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Updates on China’s Potential Change in Animal Testing Laws

Updates on China's Potential Change in Animal Testing Laws
It was just announced that China may be planning to phase out animal testing that is currently required by law. The announcement is an exciting one as it could potentially mean giant changes in the beauty industry! However, a lot of things seemed confusing about the initial press release. The Be Cruelty-Free campaign issued an FAQ to help bring some clarity to the issue.

DOES THIS MEAN CRUELTY-FREE COMPANIES CAN NOW SELL IN CHINA?

No. Firstly, the new change only applies to companies manufacturing the China, which is not possible for most of the smaller cruelty-free companies. The larger issue, however, is the fact that the Chinese government still carries out post-market animal testing of cosmetic products, and although pre-market requirements for domestic cosmetics are being simplified, post-market supervision is likely to be strengthened by Chinese regulators. According to ChemLinked.com, within three months of notifying a new, domestically manufactured ordinary cosmetic, provincial FDAs will carry out substantial examination on the product and the product information kept by cosmetic companies. Unless government surveillance efforts shift from animal- to non-animal testing approaches, it is likely that many cruelty-free companies will resist China operations in case their products subsequently become subject to government animal testing.

I encourage everyone to carefully read through this post to get a lot of insight into what’s going on with China. It’s a great step in the right direction – but too soon to give up the fight!


Following a recent announcement by the China Food & Drug Administration (CFDA) regarding changes to the country’s animal testing requirements for cosmetics, we’ve put together a brief FAQ to give you the facts on what is and isn’t changing.

BE CRUELTY-FREE CHINA Be Cruelty-Free is the dynamic global campaign from Humane Society International, launched in Europe, India, Brazil, China, New Zealand, South Korea, Canada, Australia, Russia, and in the United States via our sister organization The HSUS. Working with national partner groups, cruelty-free cosmetics companies, consumers, regulators and scientists, Be Cruelty-Free aims to change laws, policy and practice globally to create a world where no animal has to suffer and die for the sake of cosmetics. Be Cruelty-Free China is a collaboration between Humane Society International, Beijing’s Capital Animal Welfare Association, China Journalist Salon for Animal Protection, and China Youth for Animal Protection Alliance.

WHAT HAS CFDA ANNOUNCED?

On November 6, CFDA announced plans to modernize its cosmetics regulatory framework, including phasing out the requirement that new, domestically manufactured cosmetic products be tested on animals. If implemented, from June 2014, companies manufacturing “ordinary” cosmetics inside China will no longer be required to provide samples of new products to the government to be animal-tested. Instead, they will be given the option to conduct their own product risk assessment using ingredient safety data, including the possibility to rely on the results of non-animal test methods, provided the test methods are deemed scientifically valid by the European Union.

DOES THIS MEAN CHINA HAS BANNED ANIMAL TESTING FOR COSMETICS?

No, and this remains Be Cruelty-Free China’s ultimate goal that we will continue to campaign for.

DOES THIS APPLY TO ALL COSMETICS?

No. The amendment does not apply to cosmetics manufactured outside of mainland China, or to “special-use cosmetics” such as hair dyes, antiperspirants, sunscreens or skin-whitening products. However, it does eliminate the unconditional animal testing requirement for Chinese companies, who for the first time now have the opportunity to manufacture cruelty-free ranges. CFDA has indicated its intention to extend this to also include imported and special-use cosmetics once the new change has been implemented and assessed.

DOES THIS MEAN CRUELTY-FREE COMPANIES CAN NOW SELL IN CHINA?

No. Firstly, the new change only applies to companies manufacturing the China, which is not possible for most of the smaller cruelty-free companies. The larger issue, however, is the fact that the Chinese government still carries out post-market animal testing of cosmetic products, and although pre-market requirements for domestic cosmetics are being simplified, post-market supervision is likely to be strengthened by Chinese regulators. According to ChemLinked.com, within three months of notifying a new, domestically manufactured ordinary cosmetic, provincial FDAs will carry out substantial examination on the product and the product information kept by cosmetic companies. Unless government surveillance efforts shift from animal- to non-animal testing approaches, it is likely that many cruelty-free companies will resist China operations in case their products subsequently become subject to government animal testing.

WILL ALL COSMETICS COMPANIES SELLING IN CHINA BE ABLE TO AVOID NEW ANIMAL TESTING? It may be possible for companies that 1) produce only ordinary cosmetics, 2) rely exclusively on approved existing ingredients with histories of safe use, and 3) are able to carry out a full product risk assessment based on existing ingredient data and/or non-animal testing methods. There are many thousands of existing ingredients with established safety records, which is how cruelty-free companies like LUSH develop new products without new animal testing. However, many of the market leading cosmetics companies choose to develop and use “new-to-the-world” ingredients in order to give them market advantage. Such ingredients don’t have pre-existing safety data, and because non-animal test methods don’t yet exist for every single toxicity endpoint for which data is required by regulators, some new animal testing would inevitably be conducted in accordance with Chinese regulations for new chemicals. However, this is also the case in most other countries in the world. If a cosmetic company in the United States, Canada or Brazil uses genuinely “new” ingredients, new animal testing will almost certainly take place. That’s why Be Cruelty-Free corporate partners are asked to pledge not to use “new” cosmetic ingredients until their safety can be established via exclusively non-animal tests.

WHAT’S NEXT FOR THE BE CRUELTY-FREE CHINA CAMPAIGN?

Following our discussions with Beijing policy makers, we will seek to clarify answers to our outstanding questions. We will also work with our corporate partners to explore the cruelty-free potential of this new market and to assess the implementation processes. In the meantime, we will continue to press policy makers to strengthen this measure by implementing a full ban on animal testing for cosmetics in China as we have in the European Union, Israel and India.

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2 Comments

  • Reply China Takes First Step Towards Ending Animal Testing | Logical Harmony Tuesday - July 1, 2014 at 8:13 pm

    […] Another great article for background is Updates on China’s Potential Change in Animal Testing Laws. […]

  • Reply Luke Sunday - November 17, 2013 at 4:14 pm

    Great post! I am going to share this page on my channel as I got a question about this topic (I was not aware of the POSSIBLE CHANGE), however fyi leaping bunny just released some info on this also which I will comment on as well.

    this was what was sent to me
    http://www.leapingbunny.org/press13.php

    It has given me something to think about and am bit torn on it as I will mention in video, i would love to hear more what you think about it as I really value your opinion!
    THANK YOU!

  • Leave a Reply to Luke Cancel Reply