Dr Emma Meredith, Director-General of the CTPA, says: “CTPA fully and wholeheartedly supports the ban on animal testing of cosmetic products and their ingredients in the UK. We stand with the cosmetics industry and our consumers against the use of animal testing to support the safety of cosmetic and personal care products.”
Recent media reports suggest the UK is set to allow animal testing for some cosmetic ingredients. This has caused a great deal of alarm and concern. However, CTPA understands this is not the intention of UK authorities.
CTPA has sought reassurance from the Home Office, and a Government spokesperson has confirmed: “There has been no change in our legislation and the ban on using animals for the testing of finished cosmetic products remains in force.”
Strict UK and EU bans
The UK cosmetics industry voluntarily stopped animal testing on cosmetic products around a decade before the ban was introduced across Europe. CTPA and its members promoted and supported the introduction of the European Union ban on animal testing of cosmetic products and their ingredients. During the preparations for the UK’s exit from the EU, one of CTPA’s key priorities was to ensure that the new cosmetics legal framework in the UK did not weaken the strict animal testing ban that we already had in place. CTPA has a programme in place to support its members in demonstrating the safety of cosmetic products using novel and proven scientific methods that do not involve the use of animals.
Industry is not looking for loopholes
Much of the media commentary has focussed on the two main laws which cover cosmetic products and ingredients: the Cosmetics Regulation and the chemicals legislation, REACH (Registration, Evaluation and Authorisation of Chemicals). Rulings by the European Chemicals Agency (ECHA) regarding parts of REACH are also referenced. CTPA explained, when the rulings were published in 2020, that the ECHA rulings have not changed anything about the stringent ban on animal testing of cosmetic ingredients and products in the UK and EU. These strict bans still apply in the UK and Europe, and this is the case whether or not the product makes a ‘not tested on animals’ or ‘cruelty-free' claim.
The UK Cosmetics Regulation is clear in specifying that in order to meet its requirements cosmetic products may not be placed on the UK market if the final formulation, ingredients in a final formulation or a finished product have been subject to animal testing if the purpose of the tests was compliance with the UK cosmetics laws, no matter where such tests took place.
There are no loopholes and the cosmetics industry is not seeking to circumvent these important bans.
Regulatory dilemmas
The challenges presented by the different regulatory frameworks are also discussed in a recent report in ALTEX, the journal on Alternatives to Animal Experimentation. The ALTEX report concludes:
“The conflict between REACH and the Cosmetic Regulation poses a serious dilemma for all segments of the cosmetic industry: for ingredient manufacturers, as they can be legally required under REACH to conduct in vivo tests on their ingredients, but the cosmetic market may reject ingredients with such tests; for cosmetic brands, as they cannot easily identify REACH testing of ingredients in their supply chain, but if such testing is identified, a brand risks backlash from consumers if it continues to use the ingredient, but finding an alternative can be difficult and costly; and for consumers, as they can no longer have confidence that the EU cosmetic products they purchase were not tested on animals. Greater transparency on the post-ban in vivo testing and an engaged effort by stakeholders to resolve the conflict would support the cosmetic industry’s effort to be free of animal testing and help retain consumer confidence in their products.”
Pioneering science
The cosmetics industry is a global pioneer in research into alternative methods that do not use animals and is proud of its investment and success in developing alternatives to ensure human safety. The industry has a long-standing commitment to the replacement of animal testing and plays a leading role in the development of alternatives by dedicating funding, time, resources and scientific expertise to this area of research.
Thanks to this enormous contribution, the cosmetics industry is a leader in this field and has had a dedicated strategy for new testing methods for over 25 years. The cosmetics industry and CTPA work together with animal charities, academics, authorities and regulators globally to promote these methods internationally to work towards an end to animal testing in all sectors.
