Animal testing labelling

Can you trust a cosmetic company's claims that its products aren't tested on animals? If it sells them in China, possibly not.
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01 .Testing cosmetics on animals


In an attempt to differentiate their products from the competition, companies may proclaim that their products aren't tested on animals. But all is not as it seems.

In this report, you'll find:

    China's stance on cosmetics testing

    China’s increasing wealth has seen a rise in consumers with a growing disposable income, and a sizeable chunk of that money is being spent on cosmetics. Additionally, recent economic downturns and consumer belt-tightening in the west, coupled with reduced tariffs and taxes associated with selling cosmetics in China, have proven a tempting combination for cosmetic and personal care brands.

    "All cosmetic products sold in China must be registered with the authorities," explains Dr Alain Khaiat, president of the Cosmetic, Toiletry and Fragrance Association of Singapore, vice president of Scientific Affairs of the ASEAN Cosmetic Association and CEO of SEERS Consulting, a consultancy for manufacturers of personal care products. “In order to become registered, companies are required to submit a dossier to the relevant government authority, along with product samples for the authority to test. The authorities then do a number of tests, including for pH [levels] and viscosity. They also do some skin and eye irritation tests. And at the moment, these tests are done on animals.”

    So samples of products that are currently sold in China must, by law, be provided for animal testing by cosmetic companies.

    Video: Animal testing for cosmetics

    We take a close look at some confusing and sometimes misleading labelling practices when it comes to animal testing in the cosmetics world.


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    Products that have the potential to cause harm to humans, including personal care products, cosmetics and medication, must undergo safety testing in order to ensure they're relatively safe to use. Regulations requiring safety testing are important – without them, there's no way of ensuring products on the market aren’t going to cause serious harm (and even with safety testing, problems can occur). “You don’t want to buy a product that’s meant to enhance your beauty, and instead get a skin abrasion or a disease,” says Khaiat. “Cosmetics must be safe for their intended foreseeable use.”

    And the intended use isn’t always the same as the foreseeable one, as Khaiat points out. Shampoos, for example, aren’t meant for use in the eyes, but the chance of accidental eye exposure is high. So shampoos are tested to ensure they're safe for ocular contact.

    While there are many methods for testing ingredients for safety, including in vitro (test tube) tests on skin cells and donated corneas, these are relatively new scientific advances. For decades, the proverbial “guinea pigs” were, in fact, guinea pigs, as well as rats, mice and rabbits.

    Draize tests

    The methods currently used to test products in China are, according to Khaiat, variations of the Draize eye test, which involves applying the test substance to a rabbit’s eye and evaluating the damage caused. Irritation is assessed from tears, redness or swelling. The Draize skin irritation test involves shaving a patch on a rabbit’s back and applying the ingredient to be tested. The skin is then checked for irritation for up to three days.

    But questions have been raised about the reliability of animal testing. “I did a study in the late 1980s comparing the data I had on animals to the data I had on humans, and found there was a less than 50% correlation,” says Khaiat. “I switched to in vitro methods [involving human cells in test tubes] and found an 85% correlation between in vitro and human results. Animal testing is not reliable, and it is not humane to treat animals this way.”

    While alternative methods have been developed for most animal tests, including the Draize tests, there are still a small number with no alternative. However, this isn't necessarily a barrier. In justifying its wholesale ban on animal testing, the EU issued statements saying companies should either use alternative ingredients that have already undergone all necessary safety tests, or develop new methods of testing. 

    CHOICE believes information should be available so those who want to choose products which aren’t tested on animals can do so.

    Many consumers are strongly opposed to animal testing and CHOICE believes information should be available so those who want to choose products which aren’t tested on animals can do so.

    Unfortunately, our market survey found consumers’ ability to make informed decisions is being jeopardised by confusing claims, such as "against animal testing".

    Companies selling cosmetics in China knowingly provide samples for animal testing. In defending its position, Avon claims its “commitment is to remain in the countries affected and work to bring about change, such as the acceptance of non-animal testing methods. Abandoning a market does not help bring about a solution.”

    L’Occitane also talks up its fight against animal testing, but then admits: "The Company’s products are sold globally and, along with many other global businesses, China is an essential market for its development. L’Occitane respects the right of each country to set their own laws and regulations; it actively seeks to influence the debate on abolishing tests on animals throughout the world and anticipates an end to animal testing in China."

    On Bobbi Brown’s website list of FAQs, the very first question is “does your company test on animals?” The answer? A firm “no”. “Bobbi Brown is committed to the elimination of animal testing.” Except that this is followed by: “We do not conduct animal testing on our products or ingredients, nor ask others to test on our behalf, except when required by law.”

    Some cosmetic companies, such as The Body Shop, Lush Cosmetics and Paul Mitchell, have chosen not sell their products in China. They recognise that selling in prosperous markets that require animal testing is inconsistent with their stance against animal testing.

    Complicating matters is the growing appetite of cosmetic behemoths L’Oréal and Estée Lauder. L’Oréal is the parent company of Lancôme, Giorgio Armani Beauty, Biotherm, Kiehl’s, Shu Uemura, Urban Decay, Garnier, Maybelline, Kerastase, Redken, Vichy, The Body Shop and many others. Meanwhile, Estée Lauder is the parent company of Clinique, MAC, Bobbi Brown, La Mer, Smashbox, Aveda, Prescriptives, Origins and others.

    What information do cosmetic counter staff give about animal testing?

    CHOICE sent a shadow shopper, Amy (not her real name), to Myer and David Jones stores in Sydney. Amy approached the cosmetics counters of brands including Clinique, Clarins, Bobbi Brown, Benefit, Lancôme, SK II, Shiseido, Chanel, Dior, and M.A.C, all of which sell cosmetics in China, according to the Hong-Kong-based Li & Fung Research Centre and CHOICE’s own research.

    Amy asked sales assistants whether their products were tested on animals. If the response was no, she asked them about whether the product had to be tested on animals in China.

    The sales assistant at the Clinique counter was aware of the Chinese legislation, and, while she wasn’t spot-on about the application of the law, proactively warned our shadow shopper about it.

    In contrast, when our shopper asked the sales assistants at the Clarins counter about the animal testing legislation in China, she was told it didn’t exist. “Internationally it’s illegal to test on animals, because animal rights is so big now,” she was told. “Other countries really don’t have a right to say that [animal testing is compulsory]”. Wrong on all counts.

    At Benefit and Bobbi Brown, our shopper was told the products weren’t tested on animals, but upon probing further was referred to the head office for more information. SK II, Lancôme, Chanel, Dior and M.A.C sales assistants all claimed their products weren’t tested on animals, but were unsure about the existence of the Chinese legislation.

    What companies say on their websites

    CHOICE also looked at the websites of 55 brands of cosmetics, from specialty products to supermarket cheapies. Of these, 22 made claims either on their own websites or on those of their parent company about their products not being tested on animals, but only a minority were certified. Estée Lauder, the parent company of several of the brands now sold in China including Bobbi Brown and Smashbox, states on its website that “Our longstanding commitment to end animal testing has not changed: we do not test our products or ingredients on animals, nor do we ask others to test on our behalf, except where required by law”.

    According to Giorgio Armani’s website, “Giorgio Armani does not use animals to test its products, and does not have animal testing conducted on its behalf by anyone else.” The brand is in the Chinese market and is on PETA’s list of companies that do test on animals.

    A CHOICE shopper also went to supermarkets, department stores and chemists and purchased 32 products with labels making claims about animal testing. The claims on the products varied, from the seemingly unequivocal “products and ingredients not tested on animals”, “never tested on animals”, and “cruelty-free vegan”, to the slightly more ambiguous “not tested on animals” and “cruelty-free”, and the potentially questionable “against animal testing”, “finished product not tested on animals” and “tested on us”.

    What the packaging claims

    Of the 32 products, nine carried a logo that signified certification by a third party. When we checked to confirm the origins of the logos and the credentials of the companies using them, we found mixed results.

    DermaVeen, Invisible Zinc and Natural Instinct products all carried a logo that was not from a third party certifier, although featured similar imagery. We could not confirm the origins of the Grace Cole Co and Olivella logos. An additional product made by Australian company Original Source carried a logo that did not appear to be official.

    Only the Nature’s Organics, Trishave and Innoxa products were certified by a third party, Choose Cruelty Free, as not tested on animals.

    There are several independent third parties that certify products as having not been tested on animals, including Choose Cruelty Free, the Leaping Bunny, and PETA. All three organisations compile lists of companies that sign statutory declarations promising they do not test, nor do they allow others to test on their behalf, any products or ingredients on animals. These bodies do not certify companies that sell their products in markets where animal testing is required.

    However, it is important to note that in some cases, even companies which abstain from the Chinese market may be penalised by the certifiers on the basis of their parent company’s stance on animal testing. And not all logos are created equal; just because they’ve put a bunny on it, doesn’t make it “cruelty free”.



    These lists are compiled from PETA's lists of companies that do and do not test, the Leaping Bunny and CCF, as of March and April 2013. If you can't find a brand here, head to the certifiers' websites for a more complete list.

    Certified companies/brands that do not test on animals

    • Aesop
    • AHAVA
    • Akin
    • Alchemy
    • Argan Life
    • Aussie Mineral Makeup
    • Australian Pure
    • Australis
    • Aveda
    • Ayana Organics
    • Bare Escentuals
    • Bon Ami
    • Burt's Bees
    • Catwalk
    • D. Adair Cosmetics
    • De Lorenzo
    • Dermalogica
    • Eco Minerals
    • Eleven Australia
    • e.l.f cosmetics
    • Enzoskin
    • Face of Australia
    • Flurifresh
    • Forever New International
    • Gaia Skin Naturals
    • Innoxa
    • Jason
    • Larissa Bright
    • Lush
    • Natio 
    • Nature's Organics
    • New Directions
    • Paul Mitchell
    • Rusk
    • Smashbox
    • Stila Cosmetics
    • Suki
    • The Body Shop
    • The Cruelty Free Shop
    • Too Faced Cosmetics
    • Trilogy
    • Tri-Shave
    • Tropez
    • Zara

    PETA's list of companies/brands that do test on animals

    • Almay
    • Aveeno
    • Avon
    • Biotherm
    • Bobbi Brown
    • Bumble and Bumble
    • Carefree
    • Chapstick
    • Clairol
    • Clean & Clear
    • Clearasil
    • Clinique
    • DDF
    • Donna Karan
    • Dove
    • Elizabeth Arden
    • Estée Lauder
    • Garnier
    • Giorgio Armani
    • Head & Shoulders
    • Helena Rubinstein
    • Herbal Essences
    • Jurlique
    • Kerastase
    • Kiehl's
    • La Mer
    • L'Oréal
    • L'Occitane
    • Lancome
    • M.A.C Cosmetics
    • Mary Kay
    • Max Factor
    • Maybelline
    • Michael Kors
    • Missoni
    • Mitchum Deodorant
    • Nair
    • Neutrogena
    • Nice 'n Easy
    • Nu Skin International
    • Olay
    • Old Spice
    • Pantene
    • Ponds
    • Purell
    • Revlon
    • Redken
    • Shiseido
    • Shu Uemura
    • SK-II
    • Sunsilk
    • Unilever
    • Vichy
    • Veet
    • Vidal Sasson

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