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The Truth About Cosmetic Animal Testing

For several years now, we’ve seen a boom in products that make sure they are “vegan ” and “cruelty free”. However, some cosmetic products may still be tested on animals in Europe. But how can you spot cosmetic products that haven’t been tested on animals, and how are they monitored? LAO has looked into the subject for you.

What does the law say about these tests?

The European Cosmetics Regulation (No. 1223/2009) officially banned cosmetic animal experiments in 2013. The regulation prohibits carrying out animal tests within the EU for finished products and for ingredients or combinations of ingredients. This also applies to the import of products tested on animals.

The ANSM (French National Agency for the Safety of Medicines) oversees the evaluation of the quality and safety of cosmetic uses. For these tasks, it has internal and external experts, a team of inspectors and analysis laboratories, and it can take health police measures if something poses a threat to public health.

Cosmetic inspections in France are carried out in conjunction with the DGCCRF (Director of the Office of Consumer Affairs, Competition and Fraud Control) and the DRASS (Regional Directorates of Health and Social Affairs).

How can you prove the quality of a cosmetic product?

Each EU member state is responsible for enforcing the Cosmetics Regulation on its territory.

The legal requirement is that the product must not be harmful to health. It is the manufacturer’s responsibility to make sure the product meets these requirements and poses no health risk. To do so, the manufacturer must compile the product information file (PIF) and keep it available for the inspection authorities. It must include the product’s qualitative and quantitative formulas, a description of the manufacturing and control conditions, and the safety assessment of the finished product for human health.

How can these tests be replaced?

According to advocates of animal testing, animal experimentation is the surest way to measure the effects of the substances found in cosmetics. From a scientific point of view, animal tests provide estimated data and do not really make it possible to know how harmful a substance is to humans. Turning to alternative tests therefore does not mean lower safety for consumers.

To comply with Regulation 1223/2009, a cosmetic product must not be harmful to human health under normal conditions of use, and the manufacturer is required to keep available the documents attesting to its safety for human health in case of an inspection.

Cosmetic products must therefore be tested in order to honor this commitment on the part of the manufacturer. There are several alternatives to animal testing to guarantee the quality of a cosmetic product:

First, testing in vitro: products are tested on artificial human or animal cells. Second, testing in silico: this means computer calculations that make it possible to demonstrate the non-toxicity of a cosmetic product. And finally, testing on consenting human beings.

As for this last method, the test must comply with the fundamental principles of the Declaration of Helsinki as well as the scientific principles of Good Clinical Practice (GCP) defined in the ICH (International Conference of Harmonisation of technical requirement) in order to guarantee respect for the participant, as well as their safety and well-being.

The ECVAM (European Center for the Validation of Alternative Methods) is responsible for validating these alternative methods.

Why are some ingredients still legally tested on animals?

In Europe, animal testing of finished products is banned. Unfortunately, some of the ingredients that make up the product may have been tested on animals, despite the ban in the regulation.

Quite simply because a chemical or natural ingredient can be covered by cosmetic regulations but also by REACH (the regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals). This body oversees the regulation of chemical ingredients and does not ban animal testing for these ingredients, because their main function is not to be used in cosmetics.

To find out, you need to consult the technical data sheet of each ingredient.

In addition, a line in the European Cosmetics Regulation allows products and ingredients tested on animals before 2013 to keep being marketed: “Data from animal tests carried out before the respective dates of application of the marketing bans (March 11, 2009 and March 11, 2013) may continue to be used for the safety assessment of cosmetic products. 1 ”

Finally, chemical ingredients used in quantities above one ton per year in Europe must be tested. This requirement is due to the regulation REACH, which aims to determine the effects of chemical substances on health and the environment.

How can you recognize a cosmetic product that has not been tested on animals?

The labels

The Slow Cosmétique mention is a good guarantee that you are using a product that has not been tested on animals and that also contains no ingredients that might have been tested on animals.

As for vegan labels, there are several: PETA, One Voice, CCF…

However, no label can give a 100% guarantee on ALL ingredients, even if the vegan labels and the Slow Cosmétique label are the most rigorous.

100% organic and natural products

100% organic products do not prove the absence of animal testing. Unlike 100% natural products which, since they do not depend on REACH, are not subject to animal experiments.

Please note that since 2019, the ARPP has not been in favor of claims such as “not tested on animals ” or “cruelty free” on cosmetic products, because this refers to a legal obligation.

The case of products sold in China

It is well known that foreign cosmetic products sold in China are systematically tested on animals because the law requires it. While there was indeed a change in this direction in 2019, with foreign cosmetic brands no longer required to test finished products on animals, one problematic condition remains: the last step (at a minimum the packaging) must be done in China.

Conclusion

Even though the ban on animal testing of finished products, in place for 7 years now, has helped advance research into alternative methods, some companies are still demanding more.
On the other hand, because of the REACH regulation mentioned in our article, some raw materials are still tested all the same.

Every cosmetic brand has its share of responsibility in the choice of its suppliers so as not to condone this kind of practice.


In LAO’s case, we have only selected ingredients of natural origin and we have drawn up a set of specifications that was submitted to each of our suppliers.

Unfortunately, this kind of information is still rather frowned upon, and it can sometimes be hard to know the truth. That is why we choose our suppliers carefully and want to ensure the traceability of our products along their entire value chain.

Of course, our finished products will not be tested on animals.

FAQ - FREQUENTLY ASKED QUESTIONS

1. Is animal testing for cosmetics banned in Europe?
Yes. Since 2013, the European Cosmetics Regulation (No. 1223/2009) has banned animal testing for finished products and cosmetic ingredients. The import of tested products is also banned.

2. Why can some ingredients still be tested?
Because some ingredients also fall under the REACH regulation, which governs chemical substances in the broad sense (not only cosmetic ones). Under this framework, animal testing may remain mandatory for environmental or health safety reasons.

3. How are products tested today?
Brands must use alternative methods:

  • In vitro tests (on artificial cells),

  • In silico tests (computer modeling),

  • Clinical tests on human volunteers, in compliance with ethical rules.

4. How can you recognize a cosmetic product that has not been tested on animals?
Labels such as PETA, One Voice, CCF or the Slow Cosmétique mention are reliable benchmarks. Be careful: the claims “cruelty free” or “not tested on animals” are misleading because they are already a legal requirement.

5. Why are some products sold in China still tested?
Chinese legislation requires animal testing for certain imported cosmetics. Even though the rule has been easing since 2019, some conditions remain. That is why some brands refuse to sell in China.

Sources

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