What beauty brands need to know about animal testing in China

China is the world’s second-largest beauty market after the United States. According to the Hong Kong Trade Development Council of China, the Chinese beauty market was worth US$39 billion last year. But many international brands have had to give up on entering China due to its policy of carrying out mandatory animal testing on all imported cosmetics, a policy that was imposed in 2012.

Over the past few months, however, rumours have been flying, with people speculating that China has – or is about to – lift this policy. But what is fiction and what is fact? Could cruelty-free brands finally be able to market to Chinese consumers?

In this post, we’ve trawled through the hearsay and the evidence to bring you the truth on this important issue.

But first, some background:

China’s stance on animal testing for cosmetic products

While consumer pressure in Western countries has meant that, since the late 1990s, most beauty brands in the US, Europe and Australia have moved away from using animals to test cosmetic products, China is one of the few countries in the world where animal testing on beauty products is mandatory, both pre- and post-market. This means that the government is able to take products that are already being sold on the shelves, and perform animal testing on those products, and brands who want to enter the Chinese market must agree to this. This policy has been viewed by the Chinese government as the best way to ensure consumer safety.

In recent years, however, China has slowly been moving away from animal testing, showing a desire to implement international standards in this area, and pave the way for cruelty-free brands to enter their market. In 2014, China ended mandatory testing for domestically manufactured ‘non-special-use’ products, such as shampoo and perfume (‘special-use’ products include hair dye, hair removal products, anti-perspirant deodorant and sunscreen). Another major milestone was reached in November 2016 when the China Food and Drug Administration (CFDA) approved the use of a non-animal test for the safety assessment of certain cosmetic ingredients.

What has this meant for beauty brands?

This policy has of course been a particular concern for cruelty-free beauty brands, who risk reputational damage by entering the Chinese market where animal testing can be very difficult to avoid. Even celebrities like Ricky Gervais have called for consumers to boycott brands who expand to China.

This leaves beauty brands with essentially four options:

Enter the Chinese market anyway

For many beauty brands, the Chinese market is simply too big to ignore, and they have entered the market anyway. This has resulted in brands like L’Occitane, Yve Rocher, Caudalie and Mary Kay having their Leaping Bunny logo (the only internationally recognised symbol guaranteeing consumers that no new animal tests were used in the development of any product displaying it) removed.

Entering the Chinese market does risk upsetting consumers, however. To help address consumer concern, L’Occitane have published a statement on their website, which states that while L’Occitane is “fundamentally against animal testing of beauty products on a worldwide basis”, they do acknowledge that animal testing does occur in China – though they are at pains to make it clear that it’s not L’Occitane that conducts these tests, but rather the local authorities. They also talk about “developing its relationships” and opening “constructive dialogue” with the Chinese authorities to help end animal testing in the region. “We remain convinced that this open dialogue with Chinese organisations will further influence Chinese regulation and put an end to animal testing once and for all,” the statement ends.

Other companies who have tried this route have found the backlash too much to handle. In 2012, when Dermalogica entered the Chinese market, the Coalition for Consumer Information on Cosmetics (CCIC) removed its Leaping Bunny certification. Dermalogica promptly extracted its products from the market in order to regain this certification, stating it “has no intention of selling products in China until it can do so without the need for animal test data”.

Manufacture products in China

The changes to the policy in 2014, ending mandatory testing of locally manufactured ‘non-special-use’ products, has opened up another option for international beauty companies: manufacture products in China.

This is precisely what American beauty brand Nudestix have done, setting up their own supply chain in the country in order to ‘bypass’ mandatory animal testing, thereby allowing them to retain their cruelty-free status.

This option, however, is both expensive and murky – not only do companies require extensive resources to set up manufacturing in China, but while companies may be able to avoid pre-market testing this way, there’s no guarantee that they can avoid post-market testing, meaning their products may still be tested on animals.

Sell them online or through the Daigou market

Another potential loophole is that cosmetic products sold online are not subject to animal testing. This means brands can sell their products via e-commerce platforms and online stores in China. This of course comes with its own limitations, as consumers might not view online-only brands as favourably as those they see on store shelves. However, this might be a good way for brands to feel out the Chinese market in preparation for when policies become relaxed enough for cruelty-free brands to enter the market in earnest.

The other, less advisable route is selling products via the Daigou or ‘grey’ market, though this can be fraught with complications and can also have a detrimental effect on your brand image. Most brands who have tried this route soon give up.

Stay out of the Chinese market until mandatory animal testing is lifted

As you can see, all the options for entering the Chinese market have their downsides. Many brands have opted to simply bide their time and wait for the policy of mandatory animal testing of cosmetic products to be lifted, so they can enter the market responsibly without risking their cruelty-free certification or reputational damage.

How has the policy on animal testing changed?

It’s important to note that mandatory animal testing on cosmetic products has not been completely lifted – not yet at least. There have been some promising steps, however, that show China is serious about moving towards more ethical practices.

In November 2018, Cruelty Free International (CFI) announced a ground-breaking pilot program, in partnership with Knudsen&Co and Fengpu industrial Park, to enable Leaping Bunny certified companies to enter the Chinese market while staying true to their cruelty-free ethos. The first companies to be part of this venture are long-standing Leaping Bunny brands Bulldog Skincare, Neal’s Yard Remedies, Seventh Heaven and Subtle Energies.

Mette Knudsen, CEO of Knudsen&Co, said: “The Chinese government is already working hard to implement relevant policies. I believe that there will be a big change in the next few years. I hope that through this opportunity, we can gradually eliminate animal testing with CFI and promote cruelty-free international brands to Chinese consumers. At the same time, we hope that media, consumers and cosmetics companies will see the Chinese government and related animal protection organizations making great efforts to eliminate animal testing.”

And in January 2019, the CFDA issued a new regulation that allowed some new cosmetics to undergo a simplified registration process when imported through Shanghai, which potentially means these cosmetics would not be subject to China’s mandatory requirement for animal testing on imported cosmetics.

“Although the new regulation is currently limited in time and scope, we welcome this as the next step in China’s move away from cosmetics animal testing and towards a harmonised global cruelty-free market,” said CFI in response.

What should beauty brands do now?

While there have been very encouraging signs, China’s regulations are not quite at the point where companies can be completely sure their products aren’t going to undergo animal testing.

Our advice? Watch this space.

In the meantime, beauty brands can start preparing to move into the market so when the time comes when they can feel confident about retaining their cruelty-free status, they can move swiftly. This means setting up a strong online presence, including a localised and optimised website, so you can move ahead of your competitors.

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