Back in March 2019, animal activists and cruelty-free shoppers rejoiced at the news that China was taking strides to accept alternative testing options to replace animal testing for cosmetics. This excitement created an onslaught of incomplete information hitting the beauty world news causing the misunderstanding that animal testing in China was ending. I hate to be the bummer to tell you that’s NOT the whole story.

(NIKKI MOMENT! The fact that you are reading this article means you give a shit and are wanting to take action through the incredible power you hold with where you place you money. That’s so incredible! Every day we are learning more and more about how we can do better. Never look backward and feel bad. Your integrity comes from learning and becoming more of who you strive to be. NO shame. NO guilt)

Firstly, we need to let go of the idea of black and white around this. Your ethics are black and white to you, but everyone shows up with their own ideals and beliefs. Pick a topic; climate change, vaccines, cancer cures, diet culture. Polarized views are part of the social experience. Black and white simply doesn’t exist in a world where different beliefs, countries, laws (and their loopholes), business, ethics, and profit all intersect. My intention with this article is to bring you the clearest, most accurate information I can so you can make the best decision for yourself.

I’ll do my best to break this down for you as it stands as of January 1, 2020. OK, deep breath. To create more clarity, I’m going to have to bring you back to 2012 when PETA blew the lid off the dark, unknown side of the cosmetic industry. We simply didn’t understand that animal testing is MANDATORY (to certain products… I’ll explain, hang on!) in China (other countries too). So we discovered companies who “don’t test on animals” chose TO PAY the Chinese government to have their products tested on animals in order to have their products available in one the world’s biggest retail markets. To give you a scope of the magnitude of this market, Oct 2018 to October 2019 cosmetic retail trade revenue was worth 315 Billion Yuan. For those not familiar with that currency, it converts to almost $60 Billion CAD. With that huge of an opportunity, some brands decided to justify their choices to participate in animal testing while still claiming they are against animal testing. But… I digress.

Fast forward to 2014. The EU (European Union) put the pressure on the Chinese government to move toward alternative options to animal testing while still supporting everyone’s compliance needs for different markets. Progress! Well, actually, It turns out not so much. As much as they appeared to be in cooperation, they lobbied against the EU ban, leaving the internet full of bad information that was put out prematurely, further dirtying the waters of transparency.

So here’s some information I pulled together to help you understand how the laws work, what changes came about in 2019 (in effect January 1. 2020) including which alternative testing (in vitro*) practices are being introduced and how China categorizes products to decide when testing is required.

China broke things down into sections that are fairly straight forward, yet somehow overly complicated

Cosmetic products were split into two categories:

  • Ordinary products – is the label given to makeup, perfumes, skincare, general hair care and nail products.
  • Special use – for products that make a claim on the label. It’s a bit ambiguous, but from what I have gathered it included things like skin whitening products, hair color, sunscreens, and others.

Where they are made and where they are going:

  • Domestic (made and sold in China)
  • Imported (made elsewhere, and sold in China)

What stage of production the product is in:

  • Pre-market: This is the process of getting a product cleared by China’s Food and Drug Administration (“CDFA”) to bring it to market
  • Post-market: Random testing by the government for products already on the market

So what IS the progression of change that happened from 2014 to 2020?

I found these great easy to read tables from Sarah at Lumabelle to help you understand it with a bit more ease. Her article goes into more detail about exceptions, loopholes as well as more stats around how many animals are tested on. It’s a deeper exploration if you want that.

These mandatory law changes are a step in the right direction, especially when they are combined with the decisions to bring alternative testing methods to their compliance process. This release from The Institute for In Vitro Sciences (IIVS), a non-profit organization wholly dedicated to the promotion of non-animal test methods, shows China’s National Medical Products Administration (NMPA) acceptance of CERTAIN non-animal (alternative) test methods for the regulation of cosmetics. Progress! But we still have a long way to go.

To be very clear,

  • YES animal testing still part of the compliance process for post-market cosmetics of either category (ordinary or special use) being imported to China.
  • YES NMPA ( National Medical Products Administration ) has accepted some new non-animal test methods as preferred toxicological tests for the registration and pre-market approval of cosmetic ingredients.
  • YES the number of animals being harmed is decreasing, but these numbers are negligible when looking at the whole picture.
  • YES if a company is truly committed to transparency to ensure cruelty-free status, they will not physically sell China (exceptions include Hong Kong or e-commerce sales direct to customer).

A Few Final Thoughts

One of the challenges people face most out is trying to figure out if brands (and the companies that own them) they enjoy using are testing on animals or if they do engage in the practice by choosing to sell in countries where it is mandatory by law.

Things to consider are

  • companies who state that they do not test on animals ‘except where required by law’ is often an indication that they sell in China
  • PETA has Beauty Without Bunnies data base as an easy search resource for brands they trust
  • Leaping Bunny was created when national animal protection groups banded together to form the Coalition for Consumer Information on Cosmetics (CCIC). The CCIC promotes a single comprehensive standard and an internationally recognized Leaping Bunny Logo. They work with companies to help make shopping for animal-friendly products easier and more trustworthy.
  • Cruelty-free is referring to practices around product safety and compliance testing. Products that are cruelty-free means they aren’t tested on animals, not vegan.

*In vitro comes from the latin term “in glass”, therefore test tube.

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