Cosmetics brands selling in China are always under scrutiny from animal rights organizations. Every cruelty-free company explicitly tells you that they don’t market their products in China.

China is what we call a ‘taboo’ in the cruelty-free cosmetics market. It’s because China remains the only country in the world where cosmetics testing on animals is required by law.

In the last decade, things have changed in China’s animal testing front. An amendment in 2014 marked the end of animal testing of ordinary domestic beauty products.

After about five years, new laws were drafted by China’s National Medical Products Administration (NMPA) that set new standards for pre-market testing on cosmetics ingredients with plans to reduce post-market testing.

In this article, we’ll discuss the old and new cosmetics testing laws in China and how the new regulations will affect the Chinese cosmetic industry.Animal Testing Laws in China:

The animal testing laws in China have always been subject to critique (and rightly so). Millions of animals suffer and die every day in the name of the law. In the last few years, China made significant improvements in regulating animal testing.

In June 2014, China’s FDA announced that animal testing will not be compulsory for ordinary makeup products. This law only applied to the brands manufacturing domestically in China. It marked a huge milestone for animal welfare activists around the world but the problem remained unsolved.

Later in 2019, the Chinese government announced that they’ll be introducing several new alternatives to animal testing in 2020. It will give Cruelty-free and vegan cosmetics brands an opportunity to expand to the Chinese market. They also announced plans to limit post-market testing on cosmetics and the pilot project. It ensured that cruelty-free brands that participated in the pilot project will not be subjected to animal testing in the filing process.

These laws went into effect in January 2020. The new regulations are the preferred taxological tests for the registration and pre-market approval of cosmetics. There are three issues with these regulations.

  1. It focuses mainly on pre-market testing of ingredients, not the final product
  2. No solid regulations for post-market testing except the pilot project
  3. The new tests are recommended, not compulsory

Animal Testing Ban in China?

NO! China has not banned or ended cosmetics testing on animals.

New laws have been introduced at the beginning of 2020, China’s National Medical Products Administration (NMPA) accepted certain alternate non-animal test methods presented by the Institute for In Vitro Sciences (IIVS) for the regulation of cosmetics. A total of nine tests were mentioned in the acceptance draft including,

The regulation took effect in January 2020. The effects of the new regulations are unknown so far.

China also plans to reduce post-market testing in China. With the effort of IIVS and Cruelty-free International, the dream will soon become a reality. As for the time being, the CEO of Cruelty-free International has assured cruelty-free brands that off-the-shelves testing will not happen with the pilot brands.

Pre-market Testing in China

Pre-market tests take place before a makeup product is sold in the market. The cosmetics brand submits a sample of its products to the Chinese government. The sample is tested to ensure that it’s safe for human use. Most of these tests are conducted on animals.

Before the new laws were enforced, all cosmetics sold in China went through pre-market testing except in some cases. If it was an ordinary makeup or personal care product manufactured domestically.

After the new laws have been enforced, Most cosmetics are still required to go through testing for approval. The new recommended toxicological tests are recommended for the registration and pre-market approval of cosmetic ingredients. Things are changing but not so fast!

Post-market Testing in China

Post-market testing implies that makeup products can be picked off the shelves and tested at any point. These tests are supposed to make sure that the brand is holding up to the standards.

Before the new law was enforced:

Pre-market testing of ordinary cosmetics could be avoided if the brand manufactures domestically but not post-market testing. As long as cosmetics are sold in mainland China, there’s no guarantee. Therefore, any cosmetics brand selling in the Chinese retail market could not claim to be a cruelty-free brand.

After the new law has been enforced:

The CEO of cruelty-free international mentioned that they’re working closely with Oriental Beauty Valley and Fengxian district, Shanghai. Their work is to ensure that post-market testing will not happen to pilot brands (We’ll discuss pilot brands further below). China also has plans to reduce post-market testing.

As of today, post-market testing is still a reality in China.

Cosmetic Ingredients vs. Final Product

China’s animal testing alternatives are not a complete solution. The toxicological tests are intended for registration and pre-market testing of ingredients only.

In simple words, the tests will be used only for testing ingredients, not the final product. Some cosmetics will still be subjected to pre-market testing through non-cruelty-free methods.

What is Cruelty-free Pilot Project?

Cruelty-free international launched its pilot project in November 2019. The aim of the project was to pave a path for the cruelty-free brands to expand into the Chinese market without losing their leaping bunny approval.

The pilot project ensured (among other things) that cruelty-free brands could stay free from animal testing and expertly navigate through other such requirements. It also addresses the issue of post-market testing for pilot brands and makes sure post-market testing doesn’t happen with the pilot brands.

To avoid any issues, all cosmetics brands in this pilot project will be informed about the post-market testing so they have enough time to pull the product from market if it’s suspected of posing a safety issue to Chinese consumers.

The pilot project ensures that the cruelty-free brands that participated in the pilot project can operate without animal testing in China.

Is Makeup Made in China Cruelty-free?

Absolutely but not if it’s sold in China!

Confused? Basically, the cosmetics made in China are cruelty-free as long as it’s not sold in the Chinese market. In which case, the brand will need to register and submit samples of its products for testing. Domestic brands can avoid testing on ordinary cosmetics, but special-use cosmetics will still be required for testing.

In cases of international brands, they must go through a registration process and submit their product samples for testing. Both ordinary cosmetics and special-use are subject to testing. Only after getting approval by the government can you sell your product in the market.

Whether you’re a domestic cosmetics brand or export cosmetics to China, post Market Testing is still difficult to avoid. Which is why cruelty-free brands are reluctant in expanding to China.

Cosmetics Brands that Manufacture and Sell in China

Cosmetics brands that manufacture and sell their products in China are required to go through animal testing for some of their products. There are two types of cosmetics, special-use cosmetics, and ordinary cosmetics.

Special-use Cosmetics

Ordinary Cosmetics

Include cosmetics intended to be used for a specific purpose, like deodorant, sunscreen, and hair dye Include makeup, fragrances, personal care (skincare, nail care, and hair care) products
Cannot be sold in the Chinese market without animal testing Can be sold in China without animal testing but there are string attached
Should be submitted to the government for testing, preferred non-animal testing methods may be used for ingredent testing The cosmetics brand has an option to do risk assessment using ingredient safety data instead of animal testing (only for domestic products)
Goes through both pre-market and post-market testing You can never be sure about post-market testing except for the pilot brands

Why do cosmetics Brands Expand to China?

A million-dollar question indeed!

With nearly 1.4 Billion residents, China is the most populous country in the world. It’s also the second-largest cosmetics market in the world after the United States. This makes China an attractive prospect for any beauty brand. The problems start with its mandatory animal testing laws.

Through the efforts of animal rights organizations like Cruelty-free International, Humane Society International, and PETA, cosmetics testing on animals is a frowned-upon topic. Additionally, more and more cosmetics companies are gravitating toward cruelty-free.

Major cosmetics companies like Estee Lauder and L’oreal have introduced separate cruelty-free brands. Urban Decay is owned by L’oreal and Estee Lauder is the name behind Smashbox.

One way to expand your brand to the Chinese market without testing on animals is through eCommerce.

Cosmetics brands selling online in mainland China don’t need to go through testing. That way a cosmetics brand can expand to the Chinese market, and maintain its cruelty-free status.

Animal Testing in Hong Kong

In spite of being a part of China (technically), Hong Kong, Taiwan, and Macau maintain their affairs separately. They have a separate government and laws. Animal testing laws in these countries are different from mainland China.

All of those countries are not subjected to all of China’s laws. Cruelty-free companies can sell their cosmetic products in Hong Kong, Macau, and Taiwan products without testing their cosmetics on animals.

Cosmetics Sold Online in China:

cosmetics brands selling through eCommerce are not subject to mandatory animal testing. CBEC (Cross Border E-commerce) enables end-users (you and me) to buy products from foreign companies.

There are different rules for CBEC than general trade. This is the loophole cruelty-free cosmetics brands can use to expand to the Chinese market and maintain their cruelty-free status.

Countries That Have Banned Animal Testing:

Countries from all over the world are taking an initiative to put an end to animal testing. 39 countries worldwide have completely banned animal testing including the European Union.

In many countries including the United States, cosmetics testing on animals is optional. Beauty brands have an option to be cruelty-free but they can still test their products on animals.

Countries that have banned animal testing are,

  1. European Union (EU) and its member states
  2. Brazil (Seven states)
  3. European Free Trade Association (Norway, Switzerland, Iceland, and Liechtenstein)
  4. United Kingdoms (UK)
  5. Turkey Newzealand
  6. Israel
  7. India
  8. Guatemala

We’re aiming for a global ban on animal testing. It might take a few more years but the new Chines law about ending compulsory animal testing are promising.

European Union is the largest cruelty-free cosmetics market in the world today. HSI is currently working on securing mandatory alternatives to animal testing in Brazil and South Korea where animal testing is illegal if there’s an alternative available.

Do you want to switch to cruelty-free or make sure that your current brand is cruelty-free? Check our list of cruelty-free brands. It includes all makeup brands that don’t test on animals. If your current brand is not on the list then it’s probably not cruelty-free.

Why Ending Animal Testing is Important?

Animal testing is a bitter reality of our world. Every year, nearly 100,000 to 200,000 animals suffer or die from cosmetics testing.

I invite you to take a moment out of your time and think about the effects of those harsh chemicals on the skin or eyes of innocent animals. They’re robbed of their natural beauty, suffer in labs, and face severe living conditions.

If you want to avoid non-cruelty-free brands, then check our list for cosmetics brands that still test on animals.

China is taking an initiative towards ending animal testing. Although animal testing is still not be banned, there are certain improvements. It’s too early to say anything for sure, especially with the current COVID-19 pandemic. Let’s hope that things get better in both animal testing and COVID-19 fronts.

Right now, #staySafe and #BeCrueltyFree

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