xdream

I encountered a product in the pet supply store. It is described by the store as follows:
The Outward Hound™ Pet Saver™ Lifejacket is a high performance dog flotation device for boating, water sport adventures and other outdoor activities with dogs. Provides flotation and ultimate buoyancy. According to the manufacturer, the product has the following features.
Provides flotation & buoyancy for your dog.
Exceptionally durable water repellent materials.
Convenient top grab handle for easy rescue by hand or boat hook.
Fully adjustable chest and neck Velcro flaps plus quick release buckles.
Tough 600 denier nylon fabric is soft, yet sturdy & durable.
Bright colors for easy visibility.
Durable & comfortable neoprene belly band keeps your pet warm in the water.
There are no certifications listed for this product.

My problem is this:
It looks like this fails the #1 requirement for all Personal Flotation Devices - It looks like it would not float an unconscious animal in such a manner that its head would remain out of the water.

There were customer reviews for the product. The reviews for the product were very favorable, but they all seem to focus on dogs which are swimming for short periods of time, in warm water, under human supervision. But with all the flotation positioned along the animal’s dorsal surface, there appears to be nothing to keep the muzzle elevated but the animal’s neck muscles. My guess is that the animal will eventually become exhausted and drown with its rear end sticking out of the water.

I wrote them back suggesting that it is a bad business practice to sell an uncertified safety device, especially one being marketed for use on the water.

Is my concern justified?