Cruelty-Free Labeling

The Center for Laboratory Animal Welfare (CLAW) encourages consumers to make conscientious choices about the personal care products they buy. Consumers who care about animals can make humane decisions that benefit laboratory animals.


At first glance, one might think all products labeled “cruelty-free” or “not tested on animals” would be good choices. Unfortunately, this is not always true. The problem is that “cruelty-free” is not clearly defined by law, so it can be used to mean just about anything a manufacturer wants it to mean. This is further complicated by the fact that many personal care products that do not market themselves as “cruelty-free” are, in fact, tested for safety using non-animal methods.

This webpage will look at “cruelty-free” products as more than a matter of labeling or public relations, and will help you make well-informed decisions about product purchases.

What is Cruelty-Free?
Consumers need to be aware that labels that read “cruelty-free” and “not tested on animals” may not always mean what we think. As no government agency currently defines these terms, nor sets standards for their usage, it is left to each company to determine what its “cruelty-free” label means. Many scientists – including those who support alternatives – believe these ambiguities can make these labels meaningless.

“Cruelty-free” can be used to imply:

  • that neither the product nor its ingredients have ever been tested on animals. This is highly unlikely however, as almost all ingredients in use today have been tested on animals somewhere, at some time, by someone – and could be tested again,
  • that, while the ingredients have been tested on animals, the final product has not,
  • that the manufacturer itself did not conduct animal tests but instead relied on a supplier to test for them – or relied on another company’s previous animal-test results,
  • that the testing was done in a foreign country, where laws protecting animals might be weaker than in the U.S.
  • that either the ingredients or the product have not been tested on animals within the last five, ten, or twenty years (but perhaps were before, and could be again),
  • that – as in the case of the CCIC’s Leaping Bunny Program – neither the ingredients nor the products have been tested on animals after a certification date and will not be tested on animals in the future.

In short, there is no “official” or government-sanctioned cruelty-free label. Conscientious consumers are left to make some very complex choices among products made by companies that do no animal testing themselves but rely on animal-tested safety data gathered elsewhere, those that have made commitments of one degree or another to alternatives research, and companies that do neither.  Even with the challenges of understanding what most manufacturers mean by their “cruelty-free” label, the CCIC’s Leaping Bunny Program is the best resource  to help concerned consumers find products that have met a “cruelty-free” standard.

The CCIC’s Leaping Bunny Program and Logo
The Coalition for Consumer Information on Cosmetics’ (CCIC) Leaping Bunny Programmaintains a single, comprehensive standard for cruelty-free labeling. This makes it easier for consumers to shop for products manufactured without the use of animal testing.  The Leaping Bunny Program gives consumers assurance that products they are buying have met the most rigorous cruelty-free standards as licensees are required to sign a pledge not to test on animals during any stage of product development. The company’s ingredient suppliers make the same pledge, assuring that the entire product is free from animal testing.  CCIC also commissions on-site audits to assess licensees’ and suppliers claims of a “no animal testing” manufacturing policy.  In 2009, the Center for Laboratory Animal Welfare, an affiliate of the MSPCA, became a member of the CCIC and a supporter of the Leaping Bunny Program. To encourage more companies to sign on to the Leaping Bunny Program, consumers are urged to pledge to purchase cruelty-free products to save animals from cruel and unnecessary testing.

Product Safety Testing – A Brief Background
In 1933, at least 17 American women were blinded by, and one died of, complications resulting from the use of Lash Lure, a new mascara. At that time no laws or regulations governed the safety of consumer products. Manufacturers were free to market almost anything.

As a result of this and other tragic incidents related to untested products, the U.S. Congress passed the Federal Food, Drug, and Cosmetic Act of 1938, requiring that food, drugs, and cosmetics be verified as safe for human use before they could be sold.  Following this, animals came into widespread use as the mechanism for testing the safety of personal care products in the U.S. This was based on the premise that animals are similar enough to people to be used as models for human response.

Today, the federal government still requires manufacturers to establish product safety. Personal care products covered by federal laws include shampoo, deodorant, eye shadow, lipstick, nail polish, hair spray, perfume, toothpaste, shaving cream, sunscreen, and hand lotion. Some of these are regulated as cosmetics; others – including certain sunscreens, fluoride toothpastes, and antiperspirants that claim some medicinal value – are regulated as over-the-counter drugs.

In some cases, animal tests are specifically required by a federal regulatory agency. In other cases, only the “best available” safety information is requested.  Many American regulatory agencies, however, still believe traditional animal tests are the “best available.” And for some products and ingredients, traditional animal tests are still the only ones available.

Manufacturers test for both the immediate risk of exposure (through normal use, accidental contact with the eyes or skin, and accidental ingestion) and more long-term risks (such as potential to cause cancer or birth defects).  The animals most commonly used to test product safety are mice, rats, rabbits, guinea pigs, and hamsters. They are exposed to test substances by application to the eyes or patches of bare skin, by injection, by inhalation, or by feeding. The information obtained from these tests is then used to substantiate a company’s claim that a product is safe for human use.

Alternatives to Animals in Product Safety Testing
There has been much success in the development and use of alternatives to animal testing within the arena of personal care and household products.  Within the last three decades, many manufacturers have dramatically reduced their reliance on animal use for this purpose.  It is estimated that the number of animals used to test the safety of personal care products might be less than 5% of all animals used in U.S. laboratories – a nearly 90% reduction since 1980.

Reasons for the decline in animal testing
In the early 1980’s an outcry arose when the public became aware of common animal test methods such as the LD50 and Draize eye and skin irritancy tests (see CLAW’s Product Safety Testing Issues and Answers for more information). Henry Spira, the late animal activist, led consumers in lobbying to abolish these tests.  He ran full-page newspaper ads charging Revlon and other companies with perpetuating animal cruelty simply for the sake of beauty. As a result of consumer pressure, Revlon became the first U.S. cosmetics company to fund a major research program aimed at developing alternatives to the use of animals in eye-irritancy testing. Avon quickly followed suit. Soon, the Cosmetics, Toiletries, and Fragrance Association (CTFA) – whose members include all major U.S. cosmetics companies – announced a $1 million grant to develop alternatives. Funding was given to the Johns Hopkins School of Hygiene and Public Health to establish the Center for Alternatives to Animal Testing (CAAT), whose mission is to encourage the development, use, and acceptance of alternatives.

One of the major accomplishments of CAAT was the development of ALTWeb, a web-based clearinghouse for information about the methods, research and resources for alternatives.  This, and other sites that disseminate information on the safety of ingredients and product formulations, have gone a long way toward enabling a reduction in the number of animals used in testing for cosmetics and consumer products.

Increased use of alternative testing methods as safety screens has also helped to reduce the number of animals needed to test a product or ingredient. Now, toxicologists are often able to test directly on human volunteers, without any animal testing. Some manufacturers use ingredients that are “Generally Recognized as Safe” (GRAS), and therefore do not require further testing.  Many new in vitro (test tube) toxicology testing techniques and in silico (computer modeling) analyses also assist scientists in replacing or reducing the number of animals used.  Non-animal eye and skin tissue irritancy tests have attracted particular interest.  The Environmental Protection Agency and the Food and Drug Administration recently approved the first alternatives to the Draize rabbit eye irritancy test – a great step forward. This is estimated to reduce the number of rabbits used for eye toxicity testing by approximately 10%.

Additionally, many industry executives have found that alternatives make good business sense. Non-animal tests are not only more humane and faster, but can also be cheaper and more predictive of human response than traditional animal tests.

Thus far, the European Union has been a leader in seeking and applying alternatives to using animals in product safety testing for personal care products.  In 2004, the European Union implemented a directive banning the testing of finished cosmetic products and their component ingredients on animals.  In 2009 this directive expanded to include a ban on marketing cosmetics in which the final product or any of its ingredients have been tested on animals. By 2013, the ban on animal-tested cosmetics was in full effect. Israel and India have also enacted laws favoring cruelty-free cosmetics. This marks significant progress toward the end of the use of animals in cosmetics product testing globally.  Many hope it will continue to encourage the development of valid alternatives for product safety testing that can be validated and approved for use in the United States. (Please see below and see CLAW’s “Laboratory Animal Alternatives- The Three R’s Issues and Answers”).

Corporate Commitment to Alternatives

While alternatives can make good business sense, corporate commitment to them varies widely.  Although some companies are dedicated to testing for personal care product safety without the use of animals, other manufacturers show little or no real commitment to developing and promoting alternative test methods. Similarly, a company’s public statement about its decision to end animal use in product-safety testing shouldn’t be the only measure of its real commitment. Today, several of the larger companies – most of which still do some animal testing – are making progress toward the time when animal use in safety tests can be further reduced or completely eliminated.

In the 1990’s several larger cosmetics companies adopted at least some alternative testing methods, announced permanent or temporary halts to their animal testing programs (Avon, Revlon, Estée Lauder, Mary Kay, and Gillette and Bic) and/or made major corporate commitments to developing and promoting in vitro systems and other alternative tests (Proctor and Gamble, Unilever, Bristol-Myers Squibb, Johnson & Johnson).

These are all important, progressive steps, but animal testing is still done by most major companies.  However, these companies have dramatically reduced the number of animals they use in their safety-testing programs. Their efforts to establish the reliability of the alternatives they have developed offer new hope for animals in labs worldwide and their struggle to persuade U.S. and foreign governments to accept valid alternatives as evidence of product safety is essential.  Until alternatives are officially accepted by national and international regulatory agencies, further progress toward eliminating animal use in product safety testing will slow dramatically.

Encouragingly, consumer demand has created a niche market for products that use no animal ingredients and safety-test without the use of animals.  Companies such as Avalon Organics, Burt’s Bees, Beauty Without Cruelty, Kiss My Face, and Tom’s of Maine emerged to meet the demand for these products.  Additionally, stores such as Whole Foods have adopted policies of exclusively selling personal care products that have not been tested on animals.  Larger grocery store chains have also begun incorporating these products into their personal care aisles.

What You Can Do

Two factors will permanently change the landscape for lab animals. First, some personal-care product manufacturers will aim both to develop sound alternative test methods and to convince the government to accept these methods as evidence of product safety. Second, pressure on these companies and the government from concerned consumers, like you, to validate and utilize these alternatives will ensure continued progress.

Until the federal government acts to establish guidelines that define “cruelty-free” labels, it is up to conscientious consumers to learn all you can about the manufacturers of your personal care products. The Center for Laboratory Animal Welfare urges you to choose products made by companies you feel are most responsible in their entire approach to safety testing – including their commitment to developing and promoting alternatives to animal tests.

Additionally, you can write or call the manufacturers of personal care products to ask for a definition of their “cruelty-free” labels, and for information about their investment in alternatives development. You can also inquire about what they are doing to promote national and international regulatory acceptance of alternative methods.

For products that have met the Leaping Bunny Corporate Standard of Compassion for Animals, the CCIC maintains a Compassionate Shopping Guide of products that have met their stringent standards.  This can be accessed at You can also urge your representatives in Washington to introduce federal legislation defining and setting standards for “cruelty-free” labels.