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Cruelty free exemption
Hello friends,
A client wants to use the “cruelty free” claim. For that, he’s gathering letters from all his suppliers, that state that the ingredients were never tested in animals. However, big companies like BASF and Dow, made it clear that not only their ingredients were tested in animals in the past (only before 2013, which was the extended due date set by Cruelty Free International -CFI-), but that they are sometimes tested due to REACH or ECHA requirements (mainly, toxicology tests). Now, there seems to be some exemptions, according to CFI:
“Post-market
animal testing of a raw material or ingredient, that is not testing for
cosmetics purposes, and where that test is required by a regulator is
permitted. In this case, evidence that the testing is required by the regulator
(reference to regulations specifying the animal test and/or a specific request)
is needed. The Company is expected to use all reasonable means to challenge,
with the support of Cruelty Free International where appropriate, this
requirement”.So, if I’m not mistaken, everytime there is a test required from orgamisms like REACH and ECHA as long it is not for cosmetic purposes, it’s possible to test in animals and still comply with “cruelty free”, right?
There are two ingredients that puzzle me:
1) Cyclopentasiloxane, for wich Dow stated that they recently conducted an animal test (the reason for that study was “product stewardship”, which my client asked Dow for more clarification.
2) PEG-4 rapeseedamide, for which Kao said they conducted a Repeated Dose 90-Day Oral Toxicity (OECD 408) in 2014 but not for cosmetic purposes, which I believe was done for REACH registration, but I’m not quite sure.
So, I’d like to know if I’m understanding the CFI exemption for animal testing correctly, and if in the case of the two ingredients mentioned, they would still comply in your experience.
Thanks in advance!
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2 Replies
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ketchito said:…
So, if I’m not mistaken, everytime there is a test required from orgamisms like REACH and ECHA as long it is not for cosmetic purposes, it’s possible to test in animals and still comply with “cruelty free”, right?
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2) PEG-4 rapeseedamide, for which Kao said they conducted a Repeated Dose 90-Day Oral Toxicity (OECD 408) in 2014 but not for cosmetic purposes, which I believe was done for REACH registration, but I’m not quite sure.
…Correct.Oral toxicity can be for REACH/ECHA as well as for cosmetics (remember, many cosmetic ingredients weren’t invented by cosmetic companies and are therefore mainly used for other purposes than cosmetics)… however, both would be for reasons regarding consumer safety and hence be ‘cruelty free’.A ‘cruel’ product is/was usually a cosmetic product (pure chemical but mostly a mixture/final product) which is/was tested on animals (and most often could as well be tested on humans or in vitro) to ‘proof that it works as a cosmetic product’ (= cosmetics usually don’t work beyond what can easily be determined using human volunteers; drugs work and, unfortunately, require some animal testing).PS. Sorry for the many parentheses… my answer is really not easy to read. -
@Pharma As always, thank you for the clear and detailed explanation. It was very helpful!
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