Animal Testing for Cosmetics in China – It’s Complicated!

Products sold in China via e-commerce do not require (regulatory) animal testing. Companies selling in China but only via this method do not currently require regulatory animal testing.

Cosmetics sold directly in Hong Kong or Taiwan also don't need to be tested on animals.

Therefore, companies selling in China but only via these methods can still be cruelty-free.

For other distribution channels, products must fulfil certain requirements to avoid animal testing.

Expert Advice

According to Choose Cruelty Free (now Cruelty Free International), animal testing does not occur via e-commerce channels. Companies that sell into China via e-commerce can meet their cruelty-free standards as the products are sold directly to the consumer and therefore do not require regulatory animal testing.

The PETA Beauty Without Bunnies Liaison confirmed with multiple sources that Chinese authorities do not use animal testing for post-market testing and have not done so in the past. Instead, authorities sometimes pull products and do an analysis of ingredients to make sure the ingredients are exactly as they’re listed.

The Humane Society International told us that some e-commerce products could avoid pre-market animal tests, and the likelihood of post-market animal test is very low. However, there is no documented evidence that animal testing won't occur.

E-commerce is an emerging market so the policies and rules around cosmetics and animal testing could change in the near future.

Updates to Law

Updates to Chinese law concerning cosmetics now make it possible to register to sell domestically in China and avoid animal testing.¹

Several specific requirements need to be met, and the information available on the website of the responsible Chinese government agency is quite complex.²

But based on information from the Leaping Bunny,³ as of May 2021, products can be exempt from pre-market animal testing if:

• they do not have efficacy claims to them (like teeth whitening products, sunscreen, or hair dye).
• they are marketed for adults, not specifically for children or pregnant people.
• they only contain ingredients that are known and accepted by the Chinese authority.
• the company (and their suppliers) have a certificate of Good Manufacturing Practice from their local government.
• the local Responsible Person shall not be listed as a key supervision target (i.e., cannot have a criminal record or any open investigations).

It's possible for companies to sell in China and avoid animal testing by seeking the help of experts:

• The Leaping Bunny China Qualification Program, in cooperation with Knudsen&CRC (based in Shanghai), offers guidance and supervision for entering products in the Chinese market and maintaining cruelty-free status.⁴‍
• In dedication to cruel and unnecessary animal testing, Knudsen&CRC are offering to screen the ingredients list of cruelty-free brands free of charge, as there is no actual “accepted ingredients list”. The information has to be gathered individually about each ingredient.

Our Position

We include companies in our Cruelty-Free Guide that sell cosmetics in China via methods that do not require animal testing, but if laws change and we find evidence of animal testing occurring, then these companies will be removed from our guide immediately.

More Info

What are cosmetics?

In China, cosmetics are considered “daily used chemical products applied on the surface of any part of the human body (such as skin, hair, nails and lips) by way of smearing, spraying or other similar methods to keep the body clean, to get rid of undesirable smells, to protect the skin, to make up the face and to increase the beauty of the appearance.”

Cosmetic products in China are divided into two categories.⁵

1. Special use cosmetics: Whitening products, hair growth products, hair dyes, hair perming products, depilating products, breast beauty products, slimming products, deodorants, freckle-removing products, and sunscreens.
2. Non-special use cosmetics: Everything else! I.e. non-special use shampoos and lipsticks.

Are there any other exceptions to animal testing requirements?

Apart from selling products to China via e-commerce only, there are a few other exceptions:

• If a company only sells products in Hong Kong⁶ or Taiwan,⁷it can avoid animal testing. While both have not banned animal testing of cosmetics, they do not require them either.

So what cosmetic products still require animal testing by Chinese law?

• Special-use cosmetics: these have efficacy claims, like hair dye, hair perms, anti-freckle and whitening products, sunscreen, and anti-hair loss products; products for children are also classed as special cosmetics.
• Cosmetics using materials that are not part of the accepted list.
• Products by companies who are not certified as following Good Manufacturing Practices by their local government.

What about products that aren’t cosmetics?

If a product is not considered a cosmetic, whether animal testing will be required depends on relevant regulations. For detergents, usually, animal testing will not be involved.

Toothpaste is a special case. It is included as a cosmetic. Further testing will be required if it has additional claims like whitening.

*This information is based on the advice of multiple experts and in-depth research at the time of publication. Information is subject to change as new facts emerge and filter through from the China market.