This article is part of our Vogue Business membership package. To enjoy unlimited access to our weekly Beauty Edit newsletter, which contains Member-only reporting and analysis, the Beauty Trend Tracker and Leadership Advice, sign up for Vogue Business membership here.
You might think animal testing for cosmetics is a relic of the past, thanks to highly vocal anti-campaigns, but it remains prevalent across the industry. Not for scientific reasons, but for legal and regulatory ones. Consumers, animal advocates and scientists alike believe it’s time for that to change.
While the cruelty-free beauty category is growing, it still represents a small portion of the overall beauty industry. The global cruelty-free market was valued at $14.84 billion in 2023, and is expected to have a compound annual growth rate of 6.8 per cent between 2024 and 2030, according to US-based market research firm Grand View Research. However, cosmetics that are labelled “cruelty-free” represent just 2.6 per cent of the wider $557.24 billion market; a market growing at a faster rate of 7.7 per cent.
Scientific advancements in alternative testing methods have progressed in line with consumer awareness and ethical concerns. Yet, over 268 major companies, including brands owned by leading conglomerates L’Oréal, Beiersdorf and Estée Lauder Companies (ELC), still sell products containing ingredients that may have been tested on animals by their suppliers, or fund animal testing in some capacity, according to Suzana Rose, founder of cruelty-free brands database Cruelty-Free Kitty and cruelty-free subscription boxes Better Beauty Box. (The main source for this is data collated by animal rights organisation Peta, supplemented by Cruelty-Free Kitty’s independent research.)
When contacted for a comment, Beiersdorf and ELC pointed Vogue Business to their websites. On its site, Beiersdorf says it does not directly test products or ingredients on animals and that it has been at the forefront of developing and promoting alternative methods for 40 years, while ELC’s says it was one of the first companies to eliminate animal testing as a method of determining cosmetic-product safety. According to a L’Oréal spokesperson, the company hasn’t tested the safety of its products on animals since 1989 and never asks others to do so on its behalf. However, all three companies — alongside many others — sell in countries where they know animal testing is conducted on products.
And this, critics say, is a big part of the problem.
Some regions like the EU and the UK banned animal testing for cosmetics a long time ago. However, legislation around chemical and drug safety requires animal testing for certain products — sometimes in direct conflict with such bans. Products like hair dyes, SPFs and antiperspirants are considered drugs or ‘special’ cosmetics in countries including the US and China, and therefore are still permitted to undergo animal testing, according to Erin Hill, CEO of the International Collaboration on Cosmetics Safety (ICCS), a New York-based global initiative focusing on advancing the adoption of animal-free assessments of cosmetics and their ingredients. While the US and China are now taking steps to reduce animal testing, the approach and pace differ, with the US further along in implementing alternatives and legislative changes.
One of the reasons animal testing persists, says Krupa Koestline, founder of product development firm KKT Innovation Labs, is that ingredients entering US or European markets go through a process to determine how different the chemical composition is from what’s already on the offer there. If there isn’t substantial safety data already available, it might go through animal testing. “Ethically, it’s difficult to test a potentially harmful new substance on humans, so animal models remain commonly used even if it’s an expensive practice that nobody wants to perform.”
The absence of standards and a clear legal definition allows the cruelty-free label to be used loosely. This, coupled with the general lack of transparency in the beauty supply chain and conflicting policies between countries, has led to confusion among consumers over which products and brands are truly free of animal testing. A survey by Emerald Insight found that consumers are often unaware of the nuances around cruelty-free certifications and may assume products are cruelty-free based on packaging and marketing claims.
Legal and regulatory challenges
The UK was a pioneer in banning animal testing for cosmetics ingredients in 1998. However, in January 2023, British animal protection and advocacy group Cruelty Free International (CFI) revealed that the Home Office had quietly abandoned the policy in 2019 and had been issuing licences for the animal testing of certain ingredients that aren’t solely used in cosmetics or that could pose risks to workers exposed to those substances. A primary driver was concern about UK companies losing competitiveness and to align with EU regulations, CFI’s investigation suggests.
“In the EU, the European Chemicals Agency, backed by the European Commission, still requires animal testing for ingredients under chemicals regulations, undermining the bans on testing on animals for cosmetics,” explains Peta’s science policy advisor Jen Hochmuth.
In May 2023, following pressure from CFI, the Home Office reinstated parts of the 1998 policy, banning animal tests for ingredients exclusively used in cosmetics, which represents only 20 per cent of all chemicals found in cosmetics (the original ban covered exclusive and predominant use). The advocacy group is now asking for a comprehensive ban to be put into law, giving step-by-step recommendations to assist the new Labour government (which pledged to phase out animal testing in its 2024 general election manifesto).
The US — aka the world’s largest cosmetics market — presents a tricky landscape, where the lack of a national ban has made animal testing a state-level issue. Only 11 states have prohibited the sale or manufacture of products tested on animals, while a 1938 law classifies SPFs as drugs rather than cosmetics, which means animal testing is still required in some cases — despite a shift away, per 2022’s Modernization of Cosmetics Regulation Act (MoCRA). The outdated approach to regulating SPFs has been heavily criticised as it eliminates newer, more effective SPF ingredients that have been approved in Europe, for example, where experts say safety regulations are increasingly up to date. MoCRA’s impact, meanwhile, extends to all cosmetic products and ingredients, introducing requirements that enhance industry-wide safety, transparency and accountability.
Laws in China have loosened in recent years, now permitting imported “general” cosmetics, like shampoo and makeup, to be sold without animal testing, however “special” cosmetics, like antiperspirants and SPFs, still have stricter requirements, says Rose. “Despite progress, very few cruelty-free brands are able to bypass these regulations, and most large companies selling in China still test on animals,” she adds.
For general cosmetics made outside of China, companies can either sell their products online without animal testing or submit good manufacturing practice (GMP) certifications issued and granted by the local government’s cosmetic authority, along with an assessment that can fully confirm the safety of products before selling them in physical stores without additional tests. Cruelty-free brands like Aesop don’t sell products that haven’t qualified for exemption from animal testing in China.
L’Oréal says it actively works with Chinese authorities “to have alternative testing methods recognised and evolve towards a total elimination of animal testing”. The spokesperson says that, as a result of those efforts, some products, including shampoo, body wash and some makeup, that are manufactured and sold in China are no longer tested on animals. On their websites, ELC says it supports research and works with global partners that advocate for practical solutions and acceptance of animal testing alternatives, while Procter Gamble states that it is a sponsor of the World Congress on Alternatives and Animal Use to speed up the adoption of global safety regulations and supports Humane Society International’s campaign calling for the global elimination of animal testing in cosmetics.
However, only three companies — Biofilm, Colgate-Palmolive and Unilever — are categorised by Peta as “working for regulatory change”, a label highlighting companies that are actively working to change animal testing requirements. “The requirements for this category are stringent,” says Hochmuth. “They need to be completely transparent about the tests they conduct and why, and they must show that they are actively working to promote the development, validation and acceptance of non-animal methods in all geographic markets in which they operate in a significant way.”
Alternative options
Animal-free methods do exist, such as testing on human cells and tissues, advanced computer-modelling techniques and trials with human volunteers. Researchers at Imperial College London are developing artificial cells that can be 3D printed into lifelike models of human skin, reducing reliance on animal tissue, which often provides less reliable results due to its physiological differences from human skin. “There’s been significant collaboration between brands, activists, experts, scientists and policymakers to advance non-animal testing methods, which are evaluated more rigorously and have been shown to be able to provide better data than traditional animal tests,” says Emma Grange, director of science and regulatory affairs at CFI.
Hill notes that cosmetics companies have invested millions in non-animal testing methods, and regulatory bodies worldwide are increasingly interested in making this shift — but the implementation isn’t easy. “The challenge is building confidence in these new approaches and the data they provide,” Hill says. “Often laws or technical standards need to be changed, which can be a lengthy process, but our approach is to work closely with regulators to understand their concerns and build scientific or training tools that assist them in their shift away from animal testing.”
The pressure is building: consumers increasingly demand to know what goes into their favourite products and want to buy from brands that align with their values. “There’s a growing interest in supporting authentic brands that prioritise enacting change over profit and are committed to maintaining a completely ethical supply chain, which means opposing animal testing,” says Anna Brightman, co-founder of Upcircle, a beauty brand certified under CFI’s Leaping Bunny Programme, which checks for animal cruelty in the supply chain.
“There’s strong public demand for more action to end animal testing and greater investment in alternative methods,” says Peta’s Hochmuth. “This pressure is driving the political agenda.”
With a wealth of existing ingredients and non-animal methods already available, there’s no justification for keeping animals in labs for the sake of cosmetics, Hochmuth concludes. “If the safety of a product or an ingredient can’t be demonstrated using these methods, it should simply not be used.”
Comments, questions or feedback? Email us at feedback@voguebusiness.com.
