China – what’s the story?

Did you know that some countries still require animal testing of cosmetics?

The Issue

Emerging consumer markets present exciting opportunities for many companies on the Choose Cruelty Free List (CCF List). Millions of potential new customers overseas are eager to try the wide range of cosmetic and toiletry products that are already available in Australia.Rabbit Skin Test

Unfortunately, for thousands of animals, this is not great news.

Current government regulations in countries like China* (mainland) and Brazil** require that most cosmetic products manufactured outside the country and imported for retail sale to consumers must undergo animal testing.

In addition, in April and June 2016, the China Food and Drug Administration, CIRS China and the Ministry of Finance indicated that further changes to the regulations are planned to take effect from May 2017. These include adding imported toothpaste and oral care products to the list of product types that are subject to animal testing, and the introduction of animal testing for products sold by cross border e-commerce channels. Soap is still under consideration to be included in the definition of cosmetics.

In summary, we understand that:

  • The new regulation proposed involves animal testing of bonded shipments, i.e. foreign companies sending product in bulk to the China free trade zone then distributing via an agent to consumers in mainland China.
  • Products can continue to be direct mailed by foreign companies to consumers in the Chinese mainland for personal use with no animal testing requirement.
  • Products can be sent to Hong Kong by foreign companies, then an agent there can direct mail to consumers in the Chinese for personal use, with no animal testing requirement.
  • Hong Kong still has no mandatory animal testing regulations for e-commerce or retail.

We will continue to liaise with the Chinese regulators and monitor the companies on the CCF List to ensure they remain compliant with our accreditation criteria.

NB: it’s important to note that China and Brazil are not the only countries which still require some form of compulsory animal testing for imported cosmetics. * Mainland China, not Hong Kong. **Some states in Brazil.

CCF’s Position

On 12 November 2013, we wrote to all the companies on the CCF List in relation to this issue, and the following is extracted from that letter:

“At Choose Cruelty Free (CCF) we have always been proud of our accreditation process, and our criteria for inclusion on the Australian cruelty-free list are the strictest in the world. CCF will not accredit any company that has a parent or subsidiary that still conducts animal-testing; and companies must enter into a legal agreement with us. Statements of assurance are just not good enough. In view of the changing nature of the cosmetics manufacturing industry, we have decided to review our questionnaire, and introduce changes to ensure it is relevant to the current global situation.

At the moment CCF is very concerned about cosmetic companies selling, or contemplating selling, their products in China and Brazil. It is true that both offer very lucrative markets. Unfortunately, the respective governments currently require that a sample of product ingredients be tested on animals before they are registered for retail sale to consumers (although there are exceptions). If your company decides to enter a market where animal testing of your products is required you will be removed from the Choose Cruelty Free List.”

Global Campaigns Against Animal-Testing of Cosmetics

Thankfully, several large organisations with resources are working to bring an end to animal-testing of cosmetics, globally. Click the name below to go to their relevant campaign pages for more information:

On 8 November 2013, we received news that HSI has been speaking to the China Food and Drug Administration (CFDA) and in June 2014 the requirement to animal-test locally made products was abolished. Whereas this is a great step forward, it will not eliminate animal experiments entirely. The Chemical Inspection and Regulation Service Limited (CIRS China) released a Regulatory Alert on 5 November 2013 outlining what the changes mean. Read the CIRS China Regulatory Alert here.

The BUAV scored a major victory in March 2013 when the European Union ban on the sale of animal tested cosmetics came into force. Now Cruelty Free International, the global organization founded by the BUAV, launched a global campaign in August 2013 to persuade governments around the world to enact similar legislation.

We also know that PETA in 2012 donated funds to the Institute for In Vitro Sciences (IIVS) to train scientists in China how to use the 3T3 Neutral Red Uptake Phototoxicity Test, which can replace the current animal testing system in place.

On a trip to China, our secret shopper spent a little time in stores on Nanjing Road, Shanghai to see what brands are readily available to consumers (October 2013): nanjing_road_shanghai_nightview

  • Avena
  • Bourjois
  • Channel
  • Givenchy
  • Innisfree
  • Johnson & Johnson
  • La Roche
  • Lancôme
  • Maybelline
  • Nina Ricci
  • Olay
  • Ralph Lauren
  • Red Earth
  • Shiseido
  • Swarovski
  • Valentino
  • Vichy

There are also plenty of major brands selling in China, advertised via various magazines:

SELF Magazine SELF Magazine China 2013

  • Avene
  • Biotherm
  • Bobbie Brown
  • Chanel
  • Clinique
  • Estee Lauder
  • Givenchy
  • Guerlain
  • Innesfree
  • Jurlique
  • La Roche
  • Mac
  • Origins
  • Revlon
  • Versace

Tatler China TATLER Magazine China 2013

  • Artistry
  • Dior
  • Estee Lauder
  • Giorgio Armani
  • Helena Rubenstein
  • La Prairie
  • Mac
  • Pola RMB laboratories
  • Revital
  • Yves St Laurent

Media Announcements

Pan-Asian regulatory expert Dr Tommy Kong outlines current cosmetic import regulations in China. (March 2015)

HSI’s #BeCrueltyFree South Korea Campaign welcomes Cosmetics Bill requiring mandatory use of alternatives, but loopholes must be closed. (March 2015)

HSI’s #BeCrueltyFree campaign re animal-testing of cosmetics in China. (July 2014)

HSI’s #BeCrueltyFree campaign update on the latest news from China re a proposed review of animal testing regulations. (October 2013)

L’Oreal spends US$843 million to accelerate their expansion in China. (August 2013)

EU Health Commissioner Tonio Borg has urged Chinese authorities to follow the European example and rid the cosmetics arena of animal testing and turn to alternative methods instead. (June 2013)

HSI’s #BeCrueltyFree campaign launch in China. (June 2013)

HSI’s #BeCrueltyFree campaign celebrates India’s ban on animal testing of cosmetics.  (June 2013)

CHOICE exposes questionable cosmetic labelling re animal testing. Watch the CHOICE video which aired on Australian TV. (May 2013)

Page Updated: 21 July 2016