Pet Hygiene Products: What Are the Regulatory Challenges for Manufacturers?
Updated: 22 hours ago
The market for pet hygiene and care products is growing rapidly. However, unlike cosmetics intended for humans, these products are not covered by a specific European regulatory framework. This situation raises important questions for manufacturers regarding safety, classification and product claims.
COSMOPET 2026: A rapidly evolving market
From 15 to 17 September 2026, the COSMOPET congress brought together professionals to discuss innovations and challenges in the pet care products market.
Hoof and coat care, animal dermatology, pet influencers… The conferences covered a wide range of topics, reflecting the growing diversification of this sector.
On this occasion, Florian Gautier, Toxicologist and Head of the Cosmetic Market at CEHTRA, gave a presentation on a key topic: the regulatory grey areas surrounding pet hygiene products in the European Union.
Unlike cosmetics intended for humans, which are regulated by Regulation (EC) No 1223/2009, pet hygiene products are not subject to specific European legislation. However, this does not mean that they are exempt from regulatory obligations.
Depending on their composition, intended use and characteristics, they may fall under:
Regulation (EU) 2023/988, the General Product Safety Regulation (GPSR).
Regulation (EC) No 1272/2008 (CLP), concerning the classification and labelling of hazardous mixtures.
Manufacturers must therefore ensure the safety of their formulations, compliance with labelling requirements and product traceability.
One of the main challenges highlighted during the presentation concerns the risk of regulatory reclassification. Depending on its claims, a shampoo, spray or care product intended for animals may fall under more stringent regulations, particularly those governing biocidal products or veterinary medicinal products.
The choice of wording used in commercial communication is therefore crucial.
For example, a shampoo claiming to "clean the coat" would generally be considered a pet hygiene product. However, adding a claim such as "repels fleas" would bring it into the scope of biocidal products, while "kills fleas" would more specifically fall under insecticidal biocidal products (Product Type 18 under the Biocidal Products Regulation (EU) No 528/2012).
The same shampoo could even be reclassified as a veterinary medicinal product if it carries claims such as "treats a parasitic infestation", which implies a therapeutic purpose.
Therefore, a simple change in product claims, or in some cases in its formulation (for example, the addition of preservatives classified as biocidal substances), may alter its regulatory status, with significant consequences for the applicable requirements and market access.
Product safety: A key consideration
Beyond their regulatory classification, pet hygiene products require particular attention when it comes to safety. Safety assessments must consider the product's composition, conditions of use and the specific characteristics of the target animal species, including body weight, metabolism and behaviour. For example, cats spend a significant amount of time grooming themselves by licking their fur. As a result, they may ingest considerably more shampoo residues than dogs, an exposure pathway that must be considered during safety assessments.
Although there is no harmonised methodology specifically designed for pet hygiene products, certain toxicological approaches, inspired by veterinary practices or animal feed safety assessments, can help demonstrate their safety.
As with cosmetics intended for humans, implementing a system to monitor adverse effects is also a good practice to strengthen post-market product safety monitoring.
Anticipating regulatory risks with CEHTRA
Developing a pet hygiene product requires a rigorous regulatory approach from the earliest stages of product development. Product classification, claims assessment, safety evaluation and labelling compliance are all essential steps to minimise the risk of non-compliance and ensure successful market entry.
Are you developing or marketing pet hygiene products? CEHTRA's experts can support you in assessing your products' regulatory status and evaluating their safety.
Contact Florian Gautier, Toxicologist and Head of the Cosmetic Market at CEHTRA, to discuss your regulatory challenges.
