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The Beauty Industry’s Ugly Secret: The Changing Prevalence of Animal Testing in the Cosmetics Industry

Public outrage in response to increased awareness of animal welfare issues worldwide has led to a tightening of the already restrictive legislative framework surrounding use of animal testing in a number of industries. This article examines the changing attitudes of public bodies to animal testing in recent years with a particular focus on the future health and safety testing mechanisms in the beauty and cosmetics industry.

Rachael Jane Ruth is a 4th year LLB student.


It is just like man’s vanity and impertinence to call an animal dumb because it is dumb to his dull perceptions.’ – Mark Twain

  Animals have long been sent to the frontline of products-testing in the pharmaceutical industry. The healing properties of the medicines in question are directed towards the prolonging of human life through the treatment of human illness, disease and injury. If medicines went untested, could we really risk the loss of life should we attempt to treat the ill in our society with potentially dangerous drugs? This is a dichotomy which has, and will continue to exist for years to come.

 Worth 72 billion Euros in the European Union[1], the beauty industry, unlike its pharmaceutical counterpart, has never been upfront about the violations of animal health which occur for human benefit. These breaches of sanctity, however, do not occur to potentially save and improve human lives. Drugs testing on animal subjects, although undoubtedly cruel, appears to be ethically justifiable by achievement of the end result that if a medicinal product cures an animal of a certain disease, then the likely effects on humans will be of similar benefit. By comparison, when an animal subject is tested upon for the production of a cosmetics product, regardless of the effect on the animal itself, the end goal is creation of a lipstick or perfume which creates a pleasing impression of the wearer. There is no health benefit to the human consumer of the product. No human life is prolonged. The animals, on the contrary, may experience side-effects ranging from discolouration of fur to blindness, all in pursuit of an aesthetically-pleasing cosmetics product. A Eurobarometer survey carried out in 2005 indicated that the purpose of the testing is integral to the acceptability of the test itself: the majority (66%) of those surveyed agreed that scientists should be allowed to do research on animals, for the purposes of advancement of human health only[2]. The logic seems to point to an obvious answer when laid out in plain terms: we as a society should no longer use products which have been tested on animals, and in turn manufacturers should cease all animal testing - of cosmetics, at the very least – and find a humane alternative.

Legislative History of Cosmetics Animal Testing in Europe and the UK

  This argument is just the tip of an ever-growing campaign which is still ongoing to bring a worldwide end to cosmetics cruelty, and is one which arguably flourished firstly in Britain. New Labour, under the ambitious Tony Blair, implemented the industry-wide ban on cosmetic animal testing in 1997[3] in response to growing public outrage as 1990s Britain became aware that certain animals such as mice and rabbits faced a future of cruelty and chemicals. This industry-wide ban put a full halt to all granting of licenses for the experimentation on animals for cosmetic purposes – a major breakthrough for animal welfare campaigners and moral voters alike. However, a loophole soon emerged in the law: finalised products were completely impermissible for testing on animals, but the ingredients which comprised the finished cosmetic were individually testable. This exploitation of the shaky legal framework under which animals were protected soon became a driving influence for those across the UK, and later Europe, who objected to cruel industry practices. The Animal (Scientific Procedures) Act 1986 and amendments have since rigidified the legislative framework governing animal research and has been described as ‘the tightest system of regulation in the world’[4].

  By the later 2000s the European Union had become concerned with the impact of animal testing for cosmetics purposes. The knowledge of this practice becoming increasingly more public, society demanded that a firm legislative step be taken to prevent ongoing and discourage future ‘cosmetics cruelty’ to animals. Those within the industry feared for the economic consequences of introducing a ban on cosmetic animal testing, as the viability of non-animal alternatives had not been considered in great depth by the EU market until this point in time. The Impact Assessment on the Animal Testing Provisions in Cosmetics Regulation[5] produced some disturbing results. Due to the surge in EU Member States having implemented their own anti-animal testing legislation in preceding years, the Impact Assessment estimates that almost entirely animal testing for cosmetics sold and created within the EU had already moved outside of the EU by the time of the report, and therefore largely the animals spared would be overseas. Reports under the Cosmetics Regulation from 2009 suggested that the number of animals used for cosmetic purposes was almost 9000 in 2004, including rats, mice and rabbits, but the number of animals on which cosmetics were tested worldwide reached over 26,000 in 2005[6] . One year later, 84% of respondents to a 2010 Eurobarometer poll stated that they desired new EU legislation preventing the suffering or pain of animals on which any tests are carried out[7] - the wish to protect animals had not changed. However, the Impact Assessment also found data clarifying that around 90% of the ingredients used in cosmetics testing are used in other areas additionally, and so the purpose for which an animal is subject to experimentation may not be as clear as initially believed. Morality, in the absence of certainty of data from either lobby, won out.

  The Cosmetics Directive[8] was implemented in July 2013, replacing the Cosmetics Regulation from 2009, and established a legislative framework for phasing out the testing of products and ingredients for cosmetics purposes on animals. Significant features of the Directive include a direct prohibition on testing finalised cosmetics and their ingredients on animals, and an unexpectedly important prohibition on the marketing of cosmetic products within the EU which were tested on animals before and after production. This marketing prohibition applies in cases of certain human health issues unequivocally, regardless of the availability of alternative tests. The first ban establishes a strict prohibition on testing resulting in absolute protection of animal life during testing phases. The second aspect, however, is likely to discourage UK manufacturers from attempting to broaden the prospective geographical markets for their products to an EU-wide spectrum, as the legislation simply will no longer allow it. In theory, it no longer pays to test cosmetics on animals. Manufacturers simply have nowhere within the European Union to sell their immoral goods. Therein lies one of the lesser-known but markedly sinister consequences of the Western crackdown on animal cruelty in the cosmetics industry. There are still nations who unfortunately await such opportunity with open arms. This will be discussed in more detail later.

Alternatives to Animal Testing

The Government is committed to the replacement, reduction, and refinement of the use of animals in research.’ – Home Office, March 2013.

 When the Technical Report of the Commission of the European Union was presented based on scientific evidence and expertise, subject to a public consultation, the Commission reported that at the time of introduction of the Cosmetics Directive in 2013, alternatives to animal-testing of cosmetic products would not yet exist on a viable scale. The Directive was implemented, regardless. Should we take this either as faith that technology will advance rapidly to provide suitable alternative means of testing before the cosmetics industry suffers economic loss? Or is this simply the European Union tipping the scales in favour of morality over practicality?

The European Union reports that considerable sums of money have been and continue to be invested in the research into alternative test methods. The Commission provided an estimated 238 million Euros in the late 2000s, largely directed towards laboratory and alternative test centres such as the European Reference Laboratory for Alternative Methods to Animal Testing (EURL-ECVAM)[9]. The funding rates available to individual European Union Member States vary strongly. However, the facts remain that animal testing is an expensive practice. A skin sensitisation test to meet accepted industry requirements can cost around 4,000 Euros. A carcinogenity test on an animal can soar upwards of 780,000 Euros[10], but the same test – albeit so far representing only a partial replacement - carried out by an ECVAM approved method reaches no more than 35,000 Euros per substance. The estimated time saving when using the above-mentioned non-animal based test is also suggested to be over a year, according to ECVAM[11]. Surely one can conclude that finding alternatives to animal testing makes objective financial sense?

However, the very cost of animal research is what, some say, proves its necessity. Opponents suggest that animal testing is so undeniably expensive that researchers almost certainly would use other methods was the use of animals not crucial and unavoidable to ascertain product safety. Other arguments against the impending switch to non-animal related methods concern the accuracy and competency of our modern technology when simulating real-life reactions. Professor Stephen Hawking once succinctly said, ‘Computers can do amazing things. But even the most powerful computers can’t replace animal experiments in medical research’[12], a quote which is widely deferred to for the continuance of animal testing. If this is true, and the use of currently-existing alternatives is not sufficient to ensure human safety, then this danger to life will surely serve to motivate EU and international organisations to invest further into acceptable alternative means of product safety.


Today’s Cosmetics Market

The European Union claims it is continuing to work with trading partners across the world to ‘accelerate acceptance of validated alternative methods[13]’, but a blanket ban similar to that implemented in 2013 by the EU is unlikely to apply in the near future. Countless animals continue to suffer worldwide for the purposes of the cosmetics industry. While modern consumer pressure continues to weigh upon universal cosmetics markets as a motivation to invest further into viable alternatives, nations such as China have not yet joined this race for research. It is true that China last year took a crucial step in ending animal cosmetic cruelty by relaxing legislation to allow Chinese manufacturers to produce finalised ‘ordinary’ products not tested on animals (whereas in the past the nation actually required all products be tested on animals). However, foreign imported ordinary cosmetics still require to have been animal-tested before they can enter the Chinese beauty market, as do locally-produced special cosmetics such as hair dyes, deodorants and sunscreens[14]. Manufacturers of cosmetics within Europe are actively encouraged to test their products on animals to be able to sell them in such countries as enforce this testing. Those manufacturers who still do so may equally find that export to China for sale remains to be their only market. China, with one of the largest and fastest growing economies in the world, could contribute greatly to the international effort to source economical and ethical alternatives to animal research for cosmetic – as well as all general scientific – ends. World leaders can, and should – use their considerable influence on the world market to discourage what the objective moral bystander would consider to be an immoral and inhumane practice.

Humanity’s true moral test, its fundamental test…consists of its attitude towards those who are at its mercy.’ – Milan Kundera.



                                    [1] Cosmetic, Toiletry and Perfumery Association (CTPA Research), 2013

                                    [2] Special Eurobarometer 340 / Wave 73.1 – TNS Opinion& Social, June 2010

                                    [3] Animals (Scientific Procedures) Act 1986;

                                    [4] Select Committee on Animals in Scientific Procedures Report, Home Office (UK), 2002

                                    [5]  (EC) 1223/2009

                                    [6] Commission Proposal for a Regulation of the European Parliament and the Council concerning the placing on the market and the use of biocidal products, COM (2009) 267 of 12.06.2009

                                    [7] Special Eurobarometer 340 / Wave 73.1 – TNS Opinion& Social, June 2010

                                    [8] European Directive 2010/63/EU on the Protection of Animals used for Scientific Purposes

                                    [9] Impact Assessment on the Animal Testing Provisions in Cosmetics Regulation (EC) 1223/2009

                                    [10] 'Food for Thought … on the Economic of Animal Testing', Bottini and Hartung, Altex

                                    [11] EURL ECVAM Recommendation of 14.03.12

                                    [12] Seriously Ill for Medical Research, 1996

                                    [13] Official Journal of the European Union 638 L142 1-739

                                    [14] Humane Society International, June 2014,

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