Animal Testing in Chinese Cosmetics
Because of increasing cosmetic usage—especially in Eastern countries like China, many nations now mandate animal testing to ensure safety before the product moves to the market. China’s development of detailed regulations on animal testing in cosmetics shows how legislation and public opinion on animal testing have evolved in recent years. There are different nuanced definitions of the term “cosmetics,” though most countries agree that it describes a chemical product applied to the body. Specifically, China’s definition considers how the product is used, what body part it is used on, and what the product does.
A Comparison of Cosmetics and Non-Cosmetics
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Cosmetics: Spreading, spraying, or rubbing
Non-cosmetics: oral administration or injection
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Cosmetics: external parts of the human body (skin, hair, nails, lips)
Non-cosmetics: teeth or oral mucosa
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Cosmetics: skincare, to keep the body clean, to improve appearance and beauty
Non-cosmetics: Prevent and treat diseases
Though many countries implemented animal testing for human safety, some scientists and activists advocate against it for both practical and ethical reasons. One of the major practical issues is that animal models are imperfect and do not accurately reflect the product’s effect on humans. Additionally, some disapprove of the harm that cosmetic testing can cause to the animals. For example, animal welfare activists have and are continuing to push for the banning of methods such as the Lethal Dose 50 test, a test done on at least 100 animals per trial to find the amount of product needed to kill an animal—even though it is barely relevant to a product’s safety for humans. The test can not accurately predict a product’s effects on humans and is ineffective in determining long-term toxicity. Because of these reasons, China and many other countries that previously required such tests began to ban them.
China’s journey in developing animal testing regulations in cosmetics is an important example of progress in animal welfare movements. In 2007, the Ministry of Health updated its Hygienic Standards for Cosmetics policy to require seventeen toxicological tests. In 2016, the Chinese State Food and Drug Administration found an alternative method to animal testing known as the 3T3 NRU Phototoxicity Assay, a test that determines the effects of light exposure on mammalian cell cultures rather than live animals. Implemented for the first time in China’s revision of the Safety and Technical Standards for Cosmetics, this new test provided a more accurate assessment of a product’s safety for human use.
For further context on China’s animal testing policies, China separates cosmetics into “general” and “special” categories, each with separate requirements. Both categories require a complicated registration process for imported cosmetics. First, companies must acquire government approval through inspection, application, and technical assessment. Then, companies need a legal representative company in China to control their registration process. Cosmetics with ingredients not used in China must undergo animal testing for approval.
Different factors including backlash from scientists and activists and economic pressure in the international cosmetics market encouraged China to shift away from animal testing. In 2014, China replaced animal testing requirements with a safety risk assessment for domestic general cosmetics. In 2018, the Leaping Bunny China Qualification Program allowed foreign companies to maintain a cruelty-free status while selling products in China. Most recently in May 2021, China published the Provisions for Management of Cosmetic Registration and Notification Dossiers and Provisions for Management of New Cosmetic Ingredient Registration and Notification Dossiers. These new rules standardized the registration process for new products and ingredients and exempted previous animal testing requirements for imported general cosmetics.
The growth of China’s cosmetics animal testing policies from mandatory and controversial animal toxicology tests to alternative safety tests and collaborative policies shows the important progress made in animal welfare policies. China’s shift from animal testing requirements to alternatives marks a promising step toward a cruelty-free world, serving as a strong role model for other countries.