Animal cosmetic products that are applied to normal healthy, intact (unbroken) skin or hair or fur of animals for the purpose of altering their physical appearance or odour generally do not require registration, as long as the products do not:
- contain antiseptics, antimicrobials, antibiotics or other active constituents
- make any health, production or performance claim.
Such products will generally be chemically inert and act by physical rather than chemical or biochemical means.
Cosmetic products include products applied topically to ears, teeth or gums for the purpose of cleaning or reducing odour but exclude products applied to eyes or the teats of animals producing milk.
To further clarify this, these excluded products are listed as excluded from registration as a veterinary medicine in the Agvet Code Regulations. To be considered as such, the products must only be applied topically to an animal and they must not make any representation or claim on their label or other promotional material.
Products used as sheep branding substances and teat sealants have been specifically included as veterinary medicines in the Agvet Code Regulations.
Cosmetic products should not be represented as containing any active constituents on their labels or promotional material and their label should contain a statement such as ‘Cosmetic product. Product has no therapeutic effect’. They should not use the heading ‘For animal treatment only’, but may use the statement ‘For application to animals only’ to identify them as an animal product and differentiate them from medicines that are used for animal treatment. Products that are not clearly identified as cosmetic products may require registration.
Examples of cosmetic products excluded from registration include:
- non-medicated shampoos and coat conditioners to help clean, condition or shine an animal’s skin, coat or fur
- non-medicated deodorants or perfumes to help mask odours or make animals smell fresh
- non-medicated emollients to help moisturise or soften an animal’s skin, hooves or pads
- non-medicated toothpaste to help clean teeth and gums
- non-medicated ear cleaners to help clean and deodorise dirty ears by softening and removing the build-up of wax and dirt. These ear cleaners must not contain any antimicrobial or anti-inflammatory ingredient such as malic acid, lactic acid, acetic acid or salicylic acid, any disodium edetate, or any other Australian Pesticides and Veterinary Medicines Authority-approved active constituent or synergist
- essential oils when only represented as being suitable as a fragrance and when the directions for use result in essential oils making up 1% or less of the product being applied to an animal’s skin.
Read ‘Excluded animal cosmetic products – acceptable cosmetic messages’ for examples of the types of messages that can be used for animal cosmetic products without the need for the product to be registered.
It is important to note that where any recognised ingredient in the product is known to have a therapeutic effect, whether or not it is shown on the label, the product will fall under the definition of a veterinary product. For example, essential oil products, which are known to have some antiseptic and insect repellent effects, require registration when their directions for use result in essential oils making up more than 1% of the product being applied to an animal’s skin, regardless of the product representations.
Products that do not comply with the above requirements, or any product represented as being suitable for or used for modifying the health, production, performance or behaviour of an animal, may require registration. For example, medicated shampoos, conditioners, emollients and essential oils, when represented or used as an antimicrobial, antiseptic or insect repellent product, will require registration.