Takehome: To avoid animal testing requirements international cosmetics companies can consider:
1) Setting up a manufacturing facility in China to manufacture non-special use cosmetics
2) Consider using CBEC, although the regulatory landscape in this sector is changing fast. In the next couple of years we can expect standard regulatory requirements to be the same as crossborder ecommerce.
3) Consider exporting raw materials or semi-finished products in bulk for repackaging in China.
4) There is some light at the end of the tunnel for cruelty free cosmetic companies as China recently approved an alternative to animal testing (see CL news).