing the nipples of animals like cows or goat, do not fall within its scope unless they have additional functions, such as insect-repellent activity, that could trigger other legislation, such as the Biocidal Products Regulation 528/2012 (6).

Nor do pet care products qualify as veterinary medicinal products. Regulation (EU) 2019/6 defines veterinary medicinal products by reference to treating or preventing disease, to the pharmacological, immunological, or metabolic action, medical diagnosis or to be used for euthanasia (7). As long as a pet shampoo, balm or perfume does not claim to treat or prevent disease, restore physiological functions or exert a medicinal action, it remains outside the veterinary medicinal framework.

The outcome of this cumulative exclusion is clear: pet hygiene and care products are not cosmetics, not detergents and not veterinary medicines under EU law.

In the absence of a dedicated framework, pet care cosmetics marketed in the EU are regulated horizontally through general product and chemical legislation.

One of the bases was Directive 2001/95/EC on General Product Safety (8), now replaced by Regulation (EU) 2023/988 (GPSR), which requires that all consumer products placed on the market be safe under normal or reasonably foreseeable conditions of use (9). Manufacturers and distributors bear the responsibility of identifying risks, as well as implementing appropriate safety measures and providing adequate information to users.

Chemical compliance is ensured through Regulation (EC) No 1907/2006, so called REACH (10) which governs the registration, evaluation, and restriction of substances, and through the CLP Regulation (EC) No 1272/2008 (11), which addresses classification, labelling and packaging of hazardous substances and mixtures. These instruments apply irrespective of the intended user being human or animal and impose obligations related to substance hazards, environmental fate, and worker safety.

However, while these frameworks provide a baseline, they were not designed to address the specific exposure scenarios associated with products applied directly onto animals, often repeatedly and over large body surfaces, and managed by humans in close contact.

Faced with this regulatory gap, the approach that manufacturers should follow is inspired by the Cosmetic Regulation. In practice, this often means formulating pet care products in compliance with the ingredient restrictions and prohibitions set out in the annexes of Regulation (EC) No 1223/2009, even though this regulation does not legally apply. There are two reasons for taking this road.

First, these products are routinely used by humans, including professional groomers, veterinarians, and pet owners, leading to dermal and sometimes inhalation exposure. Applying cosmetic safety standards offers a pragmatic way to protect human health.

Second, cosmetic toxicology provides a well-established framework for assessing local tolerance, systemic exposure, and margin of safety (12), which can be adapted, with caution, to animal use. In established EU toxicological evaluations for topical products, hazard identification routinely prioritises local effects such as irritation and sensitisation and also accidental ingestion based on exposure scenarios.

Although animal skin physiology differs from human skin in terms of thickness, hair density and barrier properties (13), cosmetic safety assessment methodologies offer a structured starting point in the absence of animal-specific guidance.

This approach is also supported by recent scientific literature. A peer-reviewed study on type IV hypersensitivity in dogs shows that allergic contact reactions in companion animals can arise from repeated topical exposure to sensitising substances, following immunological pathways comparable to those described in humans. This reinforces the relevance of focusing on irritation and sensitisation as primary safety endpoints for pet care products and supports the use of cosmetic toxicology principles as a cautious and scientifically sound reference framework (14).

An indication of regulation: “proposition de Loi n° 1711” in France

In July 2025, France has introduced a proposition of law, "Bill No. 171" (15), challenging the regulatory status quo on a national level. The proposal seeks to regulate the composition of the so-called “cosmetic products for animals” by amending Article L.412-1 of the Consumer Code, which expressly recognizes the lack of particular requirements in this area.

Human safety, not animal health, is the main priority of the measure. Indeed, the proposition refers to a study showing that 27.4% of grooming professionals suffer from respiratory disorders and 46.2% experience skin reactions on their hands because of repeated exposure to grooming products. Notably, 81.1% of professionals reported being unaware of the chemical composition of the products they use, despite the need for specific protective measures such as gloves, goggles, or respiratory masks, information that is not currently indicated on packaging.

With these premises, the proposal indicates the need for regulating the composition, labelling, and toxicological assessment of these products according to principles comparable to those set out in Regulation (EC) No 1223/2009, without formally classifying them as cosmetics. Finally, the proposal aims also to ensure that these products are regulated in a way that reflects a more ethical and respectful understanding of animals, recognizing them as living, sentient beings.

While the intent is clear, the drafted law raises conceptual questions, particularly regarding the application of cosmetic regulatory logic to products falling outside the legal definition of cosmetics. Regardless of its outcome, the bill expresses the first signs of discomfort with the current regulatory status of these products.

The United States: grooming aids and consumer protection

A similar pattern emerges in the United States. Under the Federal Food, Drug, and Cosmetic Act, cosmetics are defined exclusively by reference to human use (16). Products intended solely for animals are therefore not cosmetics in the eyes of the Food and Drug Administration (FDA). Instead, pet shampoos and grooming products are generally considered consumer products or “grooming aids” (17).

Regulatory oversight depends largely on claims. If a product is marketed purely for cleansing, beautifying, or deodorising an animal, it remains outside the FDA’s cosmetic and drug jurisdiction. However, if therapeutic claims are made, such as treating disease or to affect the structure or function of the body of animals, the product will be classified as a drug under the FD&C Act. Even more, it may be classified as a "new animal drug" if the product cannot be considered safe and effective.

In the United States, the way a pet grooming product is described often matters as much as what is inside it. Regulators look closely at labels, advertising, and other promotional messages to understand whether a product is being offered as a simple grooming aid or whether it is implicitly claiming a therapeutic role. When the line is unclear, or when health-related intent appears to be suggested, the case is referred to the FDA’s Center for Veterinary Medicine for closer scrutiny.

Canada: consumer product safety is the anchor

In Canada, pet grooming products intended only for animals are not regulated as cosmetics under the Food and Drugs Act or the Cosmetic Regulations. Instead, they fall under the Canada Consumer Product Safety Act (CCPSA), which governs a wide range of consumer products with a focus on hazard prevention and post-market surveillance (18).

Depending on their composition and properties, such products may also be subject to the Consumer Chemicals and Containers Regulations (CCCR, 2001), if for example, the product is classified as having toxic, corrosive, flammable, explosive, or quick skin-bonding properties.

This reclassification, however, has clear boundaries: it does not apply to products intended for use on both humans and animals, nor does it affect therapeutic animal products regulated as drugs or pest control products governed by separate legislation.

Looking forward: getting outside the grey zone

Pets are increasingly part of the family, and the products we use to care for them such as shampoos, balms, and grooming aids, have evolved in the past years, focusing on gentle formulas, sensitive skin or even wellness trends.

The rules, however, have not kept up. In the EU, the USA, and Canada, these products do not fit neatly into existing categories: they are not cosmetics, detergents, or medicines. This leaves manufacturers navigating a grey area while trying to ensure safety the people who handle them and ultimately for the pets.

For now, the approach of the industry is often to borrow safety standards from human cosmetics, testing for irritation and allergic reactions, while emerging initiatives, like France’s recent proposal, point to a growing recognition that clearer rules are needed, both to cover human and animal needs.

Pet care is a market that is moving faster than the law, but the end goal and ambition would be to finally create a framework that protects animals while safeguarding humans, giving everyone confidence in the products they use.