Can cosmetics brands enter the Chinese market and still be considered cruelty-free? What is the risk of post-market animal testing? Which brands can consumers trust to maintain their cruelty-free status? In this guide, we explore the most pressing questions surrounding the current situation in China’s cosmetics industry.
Much of the valuable insight for this article comes from our discussions with Knudsen & CRC, a Shanghai-based regulatory compliance firm helping companies remain cruelty-free under the new Leaping Bunny China Qualification Program.
The Evolution of Animal Testing Regulations in China
Historically, it was nearly impossible for cosmetics brands to sell in China without complying with mandatory animal testing. Fortunately, the landscape has improved as China has progressively relaxed its animal testing requirements for cosmetics.
In 2014, China took a pivotal step by allowing certain cosmetic products manufactured domestically to bypass animal testing. This created a loophole for Western brands, enabling them to move parts of their production to China—typically bottling or filling processes—while retaining their cruelty-free status.
An even bigger milestone came in 2021 with the implementation of the Cosmetic Supervision and Administration Regulation (CSAR). Crucially, this regulation conditionally removed the pre-market animal testing requirement for imported general cosmetics.
However, after CSAR’s introduction, many Western brands quickly entered the Chinese market, only to realize that navigating the new regulatory framework was far more complex than expected. While Europe is often seen as a challenging market for foreign brands, China’s regulations have proven even more stringent.
Main takeaways from the article:
- Does China still require cosmetics to be animal tested?
Animal testing is still required for special cosmetic products, such as sunscreens, hair dyes, skin-whitening, and anti-freckle treatments. However, most general cosmetics (like daily makeup, skincare, haircare, and perfume) are exempt from this requirement. - How does animal testing occur in China?
Animal testing can take place during the product registration phase (pre-market animal testing) and, in some cases, after the product is already available for sale in stores (post-market animal testing). - Can a brand enter China without pre-market animal testing?
Yes, a brand can avoid pre-market animal testing if its products meet certain conditions. For example, the product cannot make efficacy claims, must not contain unregistered ingredients, and must not be designed specifically for children. - Can a brand avoid post-market animal testing in China?
Yes. Post-market animal testing is not a standard procedure and is only required if the product is suspected of posing a serious risk to public health. In such cases, the company can opt to recall the product rather than subject it to animal tests. - How can consumers trust that a brand remains cruelty-free in China?
The only reliable way to ensure a brand stays cruelty-free in China is by verifying if it is part of the Leaping Bunny China Qualification Program. This program guarantees that the brand does not conduct pre-market or post-market animal testing in China. - Is there hope for an animal testing ban in China?
Yes, there are several factors pushing toward a complete animal testing ban, including the Chinese government’s sustainability initiatives and a growing interest in cruelty-free products among Chinese consumers and domestic cosmetics brands.
How Can Animal Testing Occur In China?
Animal testing in China can occur at two different stages: pre-market animal testing and post-market animal testing.
- Pre-market animal testing happens during the product registration phase, where a cosmetic product is tested on animals before it is sold to consumers.
- Post-market animal testing occurs after a product is already available in stores, typically triggered by reports of widespread adverse reactions.
It’s important to clarify that Chinese authorities do not directly conduct animal testing. Instead, animal tests—also known as toxicology tests—are simply the preferred method for proving product safety in China. Ensuring a product’s safety is entirely the responsibility of the brand.
As of 2024, cosmetics brands can avoid both pre-market and post-market animal testing in China. To bypass pre-market testing, brands must submit extensive documentation to demonstrate compliance with CSAR requirements.
Post-market animal testing only takes place in response to widespread adverse reactions. In such cases, companies have the option to recall the product or prove its safety through alternative testing methods, rather than resorting to animal testing.
Staying cruelty-free in China is challenging but achievable with sufficient dedication. The product registration process is lengthy and complex, and companies may not be able to bring their entire product line to China. However, maintaining cruelty-free status in the Chinese market is possible.
Can Cosmetics Brands Enter China Without Pre-Market Animal Testing?
Yes. As of May 2021, cosmetics brands are able to enter China without the previously mandatory pre-market animal testing requirement. For imported cosmetics to be exempt from pre-market animal testing in China, the brand needs to comply with these five rules:
- The brand must have a GMP certificate – Good Manufacturing Practices (GMP) is an internationally recognized standard that ensures cosmetics meet essential safety and quality requirements. The GMP certificate is issued by the brand’s country of origin.
- The brand must appoint a Responsible Agent (RA) – A Domestic Responsible Agent is a local Chinese entity responsible for ensuring the safety of the products. Having a Responsible Agent is a mandatory step before applying for NMPA Product Registration.
- The products cannot claim new efficacy – ‘General cosmetics’ can enter the Chinese market without animal testing. However, ‘Special cosmetics’ that claim new efficacy, such as sunscreens, hair dyes, skin-whitening, and anti-freckling products, are still subject to animal testing.
- The products cannot include new ingredients – To avoid animal testing, imported cosmetics must not contain any ‘New Cosmetic Ingredients’—ingredients not listed in the Inventory of Existing Cosmetic Ingredients in China (see China CosIng).
- The products cannot be marketed to children – Cosmetics aimed at childcare or babycare are still required to undergo pre-market animal testing, with no exceptions.
The official GMP certificate is the primary requirement for avoiding pre-market animal testing for general cosmetics. Since GMP certification can only be issued by the regulatory authorities in the brand’s country of origin, Knudsen & CRC works closely with governments to help cosmetic brands obtain this certification.
Appointing a Domestic Responsible Agent (RA) is another crucial step for cosmetics companies to register their products in China without animal testing. Responsible Agents are typically Chinese distributors or consultants, serving as legal entities registered within China.
These agents are held to strict standards by the authorities and bear significant liability for product safety. If an RA has previously violated laws related to product quality or safety in China, they will not be exempt from animal testing requirements.
While appointing an RA can be challenging, the biggest hurdle for companies is avoiding ‘New Cosmetic Ingredients.’ The current list of approved ingredients in China includes fewer than 10,000, which poses a significant limitation. By contrast, the U.S. list contains approximately 30,000 ingredients.
However, if an ingredient has been on the Chinese market for more than three years, it is no longer considered “new” and will automatically be added to the IECIC (Inventory of Existing Cosmetic Ingredients in China). This is currently the best way to get ingredients registered without animal testing.
Knudsen & CRC’s long-term goal is to help introduce new cosmetic ingredients into the Chinese database without the need for animal tests. They are actively seeking ingredient suppliers to collaborate on a pilot project to achieve this.
Can Cosmetics Brands Stay In China And Avoid Post-Market Animal Testing?
While pre-market animal testing in China is relatively well understood, post-market animal testing continues to raise concerns. Given the fears and misconceptions surrounding it, we want to clarify the key point:
Yes, imported cosmetics can avoid post-market animal testing in China. Chinese authorities do not conduct routine animal tests on cosmetics. The decision to test a product on animals is always in the hands of the company.
If a product is deemed to pose a risk to consumer health, Chinese authorities may request proof of its safety. In such cases, the company can opt to recall the product rather than resorting to animal testing.
A common misconception is that Chinese officials conduct animal tests on products without the company’s knowledge or consent. This is simply not true.
Animal testing is costly and requires 10-20 product samples, and the Chinese government has no incentive to perform these tests. The responsibility for proving a product’s safety rests solely with the company.
How Can Post-Market Testing Occur?
Post-market animal testing in China is quite rare, especially for general cosmetic products. The risk of post-market animal testing arises only if there is a widespread adverse reaction to the product, such as an allergy or rash.
For post-market animal testing to be considered, multiple customers must report adverse reactions. According to Knudsen & CRC, a single report is insufficient; the government requires several testimonies before taking action.
Under the new regulatory framework, retailers and distributors are legally obligated to report all adverse reactions. Additionally, Chinese consumers are proactive in monitoring product safety, with Knudsen & CRC noting that approximately 90% of adverse reaction reports come from Chinese consumers.
If officials gather enough evidence to question a product’s safety, they may request proof of its safety from the company. In such cases, the company has three options:
- Recall the product – This is the best way to avoid animal testing. Since adverse reactions are often highly publicized, a recall can also help mitigate damage to the brand’s reputation.
- Use alternative testing methods – Methods such as in-vitro testing may be accepted by the authorities, offering a way to keep the product on the market without resorting to animal testing.
- Perform toxicology tests (animal tests) – While toxicology tests are the most definitive way to demonstrate safety and may be specifically demanded by officials, choosing this option means the brand can no longer be considered cruelty-free.
The good news is that China has started to accept alternative testing methods for proving product safety. But as it is still not a guarantee, recalling a product from the market is still the surest way to stay cruelty-free in China.
How Can Consumers Trust The Brand Stays Cruelty-Free In China?
While companies can avoid animal testing in China, consumers are still faced with a problem: how do we trust the company has not tested on animals? How do we know they have recalled a product instead of providing animal tests?
The only way to trust the company stays cruelty-free in China is if they enter China through the Leaping Bunny China Qualification Program. It’s the only program that performs an extensive pre-market audit and yearly post-market audits to make sure the company is fully cruelty-free.
The Leaping Bunny China Qualification Program is a partner program between the Leaping Bunny Certification Program and Knudsen & CRC – a Shanghai-based regulatory compliance firm that works to end animal testing in China as part of their CSR efforts.
So if a Leaping Bunny-certified brand chooses to enter China, Knudsen & CRC oversees all their paperwork to see whether the market entry is being done without animal tests. Knudsen & CRC will also be able to advise the brand on how to navigate the CSAR framework.
As the most crucial part, Knudsen & CRC will gain access to China’s Adversary Action Reporting. They see if the Chinese government has demanded proof of product safety from the company and how the company has responded to it. These post-market audits are performed every year.
Hopefully, we will see many more similar qualification programs in the future even though the entry threshold to the program is high. External certification programs are essential to maintaining customer trust – especially when a brand operates in a highly regulated industry like China.
Is There Hope For An Animal Testing Ban In China?
Along with the open policies implemented in China since 2023, the hope for an animal testing ban is very much alive in China. Countless organizations, including Knudsen & CRC, are working relentlessly to end animal testing in China for good.
With its new Clean Beauty Standard, China is showing its commitment to sustainable cosmetic products that are eco-friendly and animal-friendly with an open and transparent product cycle. Social equality is also an important part of China’s sustainability efforts.
The drive towards an animal testing ban comes also from young Chinese consumers who much prefer cruelty-free cosmetics. According to Knudsen & CRC, Chinese cosmetic companies are also interested in obtaining a cruelty-free certificate to stay competitive in the global market.
“Chinese companies want to become the world leader in cosmetics. They want “made in China” products to become synonymous with quality and sustainability. They know they cannot achieve that when they test on animals,” says Mette Knudsen, the founder of Knudsen & CRC.
According to Knudsen & CRC, the Chinese government has been actively seeking alternative testing methods to animal testing. Some labs in China are already working with US-based Institute For In Vitro Sciences in replacing toxicology tests with alternative non-animal tests.
To predict the future, we also need to look into the past. The animal testing requirement for imported cosmetics was also established to stop the entry of kitchen sink cosmetics brands that were hazardous to public health.
Once alternative testing methods can prove a product’s safety as well as animal-based toxicology tests, animal testing will surely be a thing of the past in China.
For more information about animal testing in China and the Leaping Bunny China Qualification Program, see our full interview with Knudsen & CRC and Leaping Bunny.
Summary
China is the second-largest cosmetics market in the world and we understand the pressure on brands to enter this country rather sooner than later. Thanks to the new regulations of 2021, cruelty-free brands can now enter China and stay cruelty-free.
Cosmetics companies can avoid pre-market animal testing if they comply with the new requirements. Companies can also avoid post-market testing if they are ready to recall the product if the government should demand proof of product safety.
For customers to trust the brand has stayed cruelty-free in China, we recommend companies enter China per Leaping Bunny China Guidelines. It’s the only program that ensures the company avoids animal testing when entering China and while they are there.
We hope our guide gave you useful insight into the animal testing laws in China. Contrary to what Westerners might assume, the laws and regulations in China are changing lightning-fast. We will keep this article updated with all the newest information.
See also: Leaping Bunny China Qualification Program: What Is It And Can We Trust it?
