China Cosmetic Sector and Animal Testing: An Interview with Cruelty Free International and Some Insight From the Analyst (Part 1)

Cruelty free is a both a hugely contentious and polarizing issue for the global cosmetics industry. Despite global trends towards cruelty free, best exemplified by the blanket bans on animal testing of cosmetics imposed in Europe and India, China has remained stanchly opposed to implementing a similar ban. Some forward momentum has been made in recent years with the help of advocacy groups like CFI and other activist groups, which have helped realize development and implementation of alternative to animal testing including quantitative assessment models and new in-vitro testing technologies. Despite this China is still extremely reticent to embark on any path involving either the phase out or ban of animal testing of cosmetics. Animal testing is extremely important for 3 categories of cosmetics in China

1. imported finished product cosmetics
2. all special function cosmetics
3. domestic cosmetics containing novel ingredients (not included in inventory of existing cosmetic ingredients in China).

This basically means is that all cosmetics imported to China as finished products require registration. Sucessful registration is contingent on submission of a registration dossier complete with testing data garnered from completion of various safety/efficacy assessments including animal testing. For international stakeholders that identify as cruelty free, animal testing requirements have been a deal breaker when it comes to consideration of China as a viable market. For others China market entry has required exploitation of various loopholes and workarounds to avoid ethical roadblocks and the costly and time consuming process of regulatory compliance. Either way even the mere association with the Chinese market risks alienating an established ethically minded consumer base and is also another major concern for international stakeholders considering Chinese markets.

Without further ado lets catchup with CFI (almost 5 years after my first interview with them in 2013) and find out what great work they are doing in China to advance the noble goal of cruelty free cosmetics on a global scale.

Q. So for any of our readers that are unfamiliar with your great work can you tell us a little bit about CFI and what you guys do?

A. Cruelty Free International is the leading organization working to end animal experiments worldwide. Educating, challenging and inspiring others across the globe to respect and protect animals we work with decision-makers to make a positive difference for animals in laboratories and champion better science and cruelty free living.

We currently head up the largest global campaign dedicated to ending the use of animals to test cosmetics throughout the world. Our dedicated team of experts has made real progress around the globe for animals suffering in cruel tests for cosmetics.

We do this by lobbying politicians and governments to ban the use of animals in cosmetics testing, encouraging regulators to accept non-animal tests, mobilizing compassionate citizens through high profile campaigns and encouraging companies to go cruelty free with the Leaping Bunny certification.

At a legislative and regulatory level, cruelty free trends and laws on animal testing of cosmetics have gained considerable momentum over the last several years. At Chemlinked we have reported on animal testing bans (or proposed bans) in India, Korea, Australia, Taiwan and obviously Europe (will mention complete list with hyperlink to news). What other progress have we missed and is industry following the lead of the more ethically minded governments?

The completion in 2013 of the phased landmark EU bans on testing and marketing was a pivotal moment for animals in laboratories. It set in motion a global trend that inspired many other countries to adopt similar legislation. Countries around the world are making progress to end cosmetics animal testing. Israel, India, New Zealand, Taiwan, Switzerland, Iceland, Serbia and Guatemala have ended testing. Turkey and South Korea have partial legislation in place and bans are currently under consideration by parliaments in Canada, Brazil and Australia. States like Sao Paulo in Brazil and Virginia in the USA have also ended the practice.

Largely driven by the EU’s 2013 deadline and regulatory changes occurring in other parts of the world, research into technologies that replace animal testing by the cosmetics industry and governments has been stepped up. As a result, there are now alternatives for the most commonly required safety tests for cosmetics and many of these are now recognized internationally. For tests where alternatives are not recognized internationally, further animal tests can still be avoided depending on the type of ingredient and its intended use.

What about at the consumer level? Are cruelty free trends shaping demand? 

Millions of consumer-citizens around the world are already choosing to use their purchasing power for sustainability, buying products that aren’t tested on animals as part of the sustainable lifestyles they want to live. For example, 56% of US consumers have stopped buying products from a brand or retailer if they believe they are unethical (Mintel); 29% of Brazilians prefer to buy from companies with sustainable practices (Mintel), and half of Chinese consumers are willing to pay a premium of up to 10% for sustainable products (UNEP).

 In 2015 a Nielsen survey found that “not tested on animals” mattered more to consumers than any other packaging claim. To date, nearly seven million people have also signed our joint petition with The Body Shop for a global ban on animal testing in cosmetics. The demand for the Leaping Bunny, along with the popularity of cruelty free cosmetics, demonstrates growing public awareness about animal suffering in the beauty industry and an expanding consumer market for ethical products.

Businesses now need to respond to consumer demand for more sustainable approaches by innovating at all stages of the production process and by including a commitment to no animal testing in their sustainable business policies. It’s not only the right thing to do, it also makes business sense. For example, in the case of animal testing, product testing innovations mean that there are no longer any human safety reasons that can arguably be used to justify testing cosmetics on animals. Businesses can also use their voice and influence to engage governments and their various channels, including point of sale, to inform and mobilize consumer action.

One glaring omission from the list of countries which have banned or are working towards a ban on animal testing of cosmetics is China. Progress has been made in this respect here in China with the development and implementation of alternatives to animal testing methods during cosmetic registration but overall it seems insignificant given the sheer size of China’s industry….until now. According to our sources it seems CFI has made a significant breakthrough in this respect opening the way for more ethically minded international cosmetic enterprise to consider China’s markets, can you give our readers details of this new development ?

In June, we launched a ground-breaking pilot project which will – in the first instance – enable selected cruelty free brands to access the Chinese market. A result of a unique collaboration between Cruelty Free International, Knudsen&Co and Fengpu Industrial Park, the pilot aims to remove the remaining barriers for cruelty free cosmetics brands wishing to sell in China and could pave the way for international cosmetics brands that don’t test on animals to enter the Chinese market.

The scheme will enable a selection of brands to work with Cruelty Free International and Knudsen&Co to access the market through domestic production, avoiding the risk of post-market testing and ensuring that filing takes place without animal testing.  

We are presently inviting companies to hear more about the pilot and discuss the possibility of joining. Brands will be chosen according to capacity and willingness. We will then work with our partners throughout the chain to ensure the chosen companies can enter the market cruelty free.

I’ve seen the CFI logos in The Body Shop, at an industry level what company’s do you guys feel exemplify the ethics in cosmetics principle and do you have any advice for Chinese companies that want to follow these principles?

Hundreds of cosmetics, personal care and cleaning brands are certified cruelty free under our Leaping Bunny program - the globally recognized guarantee that a brand has made a genuine commitment to ending animal testing for its products.

All certified companies must meet our rigorous criteria, including independent audits, before we let them display the Leaping Bunny logo.

So what’s next for CFI in China and at a global level?

We have met with companies at events held in Shanghai and London to discuss our pilot scheme in more detail and gauge interest in joining the program. A further announcement will be made later in the year.

Once rolled out, we will review the pilot and make recommendations for the future based on the results as part of our efforts to remove any remaining barriers to the market.

With this project we recognize that, as in the EU and the rest of the world, change does not happen overnight, but it is worth doing all we can to achieve progress. The government of China is making progress in the adoption of non-animal alternative tests and is open to cooperation with us to take further steps.

Globally, we are continuing our campaign with The Body Shop for an international end to cosmetics animal testing through the United Nations.