Does China Still Test Cosmetics On Animals?
One major barrier to realizing a cruelty-free cosmetics market is the requirement for imported cosmetics to be tested on animals to allow their sale in China. Frequent news articles indicate that policies are changing, but it is difficult keep the reports straight—partly because there is still some uncertainty about how recently announced regulations will be applied in practice.
Is animal testing of imported cosmetic products into China about to end?
Following the publication of the Cosmetics Supervision and Administration Regulation (CSAR) in June 2020, a series of supporting regulations have been issued, included the Safety and Technical Standards for Cosmetics (STSC). Through STSC and other guidance documents, the Chinese government has leveled the playing field for regular cosmetics regarding animal testing.
As of May 1, 2021, companies can sell regular cosmetics in China without animal testing whether they are produced in China or imported from abroad. But can cosmetic companies take advantage of this opportunity in the short term? For some, the answer may be “no”.
The STSC allows for the filing of imported regular cosmetics with safety tests that do not rely on animals. In other words, “alternative” (non-animal) test methods may be used. Safety will be established by assessing individual ingredients in a cosmetic formulation—similar to information submitted to the European Union for registration. Therefore, this requirement should be relatively easy for companies to achieve.
However, another requirement of the regulations will be difficult for companies to achieve—especially in the short term. A cosmetic company must submit a certificate of Good Manufacturing Practices (GMP) issued by the governmental authority from the country in which the cosmetic was manufactured, as the Chinese government wants to ensure that the manufacturing of the cosmetic is up to high-quality standards. Why is this a problem? In most countries, these types of certificates are issued by third party agencies, not by the government. However, the Chinese government inspects and issues certificates of quality to manufacturing sites in China, and they expect something equivalent for imported products.
A final uncertainty is that it appears that new cosmetics ingredients may not be able to sold without animal testing.
What will happen next?
Each company will have to determine if the countries in which they manufacture will issue GMP certificates from the government. Progress has been made in France and Poland, while the United Kingdom expects to have this ability by May 1. However, for many countries it remains unclear whether or when their governments will make these certificates available.
What are organizations doing to make progress?
Organizations like the Institute for In Vitro Sciences collaborate with the National Institute for Food and Drug Control (NIFDC) to accept alternative test methods and write them into the STSC. IIVS will also help China utilize these methods for functional products (e.g. hair dyes and sunscreens) which still require animal testing to establish safety.
Other organizations are pushing for China to participate in international harmonization projects and encouraging governments to issue GMP certificates to facilitate marketing of more cosmetics without animal testing as soon as possible.
While the recent changes don’t mean a cruelty-free cosmetics world is here yet, they do mean that international pressure is working.
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Erin Hill is a co-founder and president of the Institute for In Vitro Sciences where she is responsible for planning, directing, and coordinating activities to achieve IIVS’ mission of increasing the use and acceptance of in vitro methods worldwide. She actively engages with industry, animal protection organizations, and regulatory agencies, both domestic and international, to help coordinate efforts for the advancement of non-animal testing methods.
Kristie Sullivan, M.P.H. is the Vice President of Research Policy with the Physicians Committee for Responsible Medicine, where she directs efforts to implement human-relevant alternatives to the use of animals in medical research, education, and the testing of drugs, chemicals, and other regulated products. She has presented and conducted trainings on alternatives to animal tests to industry and government scientists, lobbied for state and federal legislation to replace animal testing, and served on federal committees advising federal and international agencies including the US Environmental Protection Agency, on topics related to the implementation of in vitro and in silico methods for regulatory chemical safety assessment. She received her Master of Public Health in Toxicology from the University of Michigan.
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