Formulating care and hygiene products for animals
The pet-care market is booming, just as much as the market for cosmetic products for animals. It is an enticing opportunity especially as, seemingly, in the absence of a dedicated regulatory framework, formulating products for animals appears not so complex. Yet, this is far from being the case whether in terms of regulatory compliance (yes, there is a regulatory framework to comply with), the diversity of the target species, or the safety of the animal … and the person applying the product!
Introduction
Cosmetics for animals? If the topic may bring a smile, it is nonetheless a rapidly developing market. In the United States, pet-care represents a market worth ten to hundreds of billions of dollars (depending on what is included). This trend of care products for animals also concerns Europe, the world’s 3rd largest market. So, it’s tempting to invest in this space and to formulate products for animals. But is it really that simple?
Understanding the regulatory framework for “cosmetics” for animals
Before addressing the formulation specifics for animals, it is essential to take stock of the regulatory framework for animal care and hygiene products. Because this framework already influences the vocabulary to be used: under Regulation (EC) No 1223/2009, a cosmetic product is intended to be applied to human skin… So the term “cosmetics for animals” is therefore incorrect — it is preferable to use “care and hygiene products for animals”.
Care and hygiene products for animals do not have a sector-specific regulation in Europe (so there is no official definition) — it’s a grey zone. That doesn’t mean that there is no regulatory framework at all. It may seem intuitive to refer to the human cosmetics framework, but that is not what is recommended. Take the case of preservatives: for an animal care product, it is incorrect to refer to Annex V of the Cosmetics Regulation. One must refer to the Biocidal Products Regulation (EU) 528/2012 (product-type 6).
The function of the product — as well as its composition — can influence its regulatory status and push it into an existing sector-specific regulation:
- within the biocides scope, for example an anti-insect repellent;
- within the veterinary medicinal products scope, for example a treating shampoo for a skin condition.
When a product does not fall into those categories, it must still comply with transversal regulations: chemical substances regulation (REACH Regulation and CLP Regulation), biocides regulation if relevant, general product safety regulation (Regulation (EU) 2019/1020 on market surveillance may apply for goods). For fragranced products, one can question the relevance of the International Fragrance Association (IFRA) standards — they refer to human safety, and the question arises of their pertinence for animal skin. Because formulating care for animals is not formulating for little (or large) furry humans!
For further reading on formulation and regulatory aspects in pet-care, see e.g. Formulating Pet Care Products. Happi
Knowing the target’s needs
What distinguishes care and hygiene products for animals is the variety of potential targets. Dog, cat or even horse (in order of market importance for care products), each species has its own specifics: skin pH, secretions, hair type and density. One must also factor in the variety of breeds within a single species: for dogs there are more than 400 breeds! From Saint-Bernard to Chinese Crested Dog, the needs will not be the same!
The skin of our domestic animals, protected by hair/fur, is often more sensitive than human skin, which has evolved to resist its environment despite the absence of a hair covering. The skin of a dog can be as sensitive as that of a baby. It is more prone to dehydration, and its pH is more alkaline than human skin (around 7.5 vs. 5.5 for humans) which predisposes it to skin infections in case of imbalance. It is therefore necessary to adapt the pH and to favour mild cleansing bases in animal products, just as shorter formulas are preferred.
Sensorial experience is not to be neglected, but other criteria must remain in mind such as rinseability. This is indeed paramount for cleansing products. For domestic animals, it’s about comfort for the animal (to limit the rinsing time) but also about safety, to avoid any cutaneous irritation or ingestion by licking in case of poor rinsing. For larger animals like horses, it is also an environmental gesture! The volume of foam generated, and the amount of rinse water are much higher than for a small dog.
The fragrance must be a point of attention, since the olfactory sensitivity of animals, particularly dogs, is much more developed than ours. A fragrance that is too present can disturb the animal but also interfere with its communication with other animals because its olfactory identity is blurred. Some scents, even if appreciated by owners, are not by animals. Dogs and cats for example are not keen on citrus scents, which are even repulsive for them. It is possible to test the perfuming compositions to verify that they are appropriate for the target.
Care/hygiene products for animals follow the same trends as cosmetics, and it is tempting to follow them sometimes by using “trendy” ingredients. But it is appropriate to ask for proof of efficacy in animals, and to not duplicate cosmetic formulas with ingredients that have no benefit in an animal care product. Some raw-material suppliers are beginning to perform specific tests, for example on reconstructed canine epidermis. National Veterinary Services+1
Taking into account a dual constraint, animal and human
Compared with “human” cosmetics, care and hygiene products for animals present another peculiarity: the product’s receiver is not the same species as the one applying it. Thus, even if for the animal the REACH regulation gives the list of authorized substances for formulation, it remains relevant to account for human-cosmetic restrictions and prohibitions.
Although there is no obligation for a full product safety report, a safety evaluation of the formula is nonetheless recommended to ensure the safety of the animal’s owner, especially if it is a professional product (groomers, breeders, etc.).
For the animal, the lack of toxicological data for certain species (and breeds) can complicate this assessment. The skin and metabolic specificities of animals must be considered, and risk analysis must be carried out even for ingredients well known in human cosmetics and deemed safe for humans. The risk of ingestion (licking) must be considered. Cats metabolize certain substances differently, which can become toxic for them, e.g. certain essential oils or benzalkonium chloride. Some other substances which may pose a risk in animals: certain botanical extracts that attract insects (strawberry, banana), glycols, benzoic acid, benzyl alcohol, theobromine, organic acids, sodium lauryl sulfate. Recognized allergens for the target animal may also differ from the list of mandatory labelling allergens, and should be considered as important as “human” allergens from the owner’s exposure.
In summary:
- The owner is also part of the safety equation;
- The animal’s species /breed /skin-specific data must be addressed;
- Ingestion risk and cross-species metabolism are key.
Conclusion
Even without a specific sectoral regulatory framework, formulating care and hygiene products for animals proves to be more complex than formulating for humans. Because absence of sector-specific regulation does not mean absence of obligations: the products must nonetheless comply with transversal regulations. The target species are moreover diverse, each with their specific needs, both in terms of requirements and in terms of evaluating the safety of the formula. Over and above the dual constraint of safety for the animal and the human who handles the product, one must therefore propose a product that is coherent with the animal’s needs, but that also satisfies the human. This balance is sometimes delicate and must prioritize the animal’s wellbeing, without falling into purely marketing-driven excess.
