PET SHAMPOO INGREDIENT LISTS PART 1

PET SHAMPOO INGREDIENT LISTS

PART I – THE CURRENT SITUATION

   As more pet groomers have been requesting ingredient information, some companies have been responding and will provide ingredient lists.  Others, especially companies that retail to the public, want their product labels to resemble human products and include ingredient information on the label.  Not all these ingredient declarations are equal, however, and not all are complete and informative. There are some of manufacturers that stubbornly refuse to share ingredient information, and claim “trade secrecy.” 

Why are pet shampoo manufacturers so resistant to disclosing ingredient information? 

•            Because they don’t HAVE to disclose. There is no legal mandate requiring manufacturers to disclose ingredients. Some cosmetic manufacturers (human or animal) would much rather market by hype and claims than by actual ingredients.
•       Because pet shampoo formulas are more similar than different. Pet shampoo companies make a big fuss over the importance of “trade secrecy” to their ingredient lineups, as if they contain unique and special ingredients.  The truth is pet shampoos are more similar than different from company to company. While the designer additives may differ, the working part of the shampoo, the shampoo base, is often similar. This is not necessarily a Bad Thing.  Simple and similar ingredient line-ups can be very effective in cleaning dirty dogs. The different additives give the products their personality and image. 
•       Because they don’t want pet groomers to become “ingredient police.”  This is a reason with which I empathize.  There is way too much Internet propaganda and fear mongering designed to frighten people away from traditional ingredients.  Unsophisticated and unaware consumers buy into negative propaganda about “dangerous ingredients” and want to cherry-pick ingredients.  An example of a maligned ingredient is Propylene Glycol.  This moisturizing ingredient has been used effectively for decades, has been extensively studied and determined as safe, but manufacturers of alternative, more “natural” products, want to scare us away from by calling it “anti-freeze”, and worse.  Pet shampoo manufacturers do not want to have to defend every ingredient choice. 
•        Because they want to be able to change or modify formulas without costly label printing, and without consumers knowing that they have changed the formula(s). This is understandable, although not defendable.  Consumers should know of changes in ingredient lineups, regardless of the cost of label printing.

What can we expect to find on a pet shampoo ingredient list?

     Not only is there no legal mandate that requires pet shampoo manufacturers to disclose ingredients, there is no uniform format for listing ingredients when they are declared. One manufacturer’s ingredient list may use formal chemical names for all or most items, and another may use common names or chemical supplier’s jargon.  While some companies are forthright and use the rules established for human cosmetics, others dance around the issue of disclosure, by using descriptive terms, hiding ingredients under the mantle of “shampoo base”, or simply listing only the additives or “selling point” ingredients. 

What is required on a list for human cosmetics?

It is helpful to look at the requirements for human cosmetics, as it gives us a model by which we can gauge the informational value of the pet product lists we obtain.  Also, a look at human cosmetics labeling gives insight into the assumptions and expectations we have when we look at a list of declared ingredients for a pet product. 

Authority over cosmetics labeling was assigned to the FDA by the Federal Food Drug & Cosmetic Act of 1938.  The act has been amended to add regulations over the years.  The current cosmetic ingredient labeling regulations were established in 1977. They require ingredients to be fully declared, in descending order of predominance, by the nomenclature established in reference sources of ingredient names.  The primary reference used today is the International Cosmetic Ingredient Dictionary and Handbook. This reference lists ingredients by the INCI names, International Nomenclature of Cosmetic Ingredients. ¹

1  1.  Fully Disclosed – Each and every ingredient must be identified.  The notable exception is trade secret ingredients.  Companies must submit an application to have trade secret status, and then must list “other ingredients” at the end of the ingredient list.  Another way to identify these proprietary ingredients is to use an assumed company name that does not allow its identification through any of the listed sources.  In pet products, an example of this type of listing is EZ Groom Crystal White Shampoo that lists, “Enzywhite-SRW Complex”. 

A trade secret is defined by the Freedom of Information Act as “any formula, pattern, device or compilation of information used in one’s business and which gives him an opportunity to obtain an advantage over competitors who do not know or use it.”  Under this definition, EZ Groom’s enzymatic complex would likely pass as proprietary, but common surfactants found in shampoo bases would not.
Currently, fragrance ingredients are the only ingredients in labeling of human products that can be identified simply by function, “fragrance” or “parfum.  In pet product labeling, it is common to find ingredients identified by description of their function rather than chemical names.  I call this the “descriptive dodge.”  An example would be, “coconut cleansing agent”.

2   2.    Descending order of predominance – This rule applies to all ingredients present in concentrations of more than 1% in the finished product.  Ingredients present in 1% or less amounts may be listed in any order after those at higher concentrations. Also, color additives may be listed in any order after the listing of all other ingredients.  Under this rule, most shampoo ingredient lists would begin with “water” and end with one or two color additives, or identification of the preservatives. 

Many pet shampoo ingredient lists break this rule, mixing up the order so that the selling point ingredients appear at the top of the list.  For example, an Oatmeal Shampoo might list Oatmeal as the first ingredient.  Really?  If there is more oatmeal in the bottle than water, it would not pour.  If there is more Aloe Vera juice than cleansing surfactants would the shampoo clean? 

      3.   INCI names.  Few people other than chemists really like the technical INCI names for cosmetic ingredients.  However, this nomenclature serves a very important purpose: use of INCI names reduces inconsistencies and confusion in how ingredients are identified.  When an ingredient is identified under a scientific name  (Lauramide Diethanolamide) on one list, a trade name on another (Lauramide D), and by function on a third list (foam stabilizer), the consumer has no way of knowing that these are all the same item.  INCI names level the playing field. On human products, botanical ingredients are required to be listed by their latin names, although common names can be used in parenthesis.  Lavender essential oil would be listed only as Lavendula officinalis (Lavender) oil.  This is rarely found on pet products. 

     4. No qualifying or descriptive information – On human cosmetics ingredient lists, they are not supposed to put modifying or qualifying information that makes other brands look bad in comparison, such as, organic, purified, or from coconut.  The use of modifiers is common in pet product ingredient information.  Gentle, mild, earth-friendly, are all used for marketing appeal. 

Since no requirements exist for the labeling on pet products, there is no reason not to use the human cosmetics labeling requirements.  Why should we hold pet products to a lesser standard?  We shouldn’t of course. Ingredient lists are important not only in comparing one product to another, but also in assessing how well the product ingredients measure up to the product marketing claims.  In Part 2 of this series, we will look at some pet product ingredient lists and assess them against the requirements for human labeling.  Stay tuned.  “Technical” can be fun!