Animal rights groups cautiously optimistic on EU roadmap to end “cruel toxicity tests”

The cosmetics industry’s push away from animal testing has reached a pivotal moment after the European Commission (EC) launched a roadmap to phase out animal tests in chemical safety assessments earlier this month. The plan marks the EC’s first official commitment to replacing these testing methods with non-animal science. 

The roadmap aims to replace animal tests for chemicals used in cosmetics and other products with alternative methods, without sacrificing safety standards for consumers or the environment. 

Dr. Emma Grange, director of science and regulatory affairs at Cruelty Free International, tells Personal Care Insights that the organization is “very encouraged” by the publication of the EC’s roadmap. 

“It promises to coordinate and steer pivotal groups and institutions across the EU, as well as create new organizational structures, all of which will be vital for progress to be made in the transition away from using animals in cruel regulatory toxicity tests,” explains Grange. 

However, roadmaps do not carry legal force, leading to lingering reservations about whether the EC will keep its promises. Additionally, legal and monetary gaps in the outline leave open-ended questions on funding and regulatory action. And yet, animal rights organizations are optimistic. 

“We know that the roadmap is not itself legally binding, but it should serve to drive the amendment and evolution of the EU’s regulatory framework. We know there is a lot of uncertainty around whether or not the key European chemicals regulation, REACH (Registration, Evaluation, Authorization and Restriction of Chemicals), will be revised, but we are encouraged by changes already made or underway,” says Grange. 

“Alongside legislative change, the roadmap should bring institutional change. Legislative change is fundamental to lasting change.” 

She adds that in an ideal world, it would take 10 years to remove all animal testing, but in reality, the timelines are likely longer.The EU roadmap aims to phase out animal testing in chemical safety assessments. 

Beauty’s cruelty-free integration

Cruelty Free International has been calling for this top-down governance “for a long time.” It calls the roadmap a direct response to its “Save Cruelty Free Cosmetics — Commit to a Europe Without Animal Testing” European Citizens’ Initiative. 

The animal protection non-profit took the initiative to the commission in 2023 with over 1.2 million verified signatures, which it says demonstrates “how important this issue is to so many people.” It brought together nonprofits, policymakers, scientists, and major global beauty brands, including Dove and The Body Shop. 

The EC’s new roadmap is built around three pillars to help phase out animal testing in Europe. The first outlines over 30 recommendations where stakeholders can replace, reduce, or refine animal use in safety assessments for human health and environmental tests. 

The second pillar aims to strengthen research and innovation in Europe, for example, by supporting scientists and businesses developing New Approach Methodologies (NAMs).

“Although we feel positive, we know the implementation phase will be critically important in translating promises to action,” says Grange. 

“We’ll be looking to the roadmap to boost investment and bring focused effort to bringing more non-animal methods into routine regulatory use for the testing of chemicals, including ingredients used in personal care products.”

Part of the EC’s pillar to strengthen NAM innovation in Europe is using AI to improve safety assessments, an approach the cosmetics industry has championed for years. 

“It’s still early days, but it’s clear that the use of AI has the potential to bring greater efficiency, consistency, and depth to chemical safety assessments,” Grange adds. 

She believes that AI could help reduce animal testing for personal care solutions even faster, and will be an important part of the delivery of the EC roadmap’s goals. “Exactly how, though, remains to be seen,” she says. 

As non-animal testing methods continue to advance, the beauty sector is increasingly being recognized for helping pave the way to wider NAM adoption. Regulators late last year cited the industry’s established use of alternative methods as a blueprint for other sectors. Non-animal methods are said to now be the default for skin and eye irritation tests. 

Industry and regulatory collaboration

The third pillar of the roadmap focuses on collaboration. The EC plans to work with EU member states, agencies, international regulators, and multiple industries to help implement alternative testing methods. 

Grange calls involvement and collaboration with the industry vital. “Industry in the EU will continue to play a crucially important role in shaping the future of toxicity testing and the legislative frameworks which govern it,” she says. 

“Making the most of all available non-animal approaches, such as through the adaptation of the standard information requirements under the REACH regulation, is a key way that the use of non-animal methods for making sound regulatory decisions can be demonstrated. This will encourage the eventual evolution of the regulatory framework itself.” 

In the short term, Grange says the organization wants to eliminate animal use in tests for skin and eye irritation, corrosion, and skin sensitization.

“The complete elimination of all toxicity testing on animals is a much longer-term goal, but over time, we want to see a steady supply of new non-animal methods coming into routine use for meeting regulatory needs.” 

“In tandem with this, we should see the evolution of the legislative framework itself, to eventually enable a full transition away from animal testing.”

Pushing for complete and clear frameworks 

For the first time, the EC has committed to replacing animal testing for chemical safety across the EU with human-relevant non-animal science. 

PETA UK says the decision will spare fish from being poisoned in lethal toxicity tests, pregnant rabbits from being force-fed chemicals through tubes, and rats from being forced to inhale chemicals. 

However, both PETA and Humane World note critical caveats: the roadmap does not cover all uses of animals in chemical testing, it’s not clear who will fund the next steps, and there’s no firm timeline for legal change. 

The ambiguity of where the funds will come from and how they may be insufficient could slow the roadmap’s progress. Additionally, without a firm timeline for legal change, outdated tests on animals will continue by default. Even under the new roadmap, tests on animals are allowed to continue wherever regulators say non-animal methods aren’t yet “acceptable.” 

“The timelines that have been set in the roadmap are ambitious, and we are happy to see that. However, we can also see that the commission has been very careful to limit its commitments to factors they are most likely to have control over,” says Grange. 

“We noticed that timelines are absent for the crucially important long-term elimination of all testing on animals. We know there is a lot of uncertainty in how long it is going to take to get to this ultimate goal, which is why, in the interim, we must see a rolling program of short- and medium-term targets which ensure momentum is maintained.”

Grange explains that the use of non-animal test methods can sometimes be impacted by factors such as a limited supply of materials and equipment, training needs, or capacity at testing laboratories. Cruelty Free International also acknowledges that not all companies are able to invest time and money into adapting standard regulatory information requirements to try and avoid testing on animals, especially smaller businesses. New Approach Methodologies could replace animal tests without lowering safety standards. 

“This is why the regulations themselves must be advanced without delay, so that there is clarity for all about when and how non-animal methods are to be used to supply regulatory information needs.”

Animal testing’s past and future

The replacement of animal tests is possible. Since the completion of the EU cosmetics testing ban in 2013, non-animal test methods have been established as viable methods for providing some vital toxicity data. 

The benefits gained extend beyond cosmetics. According to Grange, non-animal test methods for skin and eye irritation and corrosion, and for skin sensitization, are now the default methods required by regulations such as REACH. 

“Non-animal test methods have the potential to outperform tests using animals. For example, we know that defined approaches for testing skin sensitization, as detailed in the OECD Guideline 497, predict effects in humans more accurately than the Local Lymph Node Assay mouse test,” explains Grange. 

More cosmetic testing reforms are expected under the commission’s One Substance One Assessment (OSOA) initiative. It aims to prevent EU bodies from reaching different safety conclusions about the same chemical used in multiple industries. 

If the proposal is implemented, cosmetics brands could face earlier regulatory pressure to reformulate ingredients that are flagged as hazardous in other sectors. 

“We also anticipate beneficial changes to legislation and policy under the commission’s OSOA initiative — for example, better connections between the European Chemicals, Medicines, and Food Standards Agencies, as well as the creation of a Common Data Platform for Chemicals (CDPC),” says Grange.

“The CDPC will be looked after by the European Chemicals Agency, but will hold data relevant to many sectors.”

However, some members of the cosmetics industry have expressed their opposition to a hazard-based system, since the product reformulations it might require could risk disrupting supply chains.