Pet accessories sit in an awkward place in product law. They are not food, not toys for children, not medical devices, and in the markets covered here we did not find a law written specifically for them. That does not mean nothing applies: general product safety law, chemical restrictions and labelling rules all reach a pet bed, toy or bowl, and the importer or brand is usually the one who answers for them.

This article sets out the rules we were able to check against the published texts for the EU, the United States and Japan, what they mean for the materials and labels of non-food pet products, and what to ask a factory for. Where we could not confirm a rule, we say so. Checked against the published texts on 26 October 2026.

💬 Selling pet products into more than one market? Tell us where you will sell and what the products are made of, and we will build the material checks and label content into the order from the start. Tell us about your range.

The rules at a glance

In the EU the General Product Safety Regulation and the REACH restrictions are the main texts for non-food pet products; in the US, California’s Proposition 65 and specific federal rules apply product by product; Japan’s pet food law does not reach accessories.

TopicEuropean UnionUnited StatesJapan
General safetyRegulation (EU) 2023/988 (GPSR), applies from 13 December 2024No single general rule checked here; specific federal rules apply to some products, for example button cell batteriesNot confirmed for pet accessories; confirm the current rule
Restricted substancesREACH Annex XVII, for example entry 51 (phthalates) and entry 63 (lead)California Proposition 65 warnings for listed chemicalsNot confirmed for pet accessories; confirm the current rule
Fibre content labelsRegulation (EU) No 1007/2011 for textile products, including products with at least 80% textile fibres by weightFTC Textile Act rules list cushions and beddings; pet items are not namedHousehold Goods Quality Labelling Act applies to listed items; confirm whether yours is listed
Pet food lawSeparate pet food rules; not needed for accessoriesSeparate pet food rules; not needed for accessoriesPet Food Safety Act covers food for dogs and cats only
Bowls and food contactFood is defined as food for humansFood is defined to include food for animalsSee carriers, bowls and litter products

A blank or “not confirmed” in this table does not mean no rule applies. It means we did not confirm one against a primary text, and you should check before you rely on it.

European Union: the General Product Safety Regulation

Under the GPSR only safe products may be placed on the EU market, the manufacturer must run a risk analysis and keep technical documentation, and the product must carry identification and contact details.

The GPSR applies to products intended for consumers or likely to be used by them, insofar as no specific EU rules with the same objective apply. A pet bed, toy, bowl or carrier sold to pet owners is such a product. The points that matter for a brand importing from Asia:

  • Safe products only. Article 5: economic operators shall place or make available on the market only safe products. Article 6 lists what is considered in assessing safety, starting with the product’s characteristics, design, composition and packaging.
  • Risk analysis and technical documentation. Article 9(2): before placing products on the market, manufacturers shall carry out an internal risk analysis and draw up technical documentation.
  • Identification on the product. Article 9(5): a type, batch or serial number or other identifying element, visible and legible, or on the packaging or an accompanying document where size or nature does not allow it.
  • Manufacturer’s details. Article 9(6): the manufacturer’s name, registered trade name or trade mark, and postal and electronic address, on the product or, where that is not possible, on the packaging or in an accompanying document.
  • Importer’s details. Article 11(3): importers add the same details for themselves, without obscuring the manufacturer’s information.
  • Instructions and safety information in a language easily understood by consumers in the member state concerned (Article 9(7) for manufacturers), unless the product can be used safely without them.
  • A responsible person in the EU. Article 16(1): a product covered by the regulation shall not be placed on the market unless there is an economic operator established in the Union responsible for the tasks in Article 4(3) of Regulation (EU) 2019/1020.

If you sell under your own brand, you are likely to be the “manufacturer” under Article 3(8), even though a factory in Asia makes the product. What an online listing must show is set by Article 19; our guide to launching a private-label pet products brand covers that.

European Union: chemical restrictions that reach pet products

REACH Annex XVII restricts certain substances in articles generally, not only in children’s products, so pet beds, toys and mats are within reach of several entries.

Two entries are worth checking first for pet accessories:

EntryWhat it restrictsWhere it bites in a pet range
51 (as amended by Regulation (EU) 2018/2005)DEHP, DBP, BBP and DIBP shall not be placed on the market after 7 July 2020 in articles at 0.1% by weight or more of the plasticised material, individually or combinedPVC squeaky toys, vinyl coatings, non-slip bases, PVC mats, printed designs
63 (as amended by Regulation (EU) 2015/628)Lead at 0.05% by weight or more in articles supplied to the general public where the article or accessible parts may be placed in the mouth by children, with release-rate exceptionsSmall metal parts, painted or coated components, items small enough to be mouthed

Entry 51 lists exemptions, including articles exclusively for industrial or agricultural use, or exclusively for open-air use, where no plasticised material contacts mucous membranes or is in prolonged contact with skin. A pet bed or toy used in the home will not usually fit those exemptions, but ask your laboratory to confirm the scope for each product. REACH has other entries and is amended often, so check the consolidated text and ask the laboratory which entries it tests against.

Textile fibre labels

Regulation (EU) No 1007/2011 requires textile products to be labelled with their fibre composition when made available on the market, and Article 2(2) treats products with at least 80% textile fibres by weight as textile products. Whether a given pet bed, mat or garment meets that test depends on its construction. How fibre names, percentages and language work is explained in our guide to garment care and content labels by market.

When a pet toy is treated as a children’s toy

The EU toy rules apply to products designed or intended for play by children under 14, and the new Toy Safety Regulation adds a test based on what a parent could reasonably assume. Our guide to pet toy materials and testing explains how that affects design and packaging.

💬 Need test reports that match the markets you sell into? We agree the test list with you, arrange testing at a third-party laboratory on samples taken from production, and keep the reports with the order file. Send us your product list.

United States: Proposition 65 and product-specific rules

California’s Proposition 65 requires a clear and reasonable warning before a business exposes anyone to a listed chemical, and federal rules apply to particular product features such as button cell batteries.

California Health and Safety Code section 25249.6, added by Proposition 65, provides that no person in the course of doing business shall knowingly and intentionally expose any individual to a chemical known to the state to cause cancer or reproductive toxicity without first giving clear and reasonable warning, except as provided in section 25249.10. Section 25249.8 requires the list of such chemicals to be revised and republished at least once per year. The law is not specific to children’s products, so a pet product sold into California is within its reach.

In practice, ask the factory which materials, coatings and colourants it uses, test for listed chemicals that are plausible in those materials, and decide with your US importer or counsel whether a warning is needed and how it must be worded.

Other US points we checked:

  • Batteries. The Consumer Product Safety Commission has recalled pet toys for violating the mandatory standard for consumer products with button cell or coin batteries under Reese’s Law. See our pet toy guide.
  • Textile labels. The FTC’s rules under the Textile Act (16 CFR 303.45) list items including cushions and beddings as subject to the Act. Pet beds and mats are not named, so confirm with counsel or the FTC before you rely on either answer.
  • Bowls. The statutory definition of food includes food for animals; see our guide to carriers, bowls and litter products.

Other federal and state rules may apply to specific materials or products. Confirm the current rule in the market where you sell.

Japan: what the pet food law does and does not cover

Japan’s Pet Food Safety Act covers food for pet dogs and cats; it does not regulate beds, toys or bowls, so accessories must be checked against other Japanese rules.

Under Article 2 of the Act on Ensuring the Safety of Pet Food, pet food means things used for the nutrition of pet animals, and Article 1 of its Cabinet Order limits those animals to dogs and cats. Accessories are outside it. Our article on pet food made in Vietnam covers the food side.

For accessories, Japan’s Household Goods Quality Labelling Act sets labelling rules for the household goods designated under it; our garment label guide covers its textile rules. Whether a particular pet product is designated is something we did not confirm, so check it against the current rules, along with any electrical or battery rules for powered items.

What to ask the factory for

Ask for a material list per component, test reports from a laboratory you accept, and labels drafted for the market where you sell, before you approve the production sample.

Ask forWhy
A bill of materials per component, including coatings, inks and colourantsRestrictions apply by material; you cannot choose tests without it
Test reports naming the sample, the method, the laboratory and the dateA report that cannot be linked to your product proves little
Retesting when a material or supplier changesA new colourant or a new foam supplier can change the result
Label and packaging drafts per marketIdentification, contact details, warnings and language differ
A record of the approved sampleYour evidence that production matched what was tested

Test reports belong to a specific product and material. Ask for testing on samples taken from your production, not on a general report the factory holds for another customer. Our guide to pre-shipment inspection and AQL explains how to combine testing with inspection, and pet beds and cushions shows how these points apply to a sewn product.

Frequently asked questions

1. Does the EU General Product Safety Regulation apply to pet products?
It applies to products intended for consumers or likely to be used by them, where no specific EU rules with the same objective apply. Pet accessories sold to owners generally fall within it.

2. Do REACH restrictions apply to pet toys and beds?
Several Annex XVII entries apply to articles generally, including entry 51 on four phthalates in plasticised material. Your laboratory can confirm which entries apply to each product.

3. Does Proposition 65 apply to pet products sold in California?
The law is not limited to children’s products. If a product could expose someone to a listed chemical, decide with your importer or counsel whether a warning is needed.

4. Does Japan’s Pet Food Safety Act cover pet accessories?
No. It covers food for pet dogs and cats. Accessories must be checked against other Japanese rules, such as household goods labelling where the item is listed.

5. Can I use the factory’s existing test reports?
Only if they clearly cover your product and materials. Reports on other products prove little. Ask for testing on samples from your production, and retest when a material changes.

Summary

Non-food pet products are covered by general safety, chemical and labelling rules rather than by a pet-specific law, and each market draws the lines differently. Build a material list per component, test against the rules of the market where you sell, and put the identification and contact details each market requires on the product and pack.

Sunsho Trade is a trading company, not a factory. For pet products we find and vet the factory, agree material and test plans, arrange laboratory testing and inspection, and check labels with you before production.

💬 Ready to source pet products that meet the rules of your market? See our pet products OEM service, or send us your product list and we will come back with factory options and a test plan.

Sources

Checked on 26 October 2026.