The only not-for-profit in NZ with its sole purpose to end animal experimentation
Cruelty-free Cosmetics

Cruelty-free Cosmetics

 Cruelty-free Cosmetics — Everything you need to know!

how far are you willing to go for beauty

Firstly we need to clarify something – The ban on the testing of cosmetics on animals in NZ that passed in March 2015 wasn’t a complete ban!

The ban means that no cosmetics can be tested on in NZ, but NZ companies could still pay for testing to be done overseas (although as far as we are aware this doesn’t happen). It also doesn’t prohibit the sale of cosmetic products that have been tested on animals in NZ; unlike the EU, India, Norway and Israel who already have a sale and imports ban (and this is already being proposed in other places around the world such as Canada and the US).

So despite what many misleading articles may say, New Zealand is not free from cosmetics tested on animals!

NZAVS were a part of the Be Cruelty Free campaign that helped make the ban on cosmetics testing successful. We teamed up with HSI (Humane Society International) for this campaign – they are also leading the BCF campaign globally and assisting other countries in transitioning towards a ‘cruelty-free’ status. NZAVS will be working with them later this year in the next step in the BCF campaign – to get a sales and imports ban in NZ! 




To help guide you on your path to living in a more ethical way, we have answered some of the frequently asked questions we get in regards to cosmetics:

Q: What are cosmetics?

A: Under NZ law, a cosmetic is defined as:

Any substance or mixture of substances used or represented for use for the purpose of beautifying, improving, protecting, altering, or cleansing the hair, skin, or complexion of human beings; and includes:

(a) any perfume:

(b) any deodorant:

(c) any insect repellant:

(d )any dusting powder

This is defined in the Medicines Act and also the Animal Welfare Act.

Note: Different countries have different definitions of cosmetics – this isn’t a universal definition. 

 Q: How can you tell if a cosmetic has been tested on animals?

A: As mentioned above, even if a cosmetic has been made in NZ, it doesn’t mean that it is cruelty-free. Companies can still pay for testing to be done overseas.

The best thing to do is to look for a cruelty-free certification, for example the “cruelty-free” beauty without bunnies certification by PETA, the leaping bunny certification from Cruelty Free International or the “Not tested on animals” certification by CCF (Choose Cruelty Free) – note all of these certifications have corresponding cruelty-free lists or aps that you can use (see below for more info).

See a comparison of these certifications here

You can also look at credible websites that have cruelty-free lists, such as:

– The PETA Bunny Free App

– The Leaping Bunny App

– The Choose Cruelty Free Lists

– The SAFE Shopper (the app can be downloaded onto your smartphone!)

– The Logical Harmony List (updated weekly)

(Note: Some of these apps and lists still include companies that have a parent company that test on animals and companies that use animal products in their ingredients)

Alternatively, you could do your own research and email the company you are interested in purchasing from. You can find a specific companies email address in their ‘contact us’ section on their website. The key questions we ask are:

  • Does your company test any of the ingredients used, or final products, on animals?
  • Does your company pay anyone else to test any of the ingredients used, or final products, on animals? (A sneaky way for a company to appear cruelty-free is say they don’t test themselves when they are paying someone else to do the testing)
  • Does your company have a parent company? If so who are they? (Sometimes cruelty-free companies are owned by companies that still test on animals)
  • Does your company sell its products in China? (If the answer is yes then the company isn’t cruelty-free as it is mandatory to test cosmetics on animals in China, often companies will claim “we don’t test on animals, unless required so by law” and that normally means that they sell in China).

Just because a company states that it is ‘against animal testing’ or is ‘cruelty-free’, it doesn’t necessarily mean that they, themselves don’t test on animals. Companies know that cruelty-free is becoming a more important factor for consumers, and more and more people are looking for the most ethical option. Instead of earning, and following through, with a cruelty-free claim, some companies choose to mislead members of the public into believing they are against animal testing using crafty, well written answers.

Example of this: Taken from the Nivea website:


“Beiersdorf, the organisation behind the NIVEA brand, does not test on animals… We believe animal testing is not required to prove the safety and effectiveness of our products. In China, however, animal testing is mandated by law for the official registration and certification of the safety of certain product categories. In this case, the tests are conducted by local institutions authorised by the state not by the companies selling the product.”

What this really means: “yes we test on animals because we sell our products in China where it is mandatory to do so by law, and pay for the testing as the cost is passed on to us by the Chinese regulators. Other companies do however exist such as LUSH who refuse to sell in China for this reason. The EU also won’t import any of our products that are tested on animals as the EU have a ban on importing any cosmetics that are tested on animals.”

If you are having trouble figuring out if a company supports animal testing on not, you can always ask us and we can help you find out! In cases like this email 

Q: Are there countries that legally require cosmetics to be tested on animals?

 A: Yes, as mentioned above the Chinese government conducts mandatory animal tests on all cosmetic products imported into the country. They also do random post market testing (which is often done without the company’s knowledge or consent). Hence, even if a cosmetics company does not test their products or ingredients on animals, if they sell their products in China they cannot be considered cruelty-free. Brazil also requires that some, but not all, cosmetics be tested on animals.

Note: Hong Kong is exempt from the mandatory animal testing for cosmetics requirement in China. Companies can still be cruelty-free if they sell in Hong Kong and not the rest of China.

Q: Do all cosmetics sold in China get tested on animals?

A: Previously all cosmetics that were sold in China had to be animal tested and also had to be subject to random animal testing once they are for sale.

Now, there have been some small changes and if a cosmetic is produced in China for the domestic market only, and is in the list of ordinary cosmetics (hair care, nail care, skin care, perfumes and make-up but not products for hair growth, hair dye, hair perm, hair removal, breast shaping, fitness, deodorizing, spots removal and sun block; cosmetics with skin-whitening and skin pigmentation reduction claims) then the cosmetics no longer have to be tested on animals. These products are still however subject to the random post market testing.

Any cosmetic being imported into China however still has to be tested on animals.

To read more on cosmetics testing in China and the recent update go here or here

Cruelty-free companies stay clear of selling in China (even if they can be manufactured in China) because of the random post-market animal testing of cosmetics.

Q: How do cruelty-free companies get their products on the market?

A: Companies can ensure the safety of their products by choosing to create them using the thousands of ingredients that have a long history of safe use. Companies also have the option of using existing non-animal tests or investing in and developing non-animal tests for new ingredients.

For examples of these non-animal methods go here

There are so many amazing cruelty-free cosmetics companies around the world, if they can do it then big companies like MAC, L’Oreal and Proctor and Gamble can too!

Some of our favourite cruelty-free companies include:


– Rovie

– Living Nature

– Australis

– Sukin

 Q:Why does animal testing for cosmetics still happen? 

A: From a global point of view, the only countries that require animal testing by law are China and Brazil. The FDA don’t require any animal testing for cosmetics – “Under the FD&C Act, cosmetic products and ingredients, with the exception of colour additives, do not require FDA approval before they go on the market”.

So even in America animal testing for cosmetics isn’t required by law.

Why do companies still do it then?

– To protect themselves from a lawsuit if something goes wrong

– So that they can sell in China and Brazil.

– If a company is creating new cosmetics in the United States, Canada or Brazil (and various other countries that have no ban) and they want to use genuinely “new” ingredients in the production of cosmetics, animal testing will almost certainly take place.

Q: What is so bad about testing cosmetics on animals?

A: Putting aside the huge ethical dilemma involved in this issue, these (like all other animal-based tests) have scientific limitations because different species can respond differently when exposed to the same chemicals. Because of these many differences between species, results from animals can’t be accurately applied to humans.

In addition, results from animal tests can be quite variable and difficult to interpret (often the different tests are quite subjective and depend on how the researchers interpret different reactions and observations).

Unreliable and ineffective animal tests mean consumer safety cannot be guaranteed. In contrast, non-animal alternatives can combine human cell-based tests and sophisticated computer models to deliver human-relevant results in hours or days, unlike some animal tests that can take months or years. Non-animal alternatives are also typically much more cost-effective than tests that use animals.


 An example of unreliable animal tests for cosmetics is the Draize test

The Draize test is a test normally done on rabbits to measure the potential eye and skin irritation and corrosion caused by a substance.

The use of Draize test data to predict human ophthalmic risk is imprecise because there are significant structural and physiological differences between rabbit and human eyes:

  • Rabbits have a nictating membrane (third eyelid)
  • Rabbits produce tears less effectively than people
  • The pH and buffering capacity of the aqueous humour is different – human aqueous humour has a pH of 7.1 – 7.3; rabbits have a pH of 8.2
  • The cornea is 25% of a rabbit’s eye surface area, for a human it’s 7%

Due to these differences, Draize data correlates poorly with real human responses.

For example, researcher Freeberg reported 281 human ocular toxicity exposures to 14 household products, and they compared the findings to Draize test results. The human experiences differed from the Draize results by a factor of up to 250. The closest correlation differed by a factor of 18. [1]


Despite humans using the Draize test for many years, it has been noted in scientific literature that  “the widely used Draize/FHSA rabbit eye irritation test has never been validated against any reported human database.”[2]

Note: NZAVS campaigned against the Draize test and successfully got the requirement removed for Draize test data for any hazardous substance from NZ law. 

 Q: How can you help end the testing of cosmetics on animals?

A: There are many different ways you can help make this happen:

– Don’t buy cosmetics that have been tested on animals (do your own research and make an effort to avoid companies that do test)

– Email or write letters to companies that you know test on animals, ask them to be cruelty-free!

– Educate your friends and family about what products are cruelty-free

– Keep up to date with our campaigns and support the Be Cruelty-Free campaign

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If you have a question that wasn’t answered, please don’t hesitate to send your question to 


[2] Griffith JF, Freeberg FE: Empirical and experimental bases for selecting the low volume eye irritation test as the validation standard for in vitro methods. In: Goldber AM (Ed): In Vitro Toxicology: Approaches to Validation. New York, Mary Ann Libert, 1987, pp. 303-311.

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