Firms cannot use safety data derived from third-country animal testing to substantiate product safety in accordance with the European Cosmetics Regulation, but such testing does not in itself constitute a violation of the EU’s animal-testing ban. It may be more challenging to compile required safety-assessment reports, but companies don’t necessarily have to choose between the EU and emerging markets such as China.

The European Coalition to End Animal Experiments protests that “in practice, the animal tests bans would have virtually no application,” following ECHA’s clarification of REACH-related exceptions to Europe’s prohibition on animal testing for cosmetic ingredients. According to ECHA, the ban does not apply to testing required under REACH for “environmental endpoints, exposure of workers and non-cosmetic uses of substances.”

Cosmetic ingredient and raw material suppliers would be required to share toxicity and safety data with brand owners, along with certificates of analysis and contaminant testing reports, under the Cosmetic Supply Chain Transparency Act of 2021. The bill is part of a proposed Safer Beauty package introduced in the US House on 29 July by Jan Schakowsky, D-IL, and colleagues.