This has been a big week in the cruelty-free community. Earlier in the week claims came out that cruelty-free brand Wet n Wild was seen having in-store displays in Mainland China. This is a big deal because it is currently very difficult for cosmetics to be sold in Mainland China without animal testing.

There are cases where products are sold without the brands’ permission, so many of us, myself included, wanted to keep an open mind until things were confirmed by the brand. I often get sent photos of product displays in mainland China that end up either not being real products, not being there through legal means, or end up actually being in Hong Kong (where animal testing is not required). Because Wet n Wild has been so vocal about being cruelty-free, and even their desire to become a fully vegan brand, I wanted to give them the benefit of a doubt.

In this post, I run through where things currently stand with Wet n Wild and what that means for their status on the Logical Harmony Cruelty-Free Brand List.

Wet n Wild was first added to the Logical Harmony Cruelty-Free Brand List back in 2011. They were one of the first brands to be a part of the cruelty-free brand list. I have a lot of history as a customer of this brand and was using them before I was even focused on the cruelty-free niche. Having grown with this brand over the years, I have always had a personal soft spot for them.

Many people were reaching out to the brand after the photos and rumors surfaced. Several people came forward and sent me very recent screenshots of IG DM’s from the brand saying that they were not being sold in China. In the comments section of the brands IG, people were saying that they had also just been told the brand was not sold in China.

After staying relatively silent about the concerns, Wet n Wild finally released a statement via Instagram Stories on the evening of May 21, 2019.

“Wet n Wild does not test on animals. Wet n Wild is a global brand for beauty lovers, inclusive of all ages, ethnicities, skin colors, ideologies and economic statuses. Cruelty-free has and will remain a key pillar of our brand. in 2018, Watsons began offering our products to beauty enthusiasts in China via a pilot program in 30 stores. Wet n Wild products sold in China are domestically manufactured in China, and as such do not require animal testing.

Since 2014, China no longer requires animal testing for domestic non-special use cosmetics. Wet n Wild products were able to enter the Chinese market maintaining our commitment to providing customers cruelty-free, high-quality, on-trend products they can feel good about buying and wearing. As a trusted leader in cruelty-free beauty, we will continue to work closely with the Chinese government, and all governments, to adhere to our strict guidelines for cruelty-free beauty globally.

Stefan Curti
Global President”

What exactly does this mean?

Let me break this down in a few ways. At first glance, the statement makes it sound as if the brand is cruelty-free. Unfortunately, things aren’t black and white and there is a lot of grey area when it comes to animal testing in China.

Is Wet n Wild cruelty-free? No.

Wet n Wild is no longer going to be on the Logical Harmony Cruelty-Free Brand List. Wet n Wild no longer meets the Logical Harmony standard be considered a cruelty-free brand. In order to consider a brand cruelty-free, animal testing cannot occur at any point or be performed by any party. This extends from ingredients all the way to the products placed on the market for sale.

For those of you who want to get into the nitty-gritty of things, I’ll outline additional details below.

Wet n Wild was a part of PETA’s Beauty Without Bunnies program in 2011. Their parent company, Markwins International, joined them in the Beauty Without Bunnies program in 2012. Markwins International was, at some point, also certified through Leaping Bunny. Several years ago they did not renew with the Leaping Bunny program but it is unclear why. Wet n Wild themselves were never part of the Leaping Bunny program.

Is Wet n Wild selling in stores in China? Yes.

For a long time, Wet n Wild told customers that they were not sold in China. Even on May 21, 2019 I received DM’s from customers of Wet n Wild saying that the brand had told them they were not sold in China as recently as that day.

Per the statement, not only was Wet n Wild present in China at that time, but they entered the market in 2018. This is a huge blow to consumer trust with the brand and it leaves a lot of questions. They are currently sold in 30 Watson’s locations in mainland China.

Does the pilot program meant that they can avoid animal testing? No.

Wet n Wild’s statement said that they are part of a pilot program with 30 stores. From their statement, my understanding is that it’s a test program in a limited number of Watson’s stores in China meant to help see how sales go.

There is a Cruelty-Free International pilot program for brands that are Leaping Bunny certified through Cruelty-Free International. The goal of this program is to help brands sell in mainland China and remain cruelty-free. Wet n Wild is not Leaping Bunny certified, however, so Wet n Wild would be able to take part in this program.

Brands that are currently included in this pilot program are Bulldog Skincare, Neal’s Yard Remedies, Seventh Heaven, Subtle Energies, Azena, and Brighter Beauty. These brands are Leaping Bunny certified through Cruelty-Free International.

Is it true that since 2014 China has banned animal testing? Not exactly.

Back in 2014, China announced that they would start to make changes to its animal testing requirements. These changes relate specifically to pre-market animal testing. Products were divided into two categories – special use and non-special use. The products in each category have changed over time and there does continue to be overlap between the two.

Some of the pre-market animal testing laws have been reduced. These steps first started to be taken in 2014, but pre-market animal testing for cosmetics sold in China is still required in most cases. When it comes to non-special use products, it’s very tricky with cosmetics to determine what falls into these categories. It’s not black and white and it’s not simple.

Brands are able to easily avoid animal testing in China by selling only via direct-to-consumer e-commerce and not having a presence in physical stores in mainland China. Brands are also able to sell in stores in Hong Kong, where animal testing is not required by law.

Lately there have been rumors circulating that China is ending animal testing. I addressed this here on Logical Harmony, and in her article for Glamour, Justine Jenkins also highlights that this is a complex issue. Her article is a great read and I think it’s one everyone wanting to familiarize themselves with this issue should check out.

What is pre-market animal testing?

Pre-market animal testing is when the finished products are tested before they are placed on the consumer market for sale. For many brands, this is when animal testing as required by law occurs. There are now some cases in China where brands can avoid pre-market testing, but they are in rare and very specific cases.

Can Wet n Wild avoid pre-market animal testing? Maybe.

It is possible that Wet n Wild can avoid pre-market animal testing. Unfortunately, that doesn’t remove the potential for post-market animal testing.

What about post-market animal testing?

Post-market animal testing is when the finished products are tested after they have been approved to be placed in the consumer market. This means that they are pulled from the shelves of stores to have testing conducted on them.

The opinion on post-market animal testing seems to vary depending on the organization that you talk to. Some say that it no longer involves animals the majority of the time, while others state that it does most of the time. To me, the takeaway here is that animals can still be used for post-market animal testing.

Humane Society International, an organization I trust immensely, has this to say about post-market animal testing:

It’s encouraging but not yet a guarantee that no animal testing will ever again happen post-market, and pre-market animal testing for imported cosmetics remains as before. So what’s changed? China recently released for the first time its post-market testing plan, and it reveals that no animal tests are listed for routine post-market surveillance.

However, in the case of non-routine tests, eg: a consumer complaint about a product, unless/until authorities accept modern non-animal eye/skin irritation tests, and invest in local infrastructure to use such tests, animal testing could still be the default.

Pre-market cosmetic animal testing in China for foreign imports and special-use products, remains unchanged.

This shows that animals can be used for post-market animal testing. This is in relation to some other recent changes in China, but I do think it’s important to share in this context as well.

There is no concrete evidence that indicates that brands have any control over post-market testing. The Chinese government could pull any cosmetics for post-market testing for a non-routine test at any time. It is also my understanding that they do not have to contact the brand before these tests are done, so the brand may not be aware that they are happening. Humane Society International backs up this understanding and I have had this confirmed to me by brands who currently sell their cosmetics in China.

Brands who currently sell in China have also told me that they pre-emptively agree to these tests when they enter the market in China and pay fees to cover them. I have not seen contracts that confirm this, but several brands have told me this in confidence independently of each other.

Can Wet n Wild avoid post-market animal testing? No.

Post-market animal testing on cosmetics is still a reality and something that we as consumers should consider. It is not something that Wet n Wild is likely able to avoid, especially since it can occur at any time.

Is Wet n Wild cruelty-free? No.

Wet n Wild Beauty is no longer going to be on the Logical Harmony Cruelty-Free Brand List. Wet n Wild no longer meets the Logical Harmony standard be considered a cruelty-free brand.

This situation has left many in the cruelty-free community feeling very uneasy and with a lot of questions.

Why did Wet n Wild tell consumers that they were not selling in China? Why did they not announce this change in their sales markets when it happened? More importantly, why did they not come forward when photos first surfaced and tell people that they were authorized displays? It’s hard to for me to understand the logic here and, as a long-time Wet n Wild customer, I feel hurt by their lack of honesty. I believe that brands should be able to stand by their business decisions and be transparent about them.

All that said, at the end of the day, I am just thankful there are so many amazing cruelty-free brands out there. I encourage everyone upset by this to take some time and thank some of your favorite cruelty-free brands for being cruelty-free. Let them know it’s important to you and that you appreciate them.