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Top 5 Hurdles

1. China's testing

2. Poor R&D funding

3. Unique new ingredients

4. EWG & Campaign for Safe Cosmetics

5. Little consumer pressure

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Top 5 Hurdles to Ending Animal Testing of Cosmetics

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March 20, 2016

Animal testing of cosmetics continues, despite the public's desire to end it, and despite experts' concern that animal tests often do not predict human response. Pharmaceutical industry data reveal that animal testing does not correctly predict the human response in 96% of human clinical trials (1). Finding alternative methods is crucial for human safety, as well as for animal welfare.

Here are the top 5 hurdles to ending animal testing of cosmetics, and what you can do to help.

1. China's policy of animal testing. China has begun changing this, and there's reason to hope this hurdle will fall in a few years.  What You Can Do: Buy only Leaping Bunny brands and Choose Cruelty Free brands, which are confirmed to not sell in China. Importantly, tell the brands that their China policy drove your buying decision! More...

2. Lack of resources to develop alternative methods. Non-animal methods are still not available to evaluate long-term effects, such as carcinogenicity.  What You Can Do: Urge your US Representative to co-sponsor and pass the Humane Cosmetics Act (H.R. 2858), which would ban animal testing and force industry to commit resources to find the alternative methods. More...

3. Unique new ingredients. After China, the biggest trigger for animal testing today is industry's development of unique new ingredients, which require long-term tests that still have no alternatives.  What You Can Do: Contact a major cosmetics company, and tell them you don't want new ingredients if they require animal testing; to please halt development until alternative tests are available. More...

4. EWG and Campaign for Safe Cosmetics. They believe animal testing is important and are lobbying hard for the Personal Care Products Safety Act (S. 1014), which would allow animal testing and doesn't require companies to use non-animal methods even where they are available.  What You Can Do: Urge your US senators to oppose this Act. Speak out on social media when you see EWG and CSC promoting the Act. Ask your favorite brands to oppose the Act. Write EWG and CSC that animal testing is unacceptable and ask them to work for ban. More...

5. Little consumer pressure. When polled, most people say they are against animal testing of cosmetics; but when buying, they often don't think about it. When people do buy for this reason, retailers often don't know that was a consideration.  What You Can Do: Tell decisionmakers -- retailers and brands -- cruelty free is driving your buying decisions. Mention it to your friends when you are shopping together. More...




1. China's policy of animal testing

China's large market is a draw for companies in all industries. Companies selling cosmetics and personal care products in China, however, must accept animal testing of their products.

China requires animal testing of all cosmetics and personal care products imported into China. Companies can avoid this testing by manufacturing products within China; however, sunscreens, antiperspirants, and other products that claim a specific function must undergo animal testing whether they are made in China or imported.

In addition, China conducts spot-testing (also called post-market testing) of cosmetics on the shelves, and that cannot be avoided even for cosmetics made in China. For spot tests, local officials pull products off store shelves. At the official's discretion, the spot tests may simply be microbiological tests, or they may be animal tests (2).

We don't know how many animals die in testing cosmetics and personal care products in China, but the number is certainly high. Humane Society International believes it may be 300,000 animals/year.

China is open to changing to non-animal methods. They have been working with the Institute for In Vitro Sciences since 2013 to learn non-animal tests and to train scientists within China in these methods. Already with this technology transfer, China has eliminated its animal testing requirement for ordinary cosmetics made domestically.

What you can do

We probably can't influence China; however, take heart that China has begun to allow non-animal methods. There's reason to hope China will adopt non-animal methods more broadly. In the meantime, we can save animal lives by discouraging brands from selling in China.

  • Buy only brands that don't sell in China. Look for Leaping Bunny brands and Choose Cruelty Free brands, because these brands have been audited to confirm they don't test or sell in China.

  • Be vocal so the brands hear you! Tell the brands that you have chosen them because they don't allow animal testing, so that they realize this is an important consumer consideration. If you switch from a brand that sells in China, tell them you stopped buying them because they allow animal testing, so that they know it's affecting their bottom line. If you don't tell them, they won't know!

Major brands that sell in China are L'Oreal, Avon, Mary Kay, Estee Lauder, Lancome, L'Occitane, OPI, Stila, Makeup Forever, and Jurlique, but there are many more. My Beauty Bunny has a much more comprehensive list (for her list, scroll to just below her intro text).

Here is contact information for many major cosmetics companies. A short, respectful conversation or email is an effective way to have someone really hear you.


   Procter & Gamble
   301 E 6th St
   Cincinnati, OH 45202
   513-983-1100
   Send an email
L'Oreal USA
575 Fifth Av
New York, NY 10017
212-818-1500
Send an email
Revlon
1501 Williamsboro St
Oxford, NC 27565
800-473-8566
Send an email
Avon
New York, NY
212-282-7000 (general)
800-445-2866 (Product
Information Center)
Send an email
 
   Estee Lauder
   767 Fifth Av
   New York, NY 10153
   877-311-3883 (general)
   212-572-4200 (corporate)
   Send an email
Johnson & Johnson
One Johnson & Johnson Plaza
New Brunswick, NJ 08933
732-524-0400
Send an email
Mary Kay
16251 Dallas Pkwy
Addison, TX 75001
800-627-9529
Send an email
Unilever
USA Office
800 Sylvan Av
Englewood Cliffs, NJ 07632
 
Canada Office
160 Bloor St E, Ste 1500
Toronto, ON M4W 3R2
USA: 800-298-5018
Canada: 416-964-1857
Send an email



2. Lack of resources to develop alternative methods

Although non-animal alternatives exist for many safety tests, a major group of safety tests still lacks alternatives. These are the long-term tests, which look for long-term effects such as carcinogenicity. Long-term tests also take the most animals.

Finding alternatives for long-term animal tests is a major challenge in toxicology. An effective alternative must properly represent the complex processes in the human body. The challenge has been likened in scope to the Human Genome Project.

Scientists expect of alternative methods an accuracy that animal studies never achieve. Animal studies are often poor predictors of human response: 96% of drugs have not passed human clinical trials because of issues not predicted by the preceding animal tests. In 30% of the failures, the animal tests didn't predict safety problems (1). Such poor performance makes animal tests unacceptable for human safety, as well as for animal welfare.

The toxicology community has developed a roadmap to meet the challenge (3), but they are short on resources in two ways:

  • Money. US and EU funding for the required research has been anemic. Government often funds basic R&D for public health concerns. However, research funding in general has taken a hit in the US, and the EU's funding of alternatives has been minimal, too (4). L'Oreal, P&G, and other large cosmetics companies have invested in R&D for this, but without a US animal testing ban forcing them to solve the problem, they have little incentive to commit enough resources.

  • People. New methods are developed and validated by toxicologists. The number of toxicologists worldwide is limited, and they often are stretched thin. When countries pass major new chemical safety legislation, such as the EU's REACH law, toxicologists worldwide get overwhelmed with the newly required tests (they are the ones who must interpret the results of those thousands of new tests generated by the new laws). The long-term animal tests in particular are extremely labor- and time-intensive. Any work on alternatives goes on the back burner.

What you can do

Write or call your US representative and urge your representative to co-sponsor and pass the Humane Cosmetics Act (H.R. 2858), which would ban animal testing of cosmetics. We'll see a major shift of industry resources to solve this problem once they can no longer fall back on animal testing. As a former EPA staffer, I can tell you it's well documented that voluntary compliance rarely causes an industry to take action, but when an industry's hand is forced by law, they solve a problem quickly.

Find your representative's phone and email and a sample letter here.




3. Industry's development of unique new ingredients

Besides China, the other major trigger for animal testing now is the development of unique new ingredients. The cosmetics industry is constantly developing new ingredients, which they believe is necessary to stay competitive. The Personal Care Products Council, the naming organization, issues names for about 500-700 new ingredients each year (5).

If a new ingredient is similar to an existing ingredient, its safety often may be determined based on the existing ingredient, with no new animal testing needed. (Existing ingredients probably already had the animal testing, which is why they have safety data.) If the new ingredient is unique, though, and if it may be active within our bodies, then safety tests for long-term toxicity and carcinogenicity may be needed. Today, these are the long-term animal tests mentioned in hurdle 2, for which no alternative methods are yet available.

An industry article posed the dilemma:

"The questions we must face as an industry include: what constitutes adequate and sufficient safety testing for these new entities? Are the in-vitro [non-animal] methods sophisticated enough to stop serious, unexpected adverse reactions and allow a completely new molecule access to the market?" - Robert Ross-Fichtner and Daniel Noble, Focal Point Research, Inc (6)

Industry objects to legislation banning animal testing because they don't believe they can demonstrate the safety of unique new ingredients without long-term animal tests. Industry believes a ban will stifle innovation.

What you can do

Make the decision easy for industry. Write or call a major cosmetics company. Tell them that you are okay if they put innovation on hold for a few years until alternatives are available for the long-term tests. After all, we already have 15,000+ ingredients we can use!

Ask them to pour that ingredient research money into developing alternative methods that predict effects better than animal tests. That would benefit not just animals, but consumer safety.

Here's the contact info for major cosmetics companies and a sample letter.




4. Environmental groups' push for more animal testing

Many environmental groups support animal testing. This may surprise you. It did me. In a nutshell, they consider laboratory animals "purpose bred," and they believe sacrificing them for knowledge is necessary for the greater good of humans and wild animals.

Environmental groups often oppose animal welfare groups trying to minimize or end animal testing. The quote below illustrates typical sentiment. In the quote, Senior Scientist Richard Dennison of the Environmental Defense Fund expresses frustration at animal groups who successfully lobbied to reduce animal testing in the EU's REACH chemical legislation (7).

"In addition to peppering REACH with statements to the effect that animal testing would be done only as a "last resort," the changes forced by animal welfare advocates included elimination of all animal testing for existing chemicals produced below 10 tons per year per manufacturer, and a requirement that only testing proposals, not test data, be submitted at the time of registration for any tests involving laboratory animals. ...

There is, shall we say, a strongly shared interest between the chemical industry and animal welfare advocates in undercutting chemical testing programs." - Richard Dennison, Environmental Defense Fund

For cosmetics, the most active lobbyists for more safety tests, including animal tests, are the Environmental Working Group (EWG) and the Campaign for Safe Cosmetics (CSC), co-founded by EWG to focus on cosmetics. Here is the EWG's statement (CSC has a similar statement on its site):

"EWG supports uses of non-animal testing methods where available and effective. EWG supports research on alternative non-animal health and safety testing. But some studies involving animals are crucial to measuring the safety of chemicals that could harm the environment, wildlife, pets and public health." - Environmental Working Group, FAQs http://www.ewg.org/skindeep/faq/

EWG and CSC's position is similar to industry's position, in that they believe that long-term animal tests are the only way to establish safety today, but there is one big, million animal difference:

  • Industry believes long-term tests are needed for unique new ingredients that could potentially interact with our bodies (for example, nanoparticles and bioactives extracted from botanicals). This is probably fewer than 100 new ingredients each year, with total animal testing of about 10,000-20,000 animals worldwide for such ingredients (depends on tests used). (5)

  • EWG and CSC have proposed long-term animal tests for all ingredients. Their last effort, the proposed Safe Cosmetics and Personal Care Products Act of 2013, would have required these animal-intensive tests for all 15,000+ cosmetics ingredients currently in use, even natural ingredients. The estimate for new animal testing under this proposal was 1.5-11 million animals over 10 years (5). EWG and CSC's 2013 proposal was so extreme in its animal testing that toxicologists who do animal testing told me they considered the proposal unjustifiable, both morally and from a public health standpoint.

EWG and CSC haven't re-introduced their 2013 proposal since those numbers became public. They have instead backed a compromise bill negotiated with industry, called the Personal Care Products Safety Act (Senate bill S. 1014). Sponsored by Senators Dianne Feinstein D-CA and Susan Collins R-ME, this Act:

  • Allows animal testing.
  • Doesn't require non-animal test methods when they are available even if they give equivalent quality information.
  • Has provisions that make it likely that many, and possibly most, ingredients will need a 90-day animal test.

The Act does nothing to promote non-animal methods beyond what is currently done. EWG and others note the Act requires the FDA to "encourage" alternative methods, but the FDA has this mandate already, as a member of an interagency group called ICCVAM.

Over a million animals could lose their lives in the first few years under this bill if the language isn't changed to protect animals.

What you can do

  • Urge your US senators to oppose the Personal Care Products Safety Act (S. 1014). Banning animal testing is the humane choice and the only way to force rapid development of better methods crucial for human safety. Find your senators' contact information and a sample letter here.

  • Contact the Campaign for Safe Cosmetics and EWG, and ask them to support a ban on animal testing:

    - EWG: 1436 U St NW, Washington, DC 20009, 202-667-6982 or 202-667-1638, email EWG.
    - Campaign for Safe Cosmetics c/o Breast Cancer Fund: 1388 Sutter Street, Ste 400 San Francisco, CA 94109-5400, 866-760-8223 or 415-321-2902, info@breastcancerfund.org

    Since their focus is human welfare, you could point out that a ban will force industry to develop the alternative methods crucial for human safety. If you donate to them, you could tell them "no more donations." You may not ever convince them that you are right, but like every other group, they'll listen and change if they are hit in the pocketbook.

  • When you see EWG, CSC, and others promoting the Personal Care Products Safety Act, post a comment that you oppose this Act because it allows animal testing. EWG and CSC have begun a big public relations push to get public support for the Act and are posting about it on Facebook and other social media.

  • Part of their public relations campaign involves getting business support, including your favorite brands. Contact your brands and ask them to oppose the Personal Care Products Safety Act. So far, Badger and Dr Bronner's have signed as supporters of the Act, so please contact them. They likely aren't aware the Act involves animal testing. During EWG and CSC's last effort, in 2013, they signed up many Leaping Bunny brands to support their legislation without telling them that it involved animal testing.




5 Little consumer pressure

Although most people say they are against animal testing of cosmetics, most don't vote that way with their dollars. Probably, most people simply don't think about it when they're buying. If they are asked in a poll, they think about it. Otherwise, it's buried beneath 100 other priorities.

Also, although most people are against animal testing, a significant minority of people do not have empathy with animals and aren't persuaded by animal welfare arguments. It's often people with whom you normally share common views, too, so you can't anticipate it. For example, I was enjoying reading a Sun magazine interview with Joel Salatin, the famed organic guru featured in the book Omnivore and the film Food Inc., until I reached his view on animals:

"Why think animals are more special than carrots? Just because a life-form appears more closely related to humans doesn't mean it's more important than one that doesn't such as a bacterium." - Joel Salatin, The Sun magazine

My sister, who I love dearly, has this view, too, and she's a yoga teacher who has meditated every day of her adult life. So do several other people I admire, despite our strong disagreement on this point. You have probably encountered the same thing among family and friends.

People who lack empathy with animals still identify with human welfare, and alternative methods are critical for that. Without alternative methods, we'll never properly assess the many chemicals in our environment, or the safety of drugs and other products on the market.

What you can do

Talk about it with others, emphasizing animal welfare, human welfare, or both, depending on the person's beliefs. Let your buying power speak. And tell decision-makers that you are making buying decisions based on animal testing; otherwise, they won't know. For example, if you're switching to another brand because of its animal testing policy, call the original brand to explain that you must drop them because of their testing policy, and call the new one to let them know you switched to them because they refuse to allow new animal tests.



 

References

1. Pippin, J., 2013 "Animal research in medical sciences: Seeking a convergence of science, medicine, and animal law." South Texas Law Review, vol. 54:469, p. 498.

2. Mansfield, C., 2015. "Toward a cruelty-free world." AV Magazine, issue 3, 2015.

3. National Research Council, 2007. "Toxicity testing in the twenty-first century: A vision and a strategy." Washington DC, USA: National Academies Press.

4. Taylor, K., 2014. "EU member state government contribution to alternative methods." ALTEX, vol. 31, no. 2, February 2014. For a summary, see "ECEAE criticises EU countries for poor funding of non animal tests for REACH."

5. Knight, J. and C. Rovida, 2014. "Safety evaluations under the proposed US Safe Cosmetics and Personal Care Products Act of 2013: Animal use and cost estimates." ALTEX, vol. 31, no. 2, February 2014.

6. Ross-Fichtner, R. and D. Noble, Focal Point Research, Inc: "Gauging Cosmetic Safety in a Post-Animal Testing World." Cosmetics & Toiletries, February 4, 2016.

7. Dennison, R., 2009. "Talk about over-reaching: Anti-REACH screed gets nearly everything wrong." Environmental Defense Fund blog, August 26, 2009.

8. Frisch, T., 2012. "Sowing Dissent Lunatic Farmer Joel Salatin Digs In." The Sun Magazine, issue 442, October 2012.


About the author: Jean Knight is the owner of White Rabbit Beauty. She is also an environmental consultant, focused on water and hazardous waste projects. Before becoming a consultant, she worked for the US Environmental Protection Agency and private consulting engineering firms. She has a Bachelor's Degree in Civil & Environmental Engineering and a Master's Degree in Civil Engineering with a Water Resources specialty.

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