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Cruelty-Free Labeling

The MSPCA 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 webpage will look at “cruelty-free” products as more than a matter of labeling or public relations. The information below is provided to 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 individual companies to define their own “cruelty-free” label.

“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.
  • While the ingredients have been tested on animals, the final product has not.
  • The manufacturer itself did not conduct animal tests but instead relied on a supplier to test for them, or relied on another company’s results that had been obtained through animal testing.
  • The testing was done in a foreign country, where laws protecting animals might be weaker than in the U.S.
  • 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).
  • 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 Program maintains 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 must 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.

Product Safety Testing – Overview and Alternatives
Animals have been used to test the safety and effectiveness of drugs and vaccines in the U.S. since the early 1920s. After World War II, animals also came into widespread use for testing the safety of consumer products such as household cleaners, cosmetics, food additives, and pesticides, based on the theory that their responses could predict the potential for harm to humans and other animals.

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 oral intake. The information obtained from these tests is then used to substantiate a company’s claim that a product is safe for human use.

Because test results from one species don’t always apply perfectly to others (i.e. rats to rabbits to humans), the theory that animals are good test subjects has recently come under scientific criticism. In addition, many consumers have raised serious concerns about the ethics of using animals to test product safety, especially for cosmetics. Yet for a variety of reasons, scientists in government and industry continue to use animal tests in an effort to minimize harm to the consumer, despite the fact that, with some exceptions, they are not required by a federal agency. It is estimated that 500,000 animals are used in cosmetics tests worldwide every year.

Reasons for the decline in animal testing
In the early 1980s, 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 Product Safety Testing for more information). The late Henry Spira, an animal activist, led consumers in lobbying to abolish these tests during the 1970s and 1980s. 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.

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 was expanded to include a ban on cosmetics when the final product or any of its ingredients have been tested on animals. By 2013, the ban on the of sale animal-tested cosmetics was in full effect. Israel, Norway, and India have also enacted laws favoring cruelty-free cosmetics. Numerous other countries including Brazil, China, New Zealand, Russia, Vietnam, Thailand, and more have introduced campaigns and bills to reduce and stop cosmetic animal testing. This marks significant progress toward the end of the use of animals in cosmetics product testing globally.

The Environmental Protection Agency (EPA) and the Food and Drug Administration (FDA) also play a major role in working toward the end of animal testing for cosmetics. For example, these agencies approved alternatives to the Draize rabbit eye irritancy test, a great step forward, a shift that is estimated to have reduced the number of rabbits used for eye toxicity testing by approximately 10%. In 2018, the FDA launched a study to create an alternative to dog use in cosmetic studies. Along with the long-term study and a public declaration of dedication to the Three R’s, in 2018 the agency established the Animal Welfare Council to provide oversight for all animal research activities. The 2016 Frank R. Lautenberg Chemical Safety of the 21st Century Act, which requires the EPA to minimize animal testing. In 2019 the U.S. Environmental Protection Agency (EPA) announced that it was working particularly hard toward ending the use of mammals in science and testing, both in their own studies and in funding requirements. Additionally, in February 2020, the EPA issued final guidance that reduces unnecessary testing on birds in the pesticide registration review process, which is expected to save 720 test animals annually. And in July 2020, EPA released guidance that reduces unnecessary testing on fish in the pesticide registration process, expected to save 240 test animals annually.

See also Alternatives to the Use of Animals in Research.

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.

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). However, many of these companies’ efforts have faltered. Additionally, many companies have been enticed by the Chinese cosmetics market, which mandates animal testing on all products sold in China. Any company that sells its cosmetics in China cannot be considered “cruelty-free.”

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 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 and Trader Joe’s have adopted policies of selling personal care products that have not been tested on animals. Larger grocery store chains have also incorporated these products into their personal care aisles.

The Humane Cosmetics Act

Recently, the U.S. has taken steps to follow the European Union’s course of action in putting an end to animal testing. The federal Humane Cosmetics Act would prohibit testing cosmetics on animals, and no cosmetic would be sold or transported in the U.S. if the final product or any component of it was developed or manufactured using animal testing. 

Similar legislation is also pending in state legislatures.

What You Can Do

Two factors will permanently change the landscape for animals used in testing. 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 MSPCA 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. You can download the “cruelty cutter” app onto your phone to scan products while in store, determining if they are cruelty free to your standards.

Additionally, you can contact 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. You can also urge your Congressional representatives to introduce federal legislation defining and setting standards for “cruelty-free” labels.

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