In countries such as China (mainland) regulations require that most imported cosmetic products must undergo animal testing prior to being sold retail to consumers. For the animals in question this means a miserable and often shortened existence as these products are tested in the name of safety regulations.

Why do companies choose to continue to sell their products into China? Sadly because these overseas markets offer lucrative investment opportunities to major brands, many still continue to overlook animal welfare in exchange for bigger profits.

Until 2013, all cosmetics in China (domestic or imported) were required to undergo pre-market and post-market testing (which includes mandatory animal testing). Regulation changes in 2013-2014 removed the requirement for pre-market testing on domestic non-special-use cosmetics only. All imported cosmetics, regardless of category, continued to be subject to pre and post-market animal testing.

The new, yet-to-be-published regulations (CSAR) revise testing requirements further. Under the new measures, all domestic AND imported non-special-use cosmetics will no longer require pre-market testing. However, while this is a step in the right direction, there are significant loopholes:

  • Non-special-use products designed for use on children or infants and products that include raw ingredients not on China’s approved list. These will still be subject to pre-market tests

  • The measures do not remove the requirement for post-market testing

  • The measures indicate a strengthening of post-market supervision and random sampling processes to ensure quality and consistency is maintained. While currently unclear what this means in detail, it could indicate increased post-market animal testing

  • Notably, special-use cosmetics will still be subject to mandatory pre- (and post-) market animal testing

The most important consideration here is that due to post-market testing requirements, even cosmetic companies selling exempted non-special use cosmetics in China under the new regulations still cannot guarantee that their cosmetics are cruelty-free.

Animal testing in China is under constant regulatory review and we’ll do our utmost to keep you abreast of the changes as and when they occur.


1. https://www.hsi.org/wp-content/uploads/assets/pdfs/bcf_china_faqs.pdf
2. www.chinalawinsight.com/2019/07/articles/cosmetics/chinas-slow-move-to-cruelty-free-new-draft-regulation-changes-requirements-for-cosmetics-filing/#:~:text=According%20to%20Article%2011%20of,passes%20a%20safety%20risk%20assessment
3. https://www.cosmeticsdesign-asia.com/Article/2019/08/15/China-s-new-cosmetics-regulations-Key-points-you-need-to-know-about-CSAR-developments 
4. https://www.chinalawinsight.com/2019/07/articles/cosmetics/chinas-slow-move-to-cruelty-free-new-draft-regulation-changes-requirements-for-cosmetics-filing/


How does China define Cosmetics?

In China, cosmetics have different testing requirements depending on their category. Cosmetics fall under two different categories: 

Special-use cosmetics vs Non special-use cosmetics – existing regulations

As per Cosmetics Hygiene Supervision Regulations 1990 (CHSR)









These categories have recently been revised in the CSAR draft legislation that has been approved as of January 2020 but has not yet been published and implemented due to the ongoing Covid-19 crisis. 


Animal Testing Methods and Approved Non-Animal Testing Methods in China

Knudsen&CRC has prepared an overview below of the testing methods, as well as the original alternative testing methods launched during the period of 2016-2019. Find the full article here.

Pre and Post Market Animal Testing in China Regulations

Imported products can continue to be direct mailed by foreign companies to consumers in the Chinese mainland for personal use with no animal testing requirement (also known as e-commerce). Imported products can be sent to Hong Kong by foreign companies, then an agent there can direct mail to consumers in the Chinese mainland for personal use, with no animal testing requirement. Hong Kong still has no mandatory animal testing regulations for e-commerce or retail.

Media Announcements

China has passed the Cosmetic Supervision and Administration (CSAR) Regulation Draft that will replace the outdated Cosmetics Hygiene Supervision Regulations (CHSR) which was implemented in 1990 and has been a major hurdle to progress and innovation in the industry. (January 2020)

China’s National Medical Products Administration (NMPA) approves two animal-free cosmetic testing methods but it is still a long way from banning animal tests completely. (April 2019)

China’s Gansu Province National Medical Products Association has announced that post-market testing for finished imported and domestically produced cosmetics in China will not include animal tests. At this stage, this does not automatically mean that brands can import to China overnight and be cruelty free. (March 2019)

China’s cabinet, the State Council, cuts import tariffs on cosmetics goods from 8.9% to 2.4% an incentive designed to further open up the import market to meet growing consumer demand. (May 2018)

China’s National Institutes for Food and Drug Control (NIFDC) published a bulletin on the potential adoption of two non-animal methodsof cosmetics testing. (February 2018)

Public consultation on cosmetics classifications in China closes. (January 2018)

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


Designed to give you the peace of mind you need to make informed choices, our free app makes it easy for you to make cruelty-free purchases.

That means no more stress about selecting your personal care products because Choose Cruelty Free has done the hard work.


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