The EU has banned animal testing since 2013. So, cruelty-free claims as applied to the EU are just a marketing gimmick.
The only companies who would be doing animal testing would be those using new technology or those that also have a pharmaceutical section of their business. For the vast majority of cosmetic companies, animal testing just isn’t done. Which is also why cosmetic products haven’t really changed significantly in over 30 years.
But if there is a new material that someone wants to use in a cosmetic product, for some aspects of safety there are not animal testing alternatives. You can see the list of validated animal testing alternatives as accepted by the EU. What this also shows is that for things like Aquatic bioaccumulation, Genotoxicity, Repeated Dose Toxicity, and Toxicokinetics there are no animal free alternatives.
I would add that cruelty-free does not mean free from cruelty. What it means is that the products weren’t directly animal tested. ANY company that uses plant based ingredients has been involved in directly killing animals (mice, rabbits, insects, etc). Numerous animals are killed during plowing, planting and harvesting of plants. They might not view this killing as cruel but I don’t see any difference.