The amendment of China’s top cosmetics regulation has drawn tremendous attention from not only the cosmetics industry but also from numerous NGOs, such as Human Society International (HSI) and Cruelty Free International (CFI), who are dedicated to promoting animal testing bans worldwide.
On behalf of a great many animal protection supporters and a number of large cosmetics companies who would like to enter the Chinese market but refuse to produce and sell animal tested cosmetic products, NGOs have taken the opportunity to propose the validation of non-animal testing to the CFDA through submission of detailed revision comments, as they see it is a pivotal moment for China to modernize its regulatory framework for cosmetics and align the animal testing policy with that of Europe, Israel and India, where such testing is banned for cosmetic products and ingredients.
Troy Seidle, HSI’s director of research and toxicology, stated that in addition to animal welfare considerations, their comments are also motivated by concerns for consumer safety, enhancing the competiveness of the Chinese cosmetics industry (which appears not to have sufficient access to the modern tools and methods for safety testing and assessment) as well as avoiding the trade barriers caused by regulatory disparity related to animal testing.
From the perspective of consumer health, Troy seidle said that animal testing is outdated and unable to serve as the “golden standard” for the safety of human health. He also pointed out that the conflict created by contrary animal testing policies of EU and China has hindered the cosmetic trade in both directions.Chinese companies cannot sell cosmetics in EU if they are already marketed in China and the European companies that want to maintain “cruelty-free” status cannot do business in China, either. Some cosmetic brands which stick to the attitude against tests on animals, such as LUSH and Urban Decay, pledged not to sell in China until the animal test requirement is removed. The animal testing issue has negatively impacted on cosmetics trade, and technology transfer between China and more developed industries, and hamper Chinese development with respect to advancing testing methodologies that are more efficient and economical than animal-based tests.
A total ban on animal testing in China will take time to achieve but should aspects of this initiative proven sucessful, safety assessment of cosmetics may move towards a more scientific direction and ethical direction and diminish animal suffering. Dr. Nick Palmer, CFI’s director of policy, suggested that safety testing should be based on the safety of the ingredients and the proportion present in the product to avoid an excessive burden on companies to have every finished product tested even when the safety of all ingredients have already been accepted. He also proposed that China should accept in vitro based OECD testing guidelines to assess the safety of cosmetic products and ingredients. Where companies can provide a complete product safety data file for products already marketed elsewhere, with all necessary OECD tests applied, this should be normally accepted without the need to repeat all tests, unless CFDA has particular safety concerns about the product. Moreover, Cosmetic products that do not make functional claims but can be shown to have passed these non-animal tests could be accepted for marketing. It is also expected that at least one laboratory capable of providing a set of non-animal tests could be approved and companies could then be permitted to entrust this lab to handle their applications.
Apart from the regulatory change, the full ability of labs to carry out those in vitro tests and the employ of necessary testing facilities are the driving forces of realizing the goal of cruelty-free. Early in 2011, CFDA announced plans to accelerate the construction of key laboratories for cosmetics which are required to focus on researching testing techniques for prohibited,restricted or safety-risk substances in cosmetic products and also develop faster testing methods. The alternatives to animal tests are also included in the research scope. At present, the National Institutes for Food and Drug Control is actively developing expertise in this area, but more regulators, experts and company scientists need training.
The CFDA official told ChemLinked that the draft of amended “Regulations on the Hygiene Supervision over Cosmetics” is planned to be published for comments at the end of this year. It is hoped that the new draft would leave room for acceptance of non-animal testing for cosmetics.
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