Inspirations

Tested on animals? We test natural cosmetics. Learn the facts, myths, and law

More and more people are opting for natural cosmetics, counting on their safety, gentleness to the skin and lower impact on the environment. However, with the growing popularity of such products, an important question arises: are natural cosmetics tested on animals? For many consumers today, ethical issues are as important as the composition of the product or its effectiveness. Although it might seem that a natural composition automatically means no animal testing, the reality is more complex. Legal regulations vary from country to country, and the practices of individual companies can be ambiguous. In this article, we will explain exactly what animal testing of cosmetics means, what the legal situation is in the European Union and around the world, and how to consciously choose products that are cruelty free. What does "tested on animals" mean? To understand whether natural cosmetics are tested on animals, you need to start by explaining the term itself. "Animal testing" does not always mean the same thing, and the scope of the tests and their purpose can vary significantly. Definition of Animal Testing in the Context of Cosmetics Animal testing is the practice of conducting laboratory studies in which animals are used to assess the safety, effectiveness, or properties of a cosmetic or its ingredients. These tests may include: skin irritation (irritability, contact toxicity), eye irritation, sensitizing effect (sensitization), general and chronic toxicity, reproductive toxicity, carcinogenicity. In cosmetology, these were most often acute irritation tests ( Draize test on rabbits) or lethal dose tests ( LD50 ) - currently considered controversial and unethical. Why were cosmetics once tested on animals? Historically, animal testing was intended to protect consumer health. Until the 1980s, there were no advanced in vitro testing models, and many potential cosmetic substances were introduced to the market without sufficient toxicological data. Animal testing allowed for: assessment of the risk of contact with skin and mucous membranes, detection of potential allergic reactions, assessment of the toxic risk following accidental ingestion of the product. Why is animal testing controversial? Currently, the most frequently raised arguments against: Ethical: suffering and death of laboratory animals (mice, rats, rabbits, guinea pigs). Scientific: limited usefulness of results (biological differences between species). Social: growing consumer awareness and societal pressure for ethical testing. According to data from the European Commission (2020), as many as 43% of Europeans declare that they avoid purchasing cosmetics tested on animals. Which animals were used most often? According to reports from ECHA (European Chemicals Agency) and Humane Society International, the most common substances used in cosmetic tests were: Species Test Purpose Rabbits Skin and eye irritation Guinea pigs Allergy tests Mice Carcinogenicity and mutagenicity studies Rats Toxicological studies, LD50 Are there alternatives to animal testing? Yes – and this is a key breakthrough in recent years. Currently, many alternative research methods ( Alternative Methods to Animal Testing – NAMs, New Approach Methodologies ) are being developed in cosmetology, including: In vitro studies: tests on human skin cells and tissues (reconstructed skin models: EpiDerm™, SkinEthic™). Computer models (in silico): predicting the effects of substances based on algorithms, big data and databases. Ex vivo studies: studies on skin from donors (e.g. after plastic surgery). Non-animal genotoxicity tests: e.g. Ames test. Importantly, the OECD and ECVAM (European Centre for the Validation of Alternative Methods) approve such methods as equivalent in terms of reliability. Are natural cosmetics tested on animals? Natural ≠ cruelty free – the basic consumer misunderstanding Many consumers still believe that if a cosmetic is natural , it has not been tested on animals. Unfortunately, it is not that simple. The terms "natural" and "not tested on animals" refer to two different aspects of the product: the composition and the testing process. A natural cosmetic means that its production uses raw materials of plant, mineral or biotechnological origin, often minimally processed. Cruelty free, on the other hand, refers to the ethics of safety testing - both of the finished cosmetic and its ingredients. In practice, this means that you can find natural cosmetics on the market that, despite their origin, have been tested on animals at various stages – especially if a given company sells them globally and is subject to various legal regulations. Natural resources may also be subject to safety testing. It is worth realizing that the mere fact that a raw material is of natural origin does not exempt manufacturers from the obligation to assess its safety. Each cosmetic ingredient – ​​both synthetic and natural – must be subjected to an assessment of toxicology, phototoxicity, irritation, sensitization, etc. In the past, many plant extracts (such as essential oils, fruit extracts, hydrolates) were tested on animals to assess the risk of their use in humans. Data from such studies often constitute the so-called historical toxicological data on which the modern safety assessment is based. Therefore, even if a given raw material is not currently tested on animals, there may be documentation from years ago in which such tests were performed. The main difference: company policy and cruelty free declaration The position of a given brand and the entire supply chain is crucial. Companies that declare a cruelty-free policy implement rigorous rules, including: no animal testing at any stage of production, cooperation only with raw material suppliers who do not carry out such tests, withdrawal from markets where animal testing is mandatory (e.g. China until recently). In the case of natural companies, raw material suppliers can be an additional problem – some global corporations selling extracts and plant oils have conducted toxicological studies on animals for the purposes of regulations in other industries (e.g. REACH – Registration, Evaluation, Authorisation and Restriction of Chemicals in the EU). This data is sometimes made available to manufacturers of natural cosmetics as part of mandatory safety documentation (Cosmetic Product Safety Assessment Reports – CPSR). Law in the European Union and in the world In the European Union, since 2013, there has been a total ban on testing cosmetics and cosmetic ingredients on animals (Regulation (EC) No. 1223/2009). This applies to both testing finished products and raw materials used exclusively for cosmetic purposes. But even in the EU, the situation is not always completely transparent. Why? Because some cosmetic ingredients have cross-sectoral functions, such as in the pharmaceutical, chemical or agricultural industries, where regulations may require additional safety testing, sometimes on animals. Data from such testing can then be used in the cosmetic ingredient dossier, even if the cosmetic itself remains “animal testing compliant” for the purposes of cosmetics law. The European Union - the most restrictive system in the world The European Union is currently considered the world leader in animal protection in cosmetics. The key legal act here is the Regulation (EC) No 1223/2009 of the European Parliament and of the Council on cosmetic products , in force since 11 July 2013. Under it: a total ban on testing cosmetics on animals was introduced, animal testing has been banned for both finished products and individual cosmetic ingredients, the sale of cosmetics on the EU market that have been tested on animals outside the EU is prohibited. This means that no cosmetic approved for sale in the EU may be tested on animals, either in Europe or outside of it – even if the manufacturer did not carry out the tests itself but used the results of laboratory tests carried out in another country. Tests required by other regulations: the REACH loophole In practice, however, there is a legal loophole that causes confusion among consumers. This is the European REACH regulation (Registration, Evaluation, Authorisation and Restriction of Chemicals), which concerns the safety of all chemical substances, not just cosmetics. Some of the ingredients used in natural cosmetics also have industrial or pharmaceutical functions (e.g. preservatives, stabilizers, solvents, active substances). In such cases, manufacturers are sometimes required to provide additional toxicological data, which cannot always be obtained solely from alternative studies. In some cases, data from historical animal studies conducted before 2013 are still acceptable. Therefore, some plant or semi-synthetic ingredients, even though they are legal in natural cosmetics and the cosmetics themselves comply with the EU ban, may have in their dossiers data from previous animal tests conducted, for example, by suppliers of chemical raw materials. Position of the European Commission and the European Court of Justice In 2021, the European Citizens' Initiative "Save Cruelty Free Cosmetics" attempted to completely close the loopholes of REACH. In response, the European Commission confirmed that: "The basic principle remains the same - no new animal tests are required to obtain authorisation to sell a cosmetic in the EU." However, it was pointed out at the same time that toxicological tests resulting from REACH concern the safety of workers and the environment in the production of chemicals, not the safety of consumers of cosmetics, hence additional data are sometimes allowed. Global Sales of Natural Cosmetics – China’s Problem Many natural cosmetics manufacturers sell globally, which creates additional complications in the context of animal testing. Until recently, one of the biggest problems was mainland China, where the law required mandatory animal testing of cosmetics before they were allowed to be sold in stores. The situation partially changed in May 2021, when the China Market Supervision Administration (NMPA) introduced the possibility of waiving animal testing for some products (so-called general cosmetics ), provided that very strict documentation requirements are met and special safety certificates are obtained. However, not all product categories and not all brands can benefit from this exemption. Since May 1, 2021, a significant change has been introduced - in the case of non-functional cosmetics (so-called "general cosmetics"), e.g. creams, gels, balms or shampoos, animal testing can be replaced by safety documentation and appropriate certificates. However, for functional products (e.g. sunscreen, whitening, anti-acne cosmetics) there are still additional requirements, and the registration process is still not fully transparent. For many natural brands, this still means having to choose: a presence on the Chinese market or a complete cruelty-free policy. That is why some large corporations – even though they offer natural cosmetics lines – still participate in systems in which animal testing is carried out to meet local requirements. USA - No nationwide ban, slow change For many years, the United States lacked a federal ban on animal testing for cosmetics. It wasn't until December 2022 that the Modernization of Cosmetics Regulation Act (MoCRA) was signed into law, which introduced a broad reform of cosmetics regulation. While MoCRA does not impose a complete ban on animal testing at the federal level, a growing number of states (California, Nevada, Illinois, Maine, Hawaii, Virginia, Maryland) have introduced local bans on the sale of products tested on animals. In the US, however, there is still no uniform cruelty-free obligation across the entire territory of the country – the legal situation varies by state. Australia, Brazil, Canada and other countries Australia — Since July 2020, there has been a ban on the use of data from new animal tests for cosmetic ingredients. Brazil — A ban on testing finished cosmetics on animals was approved in 2023. Canada — Animal testing ban for cosmetics and their ingredients effective 2023. South Korea and Japan – no full ban; however, some brands voluntarily implement cruelty-free policies. The European Union remains the most stringent market in terms of animal protection in cosmetics. Outside the EU, the situation is more complex and requires consumers to analyze the policies of a specific brand. Practical examples: brands and animal testing Example 1: Brand X declares that its cosmetics are natural and cruelty free, and the products are available only in the EU and the USA - this means full compliance with the cruelty free principles. Example 2: Brand Y produces cosmetics but sells them in drugstore chains in mainland China — in which case it may be forced to participate in animal testing, even if it does not conduct it itself. Brands often use intermediary companies to whom they commission the tests. Example 3: The Z brand uses plant-based raw materials obtained from large chemical companies that have conducted toxicological tests of their raw materials for REACH or pharmaceutical purposes – the documentation may contain data from animal testing from years ago. Example 4: The Ż brand produces cosmetics within a large corporation, e.g. food-cosmetics or pharmaceutical-food. Ingredients can be tested within pharmaceuticals or food products. Natural, vegan cosmetics and animal testing – the differences Three different concepts that are often confused with each other In conversations about the ethics of cosmetics production, there is often a false assumption that natural, vegan, and cruelty-free cosmetics are synonyms. In fact, each of these terms refers to completely different product features and does not automatically mean the others. Natural cosmetics — refers to the composition, i.e. the use of ingredients of natural origin: plant, mineral, biotechnological. Vegan cosmetics – means that the product does not contain ingredients of animal origin or their derivatives. Cruelty free cosmetics – means that the product and its ingredients have not been tested on animals at any stage of production. In practice, this means that it is possible for a cosmetic to: is natural, but contains ingredients of animal origin (e.g. beeswax, lanolin, goat's milk), is vegan, but has been tested on animals, is cruelty free, but contains both synthetic and natural ingredients. Natural Cosmetics - Definition and Scope The concept of "natural cosmetic" is not clearly defined in the cosmetics law (Regulation (EC) 1223/2009 does not define naturalness). Therefore, there are various certification standards on the market (e.g. COSMOS, NATRUE), which specify: minimal share of natural and organic ingredients, degree of processing of raw materials, restrictions on some preservatives or emulsifiers. The key point is that the naturalness of the composition itself says nothing about the methods used to test the safety of the product. Example: Aloe vera extract (Aloe barbadensis) is a natural ingredient, but the supplier may have toxicological data from before 2013, which includes animal testing. A cosmetic containing aloe vera itself may comply with the EU testing ban, but may not necessarily meet cruelty-free standards in the strict sense. Vegan cosmetics - composition free from animal raw materials A vegan cosmetic means that none of its ingredients come from animals or are derived from their metabolic products. This includes, among others: collagen, elastin (usually obtained from fish or cattle), keratin (from wool, horns, hooves), beeswax (cera alba), lanolin (from sheep wool), milk, honey, eggs, silk. However, a vegan product can still come from a manufacturer that allows animal testing. Vegan ingredients alone do not automatically mean cruelty-free status. Example: Brand X offers a vegan moisturizer without animal ingredients but sells it in China - the product is vegan but not necessarily cruelty free. Cruelty-free cosmetics - complete elimination of animal testing The concept of cruelty free is related solely to safety testing methods. Cruelty free cosmetic: has not been tested on animals at any stage of production and distribution, its raw materials have also not been tested on animals on behalf of the manufacturer, the manufacturer does not sell in countries requiring mandatory animal testing (or provides documentation exempting from testing where possible). Importantly, a cruelty-free cosmetic does not have to be natural or vegan. It can contain both synthetic ingredients and animal ingredients (if they were not the result of animal suffering, e.g. lanolin from wool extraction). Why are these terms confused? The main cause of the confusion is the marketing activities of cosmetic brands, which often use slogans such as: "natural = vegan = ethical = cruelty free". The lack of uniform legal regulations regarding the definitions of these concepts additionally makes it difficult for consumers to properly understand the differences. Humane Society International’s 2022 consumer research shows that: 68% of consumers wrongly assume that natural cosmetics are not tested on animals, 55% believe that vegan products automatically meet cruelty free standards, only 29% consciously distinguish between both concepts. Examples for full understanding Cosmetic Natural? Vegan? Cruelty free? Cream with beeswax YES NO YES (if not tested) Synthetic serum without animal ingredients NO YES YES (if not tested) Honey face mask sold in China YES NO NO Aloe vera gel from old toxicology documentation YES YES YES (in EU), doubtful globally Does Orientana test or has tested cosmetics on animals? The Orientana brand, although founded fourteen years ago, has been guided by the principle of complete ethics in the production of natural cosmetics from the very beginning. It has never tested its products on animals or used raw materials that were tested in a way that was harmful to animals. Moreover, Orientana also avoids animal-derived ingredients whose acquisition would involve the death or suffering of animals. Thanks to this, consumers can be sure that by choosing Orientana products, they support a brand that focuses on ethics, nature and respect for all beings. Why is animal testing still being talked about when it is banned? A topic that never ends Despite the EU’s total ban on animal testing for cosmetics, the topic still stirs up a lot of emotion and doubt among consumers and the cosmetics industry alike. The reasons are complex and stem from real issues that still exist on a global scale – from complex supply chains to regulatory inconsistency. Global Supply Chain Issues Modern cosmetics production, even natural cosmetics, is based on a very extensive, international network of raw material suppliers. Even a small moisturising cream can contain 20–40 different ingredients, sourced from suppliers on several continents. Often, one cosmetics company does not produce raw materials on its own, but buys ready-made extracts, oils, emollients, preservatives or thickeners from global chemical and biotechnology concerns. The problem is that some of these companies — especially large industrial suppliers — have conducted or continue to conduct toxicological testing on animals not only for cosmetics, but also for: chemical industry, pharmaceutical, food, agrochemical. According to data from the European Chemicals Agency (ECHA), approximately 70% of substances registered under REACH also have toxicological data from animal testing carried out in the past or for the needs of other industrial sectors. A manufacturer of natural cosmetics, even if it does not conduct animal testing itself, may use raw material documentation based on such data, which introduces ethical and communication controversies. Lack of transparency among some manufacturers Not all cosmetics brands fully disclose their ethical policies and testing practices. Some companies use imprecise statements such as: "We do not test finished products on animals" "We only test when required by law" "The product has been tested in accordance with EU regulations" Such wording allows companies to formally comply with EU law but does not inform consumers about the full scope of toxicological data, which often includes older animal tests performed by suppliers. In a 2023 study by Cruelty Free International , conducted on 70 brands operating in Europe and the US, as many as 41% of companies were unable to precisely determine whether all raw materials in their products were free from data obtained from animal testing in other sectors. Different legal regulations outside the EU Although the European Union banned animal testing in cosmetics in 2013, many other countries still have inconsistent or much more lenient regulations. As a result: companies producing for global markets must adapt documentation to various regulations; for some countries (e.g. in Asia or the Middle East) animal testing is still mandatory or recommended; some countries formally abolish tests, but in practice require documents that are very difficult to obtain using fully alternative methods. For example, Japan and South Korea still lack a nationwide ban on animal testing for all cosmetics categories, although some brands in these countries voluntarily implement cruelty-free policies. In China , despite the 2021 reform, many products are still subject to mandatory safety testing, especially in the so-called "functional cosmetics" category (whitening creams, UV filters, medicinal products). Testing Chemical Ingredients for Non-Cosmetic Purposes One of the most difficult ethical issues in natural cosmetics is testing conducted for the needs of other industries – especially in terms of chemical and environmental law. In the EU, the main problem is the aforementioned REACH system (Registration, Evaluation, Authorisation and Restriction of Chemicals) . In the case of some cosmetic ingredients, which are also used in: detergent production, fertilizers, plastics, pharmaceuticals, Regulatory authorities may request additional toxicological data, which is sometimes obtained from animal studies. The European Chemicals Agency report from 2021 indicates that: "About 35% of substances registered under REACH required reproductive, developmental or genotoxic toxicity tests on animals to fully complete the industrial dossier." For natural cosmetics manufacturers, this means that not all raw material data included in their CPSRs is completely free from animal testing – even though the cosmetics themselves comply with the EU ban. Expert Summary Why doesn’t the topic of animal testing in natural cosmetics go away? Because even with a complete ban on testing ready-made cosmetics: raw material documentation is often based on older animal studies, Global regulations are still not consistent, Supply chains are multi-level and opaque, Much testing is done for other industries. That is why conscious brand communication, full transparency of documentation and education of consumers, who are often unaware of the complexity of the problem, are so important. Conscious choice of natural cosmetics Choosing natural cosmetics is an important step towards more conscious and skin-friendly care. Ingredients of plant, mineral or biotechnological origin offer a number of benefits - they are mild, often better tolerated by sensitive skin and support the balance of the microbiome. However, the naturalness of the composition is only one of many elements of ethical and responsible cosmetic production. Throughout the product development process, safety testing methods and the sources of toxicological data are equally important. It is at this stage that most misunderstandings and ethically difficult decisions occur. Animal Testing – A Topic That Won't Go Away Although the European Union has had a formal ban on testing cosmetics on animals since 2013, the problem still exists in a broader, global context: Global supply chains mean that many cosmetic raw materials used in natural formulas have a history of past toxicological testing on animals – often for REACH, pharmaceutical, industrial chemistry or environmental purposes. The lack of full transparency on the part of some manufacturers makes it even more difficult for consumers to assess to what extent a given brand actually complies with cruelty-free principles at every stage of production. Many countries outside the EU still have less stringent regulations, notably in China, Japan, South Korea and the Middle East. As a result, even a natural, organic cosmetic may have traces of past animal testing in its documentation – and this does not always mean that the manufacturer is consciously violating ethical principles. It is often the result of applicable chemical law or opaque environmental safety standards. Natural, vegan and cruelty free - precise analysis For an informed consumer, it is crucial to separate several concepts: Naturalness — refers to composition, not testing methods. Vegan — means no animal ingredients, but says nothing about testing. Cruelty free — refers exclusively to research policy and the presence of animal testing. Full ethics in cosmetics is only the sum of these three elements. Only then do we talk about cosmetics that are not only natural, but also vegan and free from animal suffering at every stage of production and research. How to make informed purchasing decisions? A conscious consumer who wants to make responsible choices should pay attention to several key issues: Brand transparency — does the manufacturer clearly communicate its cruelty-free policy, publish information about suppliers and the sales market? International Sales – Does the company sell in countries where animal testing is still required (e.g. mainland China)? Independent certifications – although we haven’t covered them in detail in this post, they can be an additional confirmation of ethical production. Awareness of global regulations – it is worth understanding the legal differences between the EU and other markets. Patience in the face of the complexity of the problem - the world of cosmetics, especially natural cosmetics, is an area of ​​many compromises between safety, law and ethics. Key Expert Conclusion Naturalness does not automatically mean ethics. Ethical cosmetics require not only good composition, but also full transparency in terms of research, suppliers and sales markets. Only the sum of these elements allows us to talk about a responsible brand. Scientific sources for this chapter (you can refer to them for the purposes of the blog text): OECD Guidelines for the Testing of Chemicals, 2021 EU Reference Laboratory for alternatives to animal testing (EURL ECVAM), 2020 European Commission. Special Eurobarometer 442 (Attitudes towards Animal Welfare), 2020 Humane Society International, 2021 report Humane Society International, 2022 Global Consumer Survey Regulation (EC) No 1223/2009 COSMOS Standard AISBL NATRUE International Standard ANNA WASILEWSKA - Creator and owner of the Orientana brand