Legal aspects in animal aromatherapy
29 January 2020 By Sabine Möbius
At the lecture “Legal Aspects Aromatherapy – Aromapflege” from Aroma Forum International e.V. with the lawyer, Dr. Stephanie Reinhart on 25.01.2020 I could also talk with her briefly about the legal circumstances in animal aromatherapy.
It is important to note that the things that follow now really only apply to aromatherapy for animals in Germany – for humans it is different or regulated at all.
In the case of animals, it is actually the case that the regulations and laws that apply to humans do not apply to animals – in that case, mainly the Cosmetics Regulation and the Medicines Act.
However, this does not mean that we as animal therapists can do what we want. If we produce mixtures for animals – which must also be designated accordingly on the label – these fall under the Product Safety Act and one must:
Advise/inform/educate the user about risks and possible dangers,
- indicate the name and address of the manufacturer on the mixture,
- Provide clear labelling, including hazard pictograms if necessary.
And basically, you have to take precautions to avoid risks. What exactly does this mean for us as animal therapists?
Mixtures should have a label where all the necessary data are noted and a sheet with safety information should be handed out. Actually, the danger pictograms that may be on the essential oil bottles should be on the bottle of the mixture. If I use (as an example) lemon as an essential oil, I would have to put the hazard pictograms that are on the essential oil bottle also on the bottle of my mixture. That would be the entirely correct way to do it.
I also asked Dr. Reinhart what actually happens when the human user is interposed, e.g. when he first applies the mixture to his hand and then massages it into the animal. How that is seen evenly legally.
Here it is then in such a way that the mixture applies nevertheless still to the animal (if evenly in such a way marked) and the human being as intermediate user changes there nothing. However, it should be noted in the safety information the recommendation that the person wears gloves during application to prevent possible allergic reactions, etc.. Thus we provide again for the information/education/safety of the human user. Whether the human user actually does this during the application or does not wear gloves is no longer a matter for us as animal therapists – we have done our best to educate them.
In addition, it would be advisable to keep the safety data sheets of the products used or to have a look at them.
And if you label it, then please do not label it with a specific disease name, otherwise it could fall under the Veterinary Medicines Act. So it is always just “aroma mixture for animal XY”.
We are also allowed to sell it – because the mixture is for an animal and here the cosmetic regulation does not apply. If necessary, however, a trade must be registered (if this is not already done by the registration of the veterinary practice).
I was able to obtain the information from Dr. Reinhart through a personal conversation during one of the breaks. There is no guarantee for completeness. However, I keep myself up to date on this and if there is new information, I am happy to share it.