Ever since China removed its pre-market animal testing requirement from imported general cosmetics in 2021, Western brands have been quick to enter the Chinese market. After all, China is the second-largest cosmetics market in the world.
But as animal testing practices are still common in China, customers have become increasingly concerned about whether brands that sell in China are conducting animal testing or not. The threat of post-market animal testing worries people the most.
What doesn’t help the situation is that companies like Paula’s Choice have gone to China without a public announcement and kept their customers in the dark about their cruelty-free status.
When people contacted Paula’s Choice on the matter, the brand responded by saying: “Don’t worry, we are still cruelty-free as we entered China per Leaping Bunny China Guidelines.”
This new program allows companies to enter China and stay certified cruelty-free. Can we trust this program and how does it work?
What Is The Leaping Bunny China Qualification Program?
Leaping Bunny China Qualification Program is a new certification program that helps cosmetics brands keep their cruelty-free status in China. The program acts as a guarantee to customers that a brand has not conducted any animal testing in the Chinese market.
The China Qualification Program was launched by Leaping Bunny, a leading cruelty-free certification label, and Shanghai-based regulatory experts from Knudsen & CRC. To receive the certification, companies must complete a pre-market audit and yearly post-market audits.
Knudsen & CRC acts as a Leaping Bunny’s extension to first make sure product registration in China happens without animal tests. After the entry, Knudsen & CRC continues to monitor the company to make sure no post-market animal testing is done either.
The Leaping Bunny China Qualification Program was launched at the end of 2022. Currently, the only company that has successfully passed all pre-market and post-market audits is Burt’s Bees. The certification process for Paula’s Choice is still ongoing.
For more information about the Leaping Bunny China Qualification Program, see our interview with Knudsen & CRC and Leaping Bunny.
Can We Trust The Leaping Bunny China Qualification Program?
Yes. We can absolutely trust the Leaping Bunny China Qualification Program. In fact, it’s currently the only program that can ensure a company’s cruelty-free status in China. It’s either trusting this program or taking the company’s word for it.
Leaping Bunny and Knudsen & CRC are both independent entities with no business interests at play. Leaping Bunny was founded by animal protection groups in 1996 and Knudsen & CRC has been working to end animal testing in China since 2016.
When a company enters the Leaping Bunny China Program, Leaping Bunny and Knudsen & CRC get access to all the documents regarding the China entry. This allows Knudsen & CRC to oversee that the market entry is done without any pre-market animal testing.
“Our process is quite detailed and rigorous, we audit everything from ingredients to finished products to efficacy claims – everything. It’s the most detailed level of scrutiny in every step,” says Mette Knudsen, the founder of Knudsen & CRC.
Knudsen & CRC also continues to monitor the brand after the products are sold in China. Their in-house audit team gains access to China’s Adverse Reaction Reporting which means Knudsen&CRC can directly check the adverse reaction status of the company.
As the China Qualification Program is a huge undertaking for the brand, not everybody is currently accepted to the program. Smaller brands are currently at a disadvantage as the brand should have a whole regulatory team devoted to a successful cruelty-free entry.
How Can Companies Join The Leaping Bunny China Program?
To join the Leaping Bunny China Qualification Program, the company needs to first be Leaping Bunny certified. Only after Leaping Bunny has deemed the company cruelty-free can the China entry process with Knudsen & CRC be initiated.
To obtain a Leaping Bunny certification, the company and all its suppliers and manufacturers need to individually confirm that no ingredients, formulations, or finished products have been tested on animals after a fixed cut-off date.
Becoming Leaping Bunny certified is free of charge, the only cost is licensing Leaping Bunny’s logo on the packaging and marketing materials. The cruelty-free status of companies is being reviewed yearly through Leaping Bunny’s advanced Supplier Monitoring System.
After becoming Leaping Bunny certified, the brand takes a short checklist survey to see if they would qualify for the China Qualification Program. At the very least, the company needs to have its trademark registered with China’s Trademark Bureau.
“Brands looking to enter China should have preferably already entered the EU market to be familiar with all of the paperwork required in registration. Brands must prepare themselves for a long and tedious market entry process that may take several months or even years,” says Kim Paschen, Leaping Bunny’s Program Manager.
After the company is considered fit for the China Qualification Program, Knudsen & CRC takes over the process and starts helping the company make a cruelty-free entry. Knudsen & CRC starts off by screening the company’s ingredients and efficacy claims.
What The Leaping Bunny China Qualification Program Offers To Companies
Leaping Bunny China Qualification Program enables companies to stay true to their cruelty-free values and maintain trust between their stakeholders and customers. The program also ensures no partner will be doing animal testing on the company’s part.
“For many brands that have entered China, it came as a terrible surprise that their partners have tested on animals when we did the paperwork for them. We have seen CEOs in tears when they found out. That’s why we want to be involved early,” says Mette Knudsen.
One of the key roles of Knudsen & CRC is to help companies navigate the complicated regulatory framework in China. The local team in Shanghai also helps the brand overcome the language barrier to be able to deal with the local laws and bureaucracy.
As Knudsen & CRC states on their homepage: “When entering the market in China, it is the responsibility of foreign companies to know the authorizations and regulations. Before initiating importation, it is essential to ensure all product ingredients and content levels are approved in China.”
The primary requirement for imported general cosmetics to avoid animal testing is an official GMP certificate from their country of origin. As the process of obtaining the certificate from the government is not easy, Knudsen & CRC is also helping brands in this process.
In addition to the GMP certificate, the products cannot make new efficacy claims or contain ingredients that are not included in China’s official ingredient database. While Knudsen & CRC is working to extend the allowed ingredient list, it is still limited to around 9000 ingredients.
Knudsen & CRC is also partnering with a US-based lab to replace animal testing in China with cruelty-free testing methods such as in-vitro testing. The Chinese government is also developing alternative tests to replace traditional animal-based toxicology tests.
“As long as the Chinese government can be sure that the alternative testing can have the same conclusion as the traditional toxicology tests, they will consider accepting alternative methods in the registration of cosmetics,” says Cathy Zhu, senior manager of Knudsen & CRC’s regulatory compliance team.
Leaping Bunny China Qualification Program is currently the only safeguarding mechanism against companies doing animal testing in China. The program makes sure the brand will not do any pre-market animal testing or post-market animal testing in the Chinese market.
We hope to see more similar programs in the near future but for the time being, we are incredibly happy that Mette, Kim, Cathy, Valery, and other great people from Leaping Bunny and Knudsen & CRC are working hard to end animal testing practices in China.
We also wish to see cruelty-free brands Paula’s Choice successfully pass all the pre-market and post-market audits to retain their cruelty-free status. It requires a huge commitment from the brands but it’s worth it for a kinder and more sustainable future for cosmetics.