Found another piece of the puzzle as well.
On the Dry Shampoo bottle there are instructions in a second language.
German!
And Personal Care Regulatory in England / Ireland is listed below the USA and AU distributorships suggesting that EU approval is being sought for the product to be sold through Douglas or perhaps even QVC which has been referenced to a start in Germany in 2020.
Evolis Dry Shampoo, page-47
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