Have you ever picked up a pet shampoo or grooming spray in a U.S. store and wondered: what regulations does this actually fall under? More importantly—how do you know it’s safe for both pets and people?
We recently connected with both the U.S. Consumer Product Safety Commission (CPSC) and the U.S. Food and Drug Administration (FDA) to get clarity—and the answer may be simpler than you think.
In the U.S., most pet grooming products—like shampoos, conditioners, and deodorizing sprays—fall into a category known as “animal grooming aids.”
According to the FDA’s Compliance Policy Guide (Section 653.100):
- Products intended only to cleanse or beautify animals are considered grooming aids
However, there’s an important distinction:
If a product claims to treat, prevent, or cure disease, or affect the structure or function of the animal’s body, it is no longer just a grooming product—it becomes a drug under Section 201(g) of the FD&C Act and falls under FDA regulation.
If your product is strictly a grooming aid (no medical claims), it falls under the jurisdiction of the U.S. Consumer Product Safety Commission (CPSC) as a consumer product. That’s where the Federal Hazardous Substances Act (FHSA) comes into play.
The FHSA, enacted in 1960, requires that hazardous household products carry clear labeling to protect consumers. This includes providing:
- Safe handling and storage instructions
- Clear hazard warnings
- First aid guidance in case of exposure
Even pet grooming products—like shampoos—can fall under this regulation if they meet the definition of a hazardous substance.
What Makes a Product “Hazardous”?
Under the FHSA, one key consideration for pet grooming products such as a shampoo is irritation:
- A product may be classified as an irritant if it causes inflammation upon contact with skin or eyes
If your product meets these criteria, specific warning language becomes mandatory on the label.
What Must Be Included on the Label?
For products classified as hazardous under the FHSA, labeling requirements are strict and must appear on both the principal display panel and secondary panels.
Required elements include but are not limited to:
- Signal word (e.g., DANGER, WARNING, CAUTION, POISON)
- Statement of principal hazard(s) (e.g., Causes eye irritation)
- Identification of hazardous ingredients
- Precautionary statements (what to do—or avoid doing)
- First aid instructions, where appropriate
- Storage and handling instructions
- “Keep out of reach of children” (or equivalent wording)
- Name and place of business of the manufacturer, packer, or distributor
The Takeaway
For most pet grooming products in the U.S., the regulatory pathway is straightforward:
- No medical claims? → Regulated by CPSC as a consumer product
- Hazardous properties? → Must comply with FHSA labeling requirements
- Medical claims? → Becomes a drug and falls under FDA regulation
Need Help Navigating U.S. Compliance?
If you are currently selling—or planning to sell—animal grooming products which do not make any medical claims in the United States, getting the labeling right is critical.
Connect with us at Dell Tech. We can help ensure your product is properly classified, labeled, and fully compliant with U.S. regulations—so you can go to market with confidence.
Blog Author
Kirsten Alcock, H.BSc.
Kirsten Alcock is the Director of Product Safety at Dell Tech, with over 25 years of experience in regulatory affairs and hazard communication. She specializes in safety data sheets, labeling, and chemical compliance across Canadian and U.S. regulations, and is an active leader in the chemical hazard communication community.
