While China’s cosmetics industry has been booming for many years, the regulatory oversight of these products has lagged behind.
China’s efforts to improve the quality of manufacturing and production of cosmetics in China has led to the updating of its major regulation: the Cosmetics Supervision and Administration Regulation, commonly referred to as CSAR. Issued at the end of June, CSAR will go into effect in January of 2021. CSAR sets forth many important changes, including a shift in responsibility for quality—from the government to the manufacturer.
It doesn’t, however, deal with the issue on the mind of many people—animal testing.
To understand animal testing in China, you first need to understand how they view different types of cosmetics. The Chinese system has two main cosmetic categories—regular and functional.
Regular cosmetics are the various products used every day, such as shampoos, lotions, and color cosmetics.
Functional cosmetics are those products that provide an effect—such as hair coloring, hair removal and sunscreens, and skin whitening.
Currently, all functional products are tested on animals. Regular cosmetics are handled differently, depending on whether they are manufactured in China or if they are imported.
When manufactured in China, the animal testing requirement can be waived.
But for now, all imported regular cosmetics go through a registration process, which includes animal testing.
Why does China still test on animals?
At one time, all countries tested cosmetics on animals. For many reasons (ethics, scientific, legislative), companies and countries greatly reduced their reliance on animal testing and shifted to using non-animal methods. China is behind the curve but is now putting in major efforts to update and modernize its regulations to include non-animal tests.
How long will they continue to test on animals?
This is a difficult question to answer. If the law is changed such that regular imported cosmetics are treated the same as domestically produced products, there will be a huge reduction in animal use. However, China is conservative and may keep animal testing of functional products and new ingredients for quite some time.
Why are imported and domestically produced regular cosmetics treated differently?
Although CSAR requires cosmetic companies to take more responsibility for the quality and safety of their products, the government is still highly involved. The Chinese government actually inspects manufacturing facilities and issues the certificate of manufacturing quality to the company. It is much more difficult—maybe even impossible—for the Chinese government to inspect manufacturing facilities in other parts of the world. Therefore, they want imported products tested before they are put on the market. And the tests they rely on right now include animals.
What does the Institute for In Vitro Sciences do in China?
IIVS works in collaboration with Chinese regulators to provide education and training in non-animal methods. This includes building the capacity of non-animal tests in Chinese laboratories, educating regulators on how to interpret information from these new tests, and reaching out to young scientists at universities.
What can we expect next?
In the coming weeks, sub-regulations will be issued which will lay out testing requirements in detail. If importers can provide China with an assurance of manufacturing quality that meets their needs, then they may be able to avoid animal testing. Importers will also need to provide the safety tests that China wants to see utilizing specific tests contained in the regulations. Both of these may be difficult for companies to do in the short-term.
Kinder Beauty thanks PCRM and IIVS for their work on the frontlines of ending cruel cosmetic animal testing, and for putting together this eye-opening article on the current state of cosmetic animal testing in China. Kinder Beauty is a vegan, cruelty-free beauty subscription box and is dedicated to doing our part to mainstream ethical alternatives—no animal needs to suffer for our good looks! We also will work hard to stay on top of the latest news impacting cosmetic animal testing, in China and beyond.
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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.