At a long-ago family gathering, my sister and cousin debated the merits of children.

“I like boys,” said Pam, mother of two boys.

“I like girls,” countered Michelle, a mother of three girls.

“I like dogs,” interjected Uncle Fred, the father of three boys and three girls.

Fred is not alone. US birth rates continue declining, from 3.65 births per woman in 1960 to 1.66 in 2022.  In contrast, pet ownership in the US continues to soar. Today, nearly 70% of households own a pet, up from 56% in 1988. According to the American Pet Products Association, 90.5 million US households owned a pet last year, with dogs and cats the most popular type of pet. Freshwater fish come in third.

Goldie may only need fresh water and a sprinkle of goldfish food, but Fido and Puff demand more… much more in grooming products like shampoos and cleansers. Their needs represent an opportunity for personal care manufacturers. The US pet grooming products market was worth nearly $5.0 billion in 2023 and is growing 5.4% a year. Shampoos and conditioners account for more than 50% of the total, followed by shear and trimming tools, and comb and brush.

How popular is pet care? Even Paris Hilton is entering the category!

Regulating Pet Care Formulas

The New York Chapter of the Society of Cosmetic Chemists produced a webinar on the topic of pet care. Amanda Rountree, senior manager of product development, IKI Manufacturing, began her presentation by reviewing the US government agencies that oversee the production and distribution of pet care products. The list includes the Food and Drug Administration (FDA), Environmental Protection Agency (EPA) and Federal Trade Commission (FTC).

Products intended solely to cleanse or beautify animals are grooming products and not subject to the Food, Drug & Cosmetic Act (the Act) or regulated by the FDA. But if a product purporting to be a grooming aid is intended to cure, mitigate, treat or prevent disease in animals, or to affect the structure or function of the body of animals, the product is a drug under section 201(g) of the Act. Further, anything unapproved or adulterated is subject to FDA enforcement.

“Grooming aid hybrids exist, like the cosmetic/drug combination,” added Rountree. “They include medicated shampoos with anti-fungal properties versus a shampoo that just cleanses.”

To stay in the know about FDA-approved animal drugs, Rountree suggested reading the FDA Green Book, updated monthly.

“Not all of these may be topics;” she advised. “However, it gives you an idea of everything included.”

A Review of Pesticides

The EPA is the primary agency that regulates pesticides in the US. As they pertain to pet care, pesticides include flea and tick killers. The EPA ensures the safety of pesticides in accordance with label directions. However, Rountree cautioned that not all pesticides are universal.

“What might be okay for a dog, can be toxic to a cat,” she explained.

Amanda Rountree, IKI

Chemists interested in formulating pesticides for pet care should review the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA). The FIFRA list is well-established and researched and gives the chemist an expansive list of options, said Rountree.

What’s the difference between EPA and FDA when it comes to pet care? In a nutshell, FDA regulates certain medicated products for animals as drugs, while the EPA regulates others as pesticides.

Rountree also reviewed animal drug terminology. She noted that the FD&C Act mandates a new animal drug may not be sold into interstate commerce unless it is the subject of an approved new drug application (NADA) or abbreviated NADA (ANADA).

If during research, a problem arises or it becomes necessary to learn more about a flea or tick product, Rountree said it’s as simple as reading a label. If the product is EPA-approved, visit www.epa.gov/pets. If the product is FDA-approved, go to www.fda.gov/vetproductreporting

The Toxic Substances Control Act (TSCA) of 1976 gave EPA the authority to require reporting, record-keeping and testing requirements, and restrictions relating to chemical substances and/or mixtures. When working with TSCA, Rountree recommended downloading the TSCA inventory and searching by chemical CAS number.

“The green light is when your CAS numbers are listed on TSCA Chemical Substance Inventory as active,” explained Rountree. “If you can’t find it on TSCA, it’s considered a new chemical.”

If the chemical is not listed under TSCA, Section 5 of TSCA requires anyone who plans to manufacture a new chemical substance for a non-exempt commercial purpose to provide EPA with a Premanufacture Notice (PMN).

She noted that R&D employees need some regulatory knowledge before starting to formulate pet care products. Information can be found in government resources, trusted industry sources, regulatory consultants and in-house legal teams.

“Regulations are not only ever-changing but also nuanced,” warned Rountree. “Just like every cosmetic manufacturing site might not be a fit for OTC, grooming aids alone might make the most sense.”

Pet Chemistry

Once all regulatory questions are answered, it’s nearly time to begin formulating. But first, Rountree urged attendees to consider product packaging. After all, domesticated animals will not bathe as often as humans. Large and bulk sizes may make sense for someone with multiple pets, larger pets and grooming businesses. Travel sizes come in handy, especially with dogs and horses that may be in showings.

Rountree reminded attendees to pay attention to pH. Human skin ranges between 7.35 and 7.45. Similarly, the dogs’ pH is 7.48. Horses, too, have a neutral pH of 7.0-7.4. In contrast, the skin pH for rabbits is 6.7, compared to cats (6.0) and guinea pigs (5.5).

“Consider the pH of the pet you want to formulate for,” she said.

Pet grooming products should:

• Clean skin, face/body, ears, eye discharge;

• Condition skin, hair/fur;

• Neutralize or eliminate odor;

• Moisturize skin and sensitive spots;

• Aid in grooming by detangling; and

• Freshen up and remove excess oils.

Rountree pointed out that regardless of end use, safety substantiation is critical. It includes stability and microbial studies, and testing and substantiating all product claims.

“While a list of ingredients is not necessary for animal products, it is a good practice to follow cosmetic labeling guides for transparency to the consumer,” said Rountree.

Pet Care Products

Common pet care products include shampoo, conditioner, leave-in conditioner, deodorizer, dry shampoo, salve, eye cleanser and nail care. Formulas come in an array of forms, including liquids, solids, hot pours, tubes, aerosols, wipes and sprays.

For shampoos, it is important to remember that some pets may not be able to close their eyes or anticipate the sting that some anionic surfactants can cause.

“Go with surfactants that have a low irritation profile based on results from reliable ocular studies,” she said. “These are often gentle, but still offer robust foam.”

Pets suffer from dry skin, excessive shedding, dander, tangles, matted hair and malodor. Pet conditioners can help maintain manageable hair and fur, but Rountree reminded the audience that some ingredients, such as cocoa butter, can be toxic to dogs and cats.

Leave-in conditioners help maintain post-bathing conditions, but Rountree said it is important to consider where the product may be spritzed or sprayed in case the pet licks its fur.

Fragrance plays an important role in every personal care product and pet care products, too. But Rountree said it’s important for brands to let fragrance suppliers know they are creating products for animals. She also suggested adding humectants to nourish skin and detangling agents to keep hair from tangling post-bath.

In between arduous bathing rituals, some pet owners may prefer applying deodorizers to their pets. These formulas neutralize malodors and impart some moisture to the skin via humectants.

“You can even make a wipe version of this product for quick freshness, especially on the go,” she said. “Consider some pets that self-groom, so be thoughtful formulating.”

Another option is aerosolized dry shampoo. Constructed of solvent and mattifying powder, the formula can include minerals or starch. Rountree suggested adding an anti-caking agent and working closely with a packaging engineer to ensure proper dispensing.

Cold weather and rough surfaces can be tough on paw pads. A semi-soft occlusive balm that moisturizes can protect those toe beans and snouts. Again, Rountree cautioned to consider the oils or butters that could be licked off by a dog or cat.

Some pets may suffer eye discharge buildup. A gentle surfactant with a saline-like solution to rinse away discharge can help remove stains from fur.

For larger, four-legged companions, it behooves owners to take care of hooves with formulas that include humectants, occlusives and emollients to keep breaks, dryness and brittleness at bay.

Pampered pooches may prefer hairsprays or even hair color, but Happi columnist *Valerie George is no fan of hair dye for dogs and cats.

Other Pet Care Ideas

Of course, not every formula belongs on a pet’s paws or fur. There are plenty of opportunities to create air fresheners, cage cleaners and urine/pet mess cleaners.

“Just remember to use pet-friendly ingredients,” said Rountree.

With safety top of mind, Rountree provided a checklist to consider before formulating for animals:

• Is this item on the TSCA inventory?

• Is this item safe for use on the animal intended?

• Is the pH right?

• Is there any affiliation with toxicity, allergy or other concerns?

• Are these ingredients affiliated with any FDA or EPA registration?

• Do these raw materials have any glaring regulatory issues on the state level?

Clearly, pets have different grooming needs. But that doesn’t stop consumers from asking if they can groom their pets with products intended for humans. Rountree discouraged the practice, noting it is best to formulate and use products on the subject intended.