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  • Writer's pictureLouisa Sperrazza

Animal Testing in China in the Cosmetics Industry

Updated: Nov 5, 2019

If you are interested in learning about the laws of animal testing in China, abuse in testing, and why China is disinclined to rush to adopt alternative methods, read below:



You are so excited to buy that new lipstick. You swatch different colors until you find the right match. Somewhere, animals are suffering so that you get the perfect shade of red. Cruelty Free International (CFI), an animal advocacy group based in England that campaigns for the abolition of animal experimentation, defines animal testing as “any scientific experiment or test in which a live animal is forced to undergo something that is likely to cause them pain, suffering, distress or lasting harm”. CFI states that animals are usually killed at the end of the experiment. This form of testing is used on all cosmetic products, including makeup, nail and hair care, fragrances, skin care, and more. Animal testing is especially an issue in the cosmetics industry in China, which is the only country where (excluding Hong Kong) animal testing is required in order for a foreign product to be physically sold in the country. Foreign (particularly American and European) companies that sell their products on the Chinese market often overlook the requirement to animal test despite ethical debates due to the fact that China’s cosmetic market earns companies a massive profit. For example, in 2017, 251.4 billion Chinese Renminbi (which translates to over 36 billion USD) worth of cosmetics products were sold. Still, activists argue that animal testing is ineffective and harmful to animals, and there are more ethical alternatives. Even though China has made progressive legislation regarding animal testing, the country is disinclined to rush to adopt new, more functional alternatives.


China began its journey towards legislative revision regarding animal testing on June 30, 2014, when the requirement to animal test on domestically produced ordinary products was lifted. This change enables local Chinese manufacturers of ordinary products to opt for alternative methods of testing. The lifted regulation does not apply to foreign imported ordinary products nor foreign and domestically produced special-use products, which both prior to the legislative change and still currently require animal testing. Ordinary and special-use cosmetics are the two classes which products are placed into. Each class requires a different license from the Chinese Food and Drug Administration. Ordinary products acquire a record-keeping certificate in four to six months. Special-use cosmetic products require a hygiene license, which is more expensive and takes about eight to 15 months to acquire.  Ordinary cosmetics include make-up, hair and skin care, and perfumes. Special-use cosmetics include hair dyes and perms, whitening products, and sunscreens.


China currently requires pre-market testing on animals for all foreign cosmetic products sold within the country’s boundaries (excluding Hong Kong). Online shopping is not included in this regulation. Before a recent change in the law in the spring of 2019, both pre-market and post-market testing on animals was required for a product to be physically sold in China. Justine Jenkins, a journalist for Glamour Magazine United Kingdom, defines pre-market animal testing as the testing of finished products before marketing and post-market animal testing as the testing of finished products after they have been approved for marketing. 


Chinese policy has been significantly influenced by campaigns such as Be Cruelty Free China, which is led by Humane Society International Beijing and Chinese activist partners. Be Cruelty Free China is the world’s largest campaign to end animal testing of cosmetics. Thanks to the spreading of awareness and campaigns such as Be Cruelty Free China, China is making progress. The requirement on post-market testing in China has been lifted; however, post-market testing is still permitted, and pre-market testing is still mandatory.  



Another regulation in China is that only the substances registered in the Chinese government’s “Inventory of Existing Cosmetic Ingredients” are authorized to be used in products sold in the country. This means that any new chemicals which enter the country are subject to animal testing, even if the chemicals were tested somewhere else. Foreign test data is occasionally not accepted by Chinese authorities.


One reason why activist organizations are so passionate about Chinese policy reform is due to the brutal torture which animals undergo during testing that often leads to death. As of 2014, Humane Society International estimates that 100,000 to 300,000 animals every year are used to test cosmetics in China. CFI estimates that approximately 115 million animals are tested on annually worldwide. When animals are used as test subjects, chemicals are dripped in their eyes, spread on their shaved skin, or even force-fed in large, lethal doses. During testing, the subjects are not provided with pain relief so that the animal’s reaction to the product can gauge the response of a human. The animals can be burned, blinded, shocked, poisoned, drowned, addicted to drugs, and brain-damaged. Experimenters implant wires into the animals’ brains and break their spines, just to name a few of the brutalities. Specifically, rabbits are used during the Draize eye test, which was designed to assess eye irritation caused by certain chemicals. During the Draize test, the chemical is placed in one rabbit’s eye, while the other eye serves as a control. The rabbits are restrained, which prevents them from reacting naturally and are observed in 24 hour intervals for up to 14 days. The rabbits suffer redness, ulcers, bleeding, and blindness; the subjects are killed at the end of the experiment. Another animal that is frequently a victim of testing is guinea pigs, who test for skin sensitization. In the Guinea Pig Maximization Test, chemicals are spread on shaved skin. Tests are highly subjective as conclusions are determined solely based on the appearance of the skin. Although hard to imagine, dogs are also prisoners in labs. Beagles in particular are often used due to their docile, trusting personalities and small bodies that are cheap to house in crates. In addition to these animals, other test subjects include mice, rats, and fish, all of which make great subjects in the eyes of researchers due to their short life cycles and simple body systems.



In addition to the fact that animal testing causes unbearable pain and torture, activists argue that it is ineffective. The National Institute of Health states that 95 out of every 100 drugs that pass animal tests fail in humans because chemical reactions cannot accurately be predicted in humans based on how animals react. Because of how inaccurate results can often be, activists argue that animal testing is a waste of money, time, and resources that could have been spent on human-relevant research. In addition to being ineffective, animal testing is undoubtedly an outdated method of research; there are a multitude of alternatives which provide more accurate results. These non-animal methods are known as “in vitro” testing (meaning “in glass”), where research is done using human cells and tissue. For example, Harvard has created “organs-on-chips,” which contain human cells that mimic the formation and function of human organs and organ systems. People for the Ethical Treatment of Animals (PETA) states that these chips can replace animals in drug testing, disease research, and more and have been proven to more accurately depict a reaction in a human than an animal would. MatTek Corporation, which constructs human tissue models, has engineered a product called the EpiDerm Tissue Model that replicates traits of normal human skin. The EpiDerm Tissue Model is used to replace animals who are either injected with substances or have chemicals applied on shaved skin to determine a potential allergic reaction. The goal of these alternatives is to replace animal tests by using knowledge of human biology.


Despite the abuse that animals suffer during testing and the various alternatives to this torture, China is disinclined to adopt other methods. Animal testing in the cosmetics industry in China is an extremely popular form of testing, and it is highly unlikely that it is going away any time soon. Erin Hill, President of the United States-based Institute of In Vitro Sciences, states that China is “completely behind the curve in learning about the new science.” Hill states that the shift from animal to non-animal testing methods is a big task that requires appropriate laboratories, people skilled in using alternative methods, and access to proper equipment and supplies. It will likely take many years to abandon traditional animal testing methods and convince Chinese officials that alternative methods are more effective. Once China is motivated to invest in alternative testing methods, Hill admits that there will be much time and money required to gain proper equipment and to train people to use alternatives. Many manufacturers argue that more research of alternative methods is necessary before making the transition due to the fact that the change is so expensive.


Although a complete ban of animal testing in China is highly unlikely any time soon, Chinese officials should be striving towards this legislative change. The Chinese cosmetics industry would tremendously benefit with a ban in animal testing, allowing foreign cruelty-free cosmetic companies to sell their products in China. Actions in the past by former cruelty-free cosmetic companies to sell in China (and therefore submit to animal testing) have led to boycotts of brands such as French cosmetics and skin care company NARS. NARS had been a cruelty-free brand until the company decided to start selling their products in China in June of 2017. Even though NARS products sold outside of China would continue to not be tested on animals, consumers were outraged. Hashtags such as “#BoycottNARS”, “#StopAnimalTesting”, and “#BloodOnYourHands” began trending. Many people accused NARS of valuing profit over ethics. Consumers are undoubtedly attracted to and support brands that promote in vitro testing and the well-being of animals. Thrive Causemetics, a 100% vegan and cruelty-free makeup brand based in California, attracts millions of consumers from around the globe with their moral mission of refusing to animal test. After a mere three years of launching, Thrive Causemetics began selling over $100,000 worth of beauty products daily in November 2016. 



Although the Chinese cosmetics industry would acquire the support and business of cruelty-free brands as well as millions of consumers if China accepted alternatives to animal testing and disapproved torturous methods, this process is unlikely to happen soon. As Erin Hill states, much time, money, and effort from Chinese officials, activist organizations, and consumers will be necessary for a substantial shift in testing methods to occur. A significant change in the abuses of animal testing will not occur until China invests in modern technology, proper facilities, and training to switch from animal testing procedures to in vitro testing.


Animal testing causes great harm to the well-being of animals and is frequently ineffective due to the differences in the bodily functions and systems of humans and animals. Activists argue that animal testing is a waste of time, money, and resources that could be directed towards useful research in effective alternatives and the development of even more precise, moral methods. In vitro testing methods are more accurate than animal testing, and consumers are inclined to support cruelty-free and vegan brands; however, China is unlikely to rush to adopt these alternatives due to the great time and money that the transition will cost.


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