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Senator Booker: Amend the Humane Cosmetics Act to keep out EU animal tests
The Humane Cosmetics Act would ban animal tests for cosmetic ingredients in the US; however, it exempts animal tests done for foreign governments. With the EU asking for new animal tests for many cosmetic ingredients, this exemption must go.
Here's the letter I sent Senator Cory Booker, who is the lead sponsor of the Humane Cosmetics Act in the US Senate. Write your own note to Senator Booker at www.booker.senate.gov.
May 4, 2022
Dear Senator Booker,
I deeply appreciate your sponsorship of the Humane Cosmetics Act of 2021, which has the strong statement of intent to "substantially restrict the use of animal testing for cosmetics". As someone who witnessed laboratory testing of animals during my undergraduate years, I know first-hand the horrors of this practice.
The Act includes two exemptions, however, that will make the Act ineffective: Section 2(d)(1) exempts tests "conducted outside the United States in order to comply with a requirement from a foreign regulatory authority" and section 2(d)(4) exempts tests for "non-cosmetic purposes pursuant to a requirement of a Federal, State, or foreign regulatory authority."
The key problem for both exemptions is the European Union's REACH regulation, which requires evaluation of all chemicals manufactured or imported into the EU in quantities of 1 or more tons/year. REACH includes specific animal test requirements for chemicals in quantities of 10 or more tons/year, with no exceptions for cosmetic ingredients, even ingredients used exclusively for cosmetics.
An October 2021 peer-reviewed paper, of which I am a co-author, identified the extent of the REACH animal testing to date on cosmetic-exclusive ingredients: 63 cosmetic-exclusive ingredients have undergone animal tests for REACH so far, with more expected. Some are common ingredients found in many personal care products. You can view that paper here: https://www.altex.org/index.php/altex/article/view/2291.
In speaking with industry experts, including Unilever's Head of Safety and Environmental Assurance Centre, and Clariant Corporation's Head of Global Toxicology and Ecotoxicology (who is also a co-author of the paper), there is serious industry concern that most cosmetic ingredients will be tested on animals for REACH. Chemical registrants report that ECHA, the regulatory body implementing REACH, is often rejecting their alternative approaches and requiring new animal tests.
I urge you to amend the Humane Cosmetics Act to remove exemptions for tests conducted for a foreign regulatory authority. Unless the US takes a stand against the EU's cosmetic ingredient testing under REACH, then the Humane Cosmetics Act will be symbolic only. By taking a stand, the US can help move the EU to change its current regulatory environment favoring animal tests over accepted alternatives and make the Humane Cosmetics Act a real path forward to substantially restrict the use of animal testing for cosmetics.
With best regards,
Jean Knight
Environmental Engineer, retired
Half Moon Bay, California
Related Articles
The EU is testing cosmetic ingredients on animals Despite the EU's ban on animal testing of cosmetics, the EU has been imposing such tests under its REACH regulation.
7 States Ban Animal Testing of Cosmetics And more states have introduced legislation. Learn what the bans do and what they exempt.
3 Easy Actions to Help End Animal Testing These simple actions will add up to big change if we all do them.
Cosmetics Testing Today Most ingredients are no longer tested on animals, but animals are still losing their lives for "innovation."
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