Let us help you! There's a bit of essential information you really should know. While there are plenty of dog shampoos and grooming products already on the market, many of them aren't actually compliant with regulations — especially in the UK and EU.
A lot of these products copy the labelling format and claims of human cosmetics, which can be misleading. This isn’t an opinion piece — what follows is simply grounded in facts based on UK and EU legislation.
First up: Dog shampoos are not cosmetics
Even though a human will handle the product when applying it, the intended use is on the animal, and cosmetic regulations (both UK and EU) only apply to products intended for human use. So, no matter how nicely it's fragranced or how gentle the surfactants are, it is not a cosmetic.
That means it doesn’t fall under the Cosmetic Regulation. But it also doesn't automatically become a veterinary medicine either. Instead, dog shampoos are treated as general chemical mixtures. They're not covered by cosmetics law or veterinary medicine unless their claims suggest otherwise. While they’re not technically regulated under the Detergents Regulation, many brands follow similar labelling conventions as a form of best practice — particularly for transparency and consumer familiarity.
Consumer Safety & Labelling (CLP)
Because your dog shampoo is still a chemical mixture, you must classify and label it correctly under CLP. This includes:
- Hazard pictograms (e.g. irritant, corrosive)
- Signal word (e.g. "Warning") — which must match the pictogram
- Hazard (H) and Precautionary (P) statements
Tip: You can use smaller pictograms and font sizes allowed under CLP for small containers — great if you're trying to keep a cosmetic look!
Even if your shampoo seems mild, it may still trigger classification if it contains a high surfactant load or certain preservatives. Many products skip this to avoid putting scary symbols on the label — but doing so is non-compliant.
Preservatives: Article 95 BPR Requirements
If your product needs a preservative (and it likely will), you must use one approved under the Biocidal Products Regulation (BPR) — specifically for Product Type 6 (PT6 – in-can preservatives).
This is where things often catch people out — in cosmetics, preservatives are regulated differently (Annex V of the Cosmetics Regulation), so people from that background aren’t used to the BPR Article 95 requirement.
In summary:
• Use a preservative listed on Article 95 for PT6
• Source it from a supplier listed for that substance and PT
Optional INCI List — but a nice touch
You're not legally required to display an INCI list like on cosmetics — but it's a nice consumer-friendly addition. If you want to use one, go ahead! But make sure the main legal focus is on:
Typical detergent-style ingredient labelling, e.g.:
• "5–15% anionic surfactants"
• "<5% non-ionic surfactants"
• "Preservatives (contains phenoxyethanol)"
• Allergens, e.g. limonene, linalool, listed if present
This format is not mandatory, and the product is not regulated under the Detergents Regulation — but keeping this approach is strongly recommended. It’s ideal for highlighting key safety-related information such as allergens and preservatives, and aligns with best practice labelling in the market.
Claims: Stay out of biocide and vet med territory!
This is a biggie.
If you make claims like:
• "Repels fleas and ticks"
• "Kills bacteria"
• "Helps with itching"
• "Supports skin immunity"
Then you're leaving general chemical mixture territory and heading into:
• Biocidal Products Regulation (e.g. PT19 for repellents, PT3 for veterinary hygiene)
• Veterinary Medicines Regulation — especially if you imply treatment or prevention of disease
Even saying something like “helps relieve itching” could be interpreted as a physiological effect — and that’s medicinal by presentation under UK law. Once it crosses that line, the product needs a full Veterinary Marketing Authorisation (VMA) — and that involves:
• Pre-clinical testing
• Efficacy data
• GLP lab work
• Easily £100,000+ to bring one product to market
You cannot sell a veterinary medicine without prior authorisation. It’s a criminal offence.
Why are so many non-compliant products on the UK market?
Because enforcement is frankly poor in the UK. But that doesn’t mean you're safe — when companies are caught, it's often because:
• A competitor reports them
• Trading Standards follows up on a complaint
There will almost certainly be a regulatory purge at some point. Better to be prepared now than pulled off shelves later.
So what can you safely do?
• Treat it as a general chemical product, and follow detergent-style labelling as good practice
• Avoid all biocidal or medicinal claims
• Use a preservative listed on Article 95 PT6
• Consider using cosmetic-grade ingredients for safety and consumer trust
• Include CLP labelling (even in small font)
• Add INCI list if you like, but it’s optional
And remember: you can state that your product contains an ingredient, but you cannot imply that ingredient has a functional benefit (e.g. "contains neem oil" is okay; "repels fleas with neem" is not — that’s a biocidal claim).
Further Reading
- Regulation (EC) No 1223/2009 — Cosmetic Products (recast)
Full text of the principal EU cosmetic regulation (still relevant for Northern Ireland and EEA markets) - Regulation 1223/2009 & Cosmetic Products Enforcement (Great Britain)
GOV.UK guidance on the Cosmetic Products Enforcement Regulations 2013 and how they apply in Great Britain - GOV.UK: Consumer Products – Cosmetics
Overview of the obligations and safety requirements for cosmetic products placed on the UK market - GB Article 95 List – HSE (Biocidal Products Regulation)
Guidance from the Health and Safety Executive on the GB Article 95 list of approved suppliers of active substances under the Biocidal Products Regulation - ECHA Guidance on Biocides Legislation
European Chemicals Agency guidance covering biocidal product authorisation, active substance approval, and Article 95 requirements - Veterinary Medicines Directorate (VMD) Guidance
Official guidance on legal requirements for placing a veterinary medicine on the UK market, including “medicinal by presentation” criteria
