An introduction to animal testing policies

While it might say, “We are against animal testing” on the side of your shampoo bottle, this provides little assurance that the product you’re buying is free from animal testing.

In this guide to animal testing policies we demystify corporate speak examining issues such as:

• How to spot meaningless statements
• Why some companies still test on animals
• How animal testing usually occurs in the ingredients supply chain
• What fixed cut-off dates are and why they are used
• The role of exceptions in animal testing policies
• How Ethical Consumer rates companies on animal testing 
• Which companies score Ethical Consumer’s best and worst ratings for animal testing

What does ‘cruelty-free’ actually mean?

Lots of terms we associate with animal testing are not protected (meaning that there is no legal definition of what they actually mean). 

By themselves many can be close to meaningless when it comes to knowing whether or not the company has a stringent policy not to test on animals. At one point, companies could put them on a product or website even if they did test on animals, but it appears that 'green claims' regulations in both the EU and UK may be making this more difficult now.

Examples of terms that don’t provide meaningful assurance when it comes to not testing on animals include: 

• cruelty-free 
• against animal testing
• vegan
• or other terms that might lead a consumer to believe the company is animal-friendly

Why do some companies still test on animals?

Sadly, almost all of the ingredients that go into our cosmetics have been tested on animals at some point. Some companies continue to test on animals. 

Most companies say that animal testing in relation to cosmetics or household products is conducted for one of the following reasons:

• to test for the safety of products
• to test for the safety of ingredients

Animal testing on end-products is now relatively uncommon in cosmetics and has reduced with household products.

However, ingredient testing is still commonplace. Those ingredients go on to be used in various industries, including cosmetics and household products.

Researchers are developing new ways to prove ingredients are safe

For years health specialists and campaign groups have argued that animal experiments, no matter the species used or the type of disease research undertaken, are highly unreliable when it comes to determining whether a product is safe for humans.

Around 95% of percent of drugs that pass pre-clinical tests, including “pivotal” animal tests, fail to end up actually being sold on the market.

Many alternatives to animal testing are now available too, and companies with a strong stance on animal testing may be working to fund and promote alternative methods of testing products’ safety. 

Some laboratories are even exclusively devoted to animal-free safety testing, such as UK-based lab XCellR8.

We also partner with Lush to manage the Lush Prize. This is a global prize fund to support initiatives to end or replace animal testing. You can watch the Lush Prize conference here to find out about a broad range of initiatives working to end animal testing, including the latest scientific breakthroughs around alternatives to animal testing. 

Why companies rarely test products on animals

Well-known consumer-facing companies and brands rarely test their end products on animals.

Most consumer brands don’t  have their own labs and their staff probably don’t carry out tests on products themselves. 

There are several reasons why consumer-facing companies are unlikely to test their products on animals: 

• It can create bad publicity for a company if consumers discover they are involved in animal testing. 
• It can be expensive to carry out. 
• Companies are also legally prohibited from testing on animals in some instances – for example, in the EU it’s illegal to test finished cosmetic products on animals.

As it’s illegal to test cosmetics on animals in the EU, cosmetics companies that say they don’t test on animals are really just complying with the law – the absolute minimum. 

As we’ll go on to see, if all a company only says is that it doesn’t test on animals then it probably has a weak policy. It should be providing much more detail. 

For example if a company says “We don’t test on animals” that doesn’t necessarily mean they don’t commission other companies or third-parties to do it for them!

Animal testing usually occurs in the ingredients supply chain

Strong non-animal testing policies are specific and move beyond general statements.

In particular they demonstrate an awareness of the role of ingredients. Animal testing usually takes place on the ingredients inside a product, rather than on the final product itself. 

Strong non-animal testing policies should therefore explicitly discuss the ingredients that are inside products.

What is a fixed cut-off date?

If a company has a fixed cut-off date, this shows that the company understands that animal testing takes place at the supplier level and is working to ensure that none of the ingredients in its products were tested on animals by suppliers. 

Having a fixed cut-off date is an important element of many strong no animal testing policies. 

A company chooses a date, for example, 1 June 2012. This tells consumers and other stakeholders in the business that (i) the company has not tested on animals since that date, and (ii) none of the ingredients in its products were tested on animals by direct suppliers after that date.

Why are fixed cut off dates used?

Virtually all ingredients have been tested on animals at some stage. Therefore, it’s barely ever possible to say that an ingredient has not been tested on animals. 

The ‘5 year rolling rule’

If a company has a 5-year rolling rule, it could label a product as ‘free from animal testing’ if none of the ingredients within it had been tested on animals in the past five years.

However, this means that companies could develop a new ingredient and test it on animals, and then wait five years and sell it as animal testing free. 

As such, the fixed cut-off date was introduced to reduce this risk.

The ‘fixed cut off date’

This is where a company commits to not using ingredients that have been tested on animals after a certain year e.g. a company might say “we do not use ingredients that have been tested on animals since 1997”.

It also in theory discourages chemists from coming up with exciting new ingredients (for non-essential products like make-up) which then need by law to be tested.

By enforcing a fixed cut-off date, companies seek to find ingredients that haven’t recently been tested on animals by their suppliers.

Therefore, companies that really enforce their fixed cut-off date should only buy ingredients that were either:

• proven safe before the fixed cut-off date;
• were proven safe after it through non-animal alternative testing methods;
• were proven to be safe by another manufacturer or entity. (Though this may mean that another manufacturer has conducted animal testing on that type of ingredient and the supplier is buying the testing data from them, and so benefitting from it even though they didn’t conduct or commission it).

Challenges in applying animal testing policies

There are challenges when it comes to upholding non-animal testing policies with fixed cut-off dates or other criteria. 

Different certifications and companies might exempt some suppliers from meeting the criteria in, for example, the following instances:

b) Commitment to no animal tests in the future

Some certifications or companies may also decide they are willing to source from a supplier who does not test on animals now, but has tested on animals after the company’s fixed cut-off date (for example, the company’s fixed cut off date is 2010, but the supplier carried out an animal test in 2011).

They may decide that if the supplier is transparent about this with the company and has committed to not carrying out any more tests now or in future, this is acceptable.

How Ethical Consumer rates companies on animal testing

Ethical Consumer rates all companies that are involved in cosmetics, pharmaceuticals, animal nutrition, and household, toiletries and cleaning products on their approach to animal testing. 

We don’t rate companies on whether or not they test on animals because few consumer-facing brands do test on animals. Instead, we rate them on how much effort they are putting in to reduce the risk of animal testing occurring in their supply chain. Read more about why we do this in our summary about animal testing.

Updated animal testing policy rating

In October 2021 we updated our animal testing policy rating. We rate large companies as follows. 

Best rating

We expect companies to have a fixed cut-off date that applies to both own-brand and retailed products if they are to receive our best rating. If all its products are certified by one of the certification schemes which require a fixed cut-off date, this therefore scores a best. Leaping Bunny certification meets this requirement if it applies to the whole company group.

Middle rating

There are three ways to receive a middle rating. 

1. Having a fixed cut off date that only applies to own-brand products but not retailed products
2. Having a non-animal testing policy that specifically mentions ingredients as opposed to only final products. While this is less stringent than a fixed cut off date, it does demonstrate an awareness by the company that they do not want suppliers to carry out testing on animals on their behalf. 
3. Having all products certified by Peta, Vegan Society, Vegetarian Society, or Soil Association.

Worst

If none of the above criteria are met, it's considered to have not made significant effort to reduce the risk of animal testing and receives a worst rating.

Small companies

We’re more lenient with small companies because you often have to pay to get certified by animal rights/ welfare organisations, plus it takes time and administration efforts that small companies may not have capacity for. When starting a business, it can also take time to recognise which strong policies are needed and to develop them. 

For this reason, we also give small companies a middle rating if they have a general, albeit vague, statement against animal testing e.g. describing their range as ‘cruelty free’.

The can receive an exemption and get a best rating if they have a statement against animal testing which discusses ingredients; or have all products certified by any animal rights organisation that discusses ingredients.

Check whether certification applies to own-brand and/or retailed products

If you want to go the extra mile you could only buy from companies that refuse to retail any products that are implicated in animal testing, even if they’re not own-brand.

When we rate companies on their animal testing policies, we expect them to not only be talking about own-brand products but also products that they retail.

For example, John Lewis has a strong non-animal testing policy for own-brand products, but its policy doesn’t apply to non own-brand products. It still retails products which have been criticised for animal testing involvement, such as Estée Lauder and Clarins.

Read more about animal testing in our guide to non animal testing certifications.