China’s Animal Testing Laws: What You Need To Know

Did you know that animal testing is required by law in China for all foreign cosmetic brands? Even brands that have otherwise stopped testing on animals have to comply with these laws when they enter the Chinese market.

What makes this situation worse is that China’s animal testing laws can be really confusing. This is often simply because many of the articles on this subject are either too wordy or give too little information.

So, I’ve set out to write my own explanation of China’s animal testing laws with the goal of describing them as clearly and efficiently as possible.

Here’s everything you need to know about China’s animal testing laws (and nothing you don’t):

Why Sell In China?

China is home to about 1.5 billion people and the country’s cosmetics market alone is worth over $26 billion USD. The lure of potential profits makes China incredibly appealing to many companies looking to increase their revenue by a huge margin, but only if they make the decision to prioritize dollars over ethics.

Cosmetics Brands That Sell In China

Below are some cosmetics brands that sell their products in China. A few of these brands have a long history of actually being against animal testing but have since lost their cruelty-free status by choosing to join the Chinese market while mandatory testing laws are still in place.

Because they sell products in China, these brands are NOT cruelty-free.

AerinEstee LauderNARS
BurberryLa Roche PosayOlay
Calvin KleinLancomeOrigins
ChanelL’OrealRimmel London
DiorMary KayTom Ford
Dolce & GabbanaMaybellineVichy
EOSMichael KorsWet n Wild

In contrast, pop over to my list of cruelty-free & vegan brands (none of them sell in China) and support businesses with a steady moral compass.

Mainland China vs. Hong Kong

Hong Kong’s relationship with mainland China isn’t exactly clear-cut.

Hong Kong is a Special Administrative Region (SAR) of the People’s Republic of China (colloquially referred to as “mainland China”). But Hong Kong enjoys plenty of operational autonomy in that it has its own currency and even maintains its own government separate from mainland China.

This means Hong Kong can set its own laws regarding cosmetics animal testing for products sold specifically in Hong Kong.

According to Hong Kong’s SPCA:

“Hong Kong recognises many international cosmetic safety standards under the Consumer Goods Safety Ordinance (Cap. 456) and does not require additional animal testing as a pre-requisite for import and sale of cosmetic products.”

This means Hong Kong does not automatically require any more safety animal testing than what is mandated by the countries from which brands operate.

It’s important to note that neither Hong Kong nor mainland China have enacted total bans on animal testing for cosmetics, so it’s still possible for products from either of these regions to be tested on animals.

Important Terms

To understand China’s animal testing laws, you need to be familiar with a few important terms.

Pre-Market vs. Post-Market Testing

China tests on animals at two stages: pre-market and post-market.

Pre-Market tests are done before products hit the market.

Post-Market tests are done after products hit the market.

For post-market animal testing in China, the government can — at any time and without notifying a brand or asking their permission — actually pull products from shelves and test them on animals.

A brand implicitly agrees to these terms by agreeing to sell products in mainland China, and these brands are well-aware this means their products might be tested on animals.

“Ordinary” vs. “Special Use” Cosmetics

“Special-use” cosmetics are products that make a functional claim on the label. Hair dyes, perms and hair growth products, deodorants, sunscreens, skin-whitening creams are all examples of what China considers “special-use” cosmetics.

“Ordinary” cosmetics are products that don’t make a functional claim on the label. Make-up; fragrances; skin, hair, and nail care products are all examples of what China considers “ordinary” cosmetics.

Who Does the Testing?

The Chinese government conducts tests according to their laws at their own discretion and companies must fund China’s testing of their products with their own money.

When Is Testing Required?

Always Required:

  • Pre-market testing for ALL foreign and domestic cosmetics (if sold in mainland China)
  • Post-market testing for domestically produced “special use” cosmetics (if sold in mainland China)
  • Post-market testing for foreign imported “ordinary” and “special use” cosmetics

Required Only In Certain Circumstances*:

  • Post-market testing for domestically produced “ordinary” cosmetics (as of January 1, 2020), including those sold at Chinese airports

*”Certain circumstances” occur when a consumer files a complaint about a product or whenever the Chinese government believes further testing is required to determine a product’s safety. These tests may or may not be done on animals (again, at the Chinese government’s discretion).

When Is Testing NOT Required?

Online Shopping

China’s testing laws do NOT apply to online shopping; they only apply to cosmetics that are physically sold in mainland China. This means cosmetics purchased by Chinese consumers via foreign shopping websites are exempt from China’s mandatory animal testing laws (provided retailers don’t also physically sell them in mainland China).

“Made in China”

Just because a cosmetic product says “Made in China” on the label does NOT mean that product has been tested on animals, though it still might.

The only time a cosmetic product that’s manufactured in China is required by Chinese law to be tested is:

  • If it’s “special-use” cosmetic
  • If it’s an “ordinary” cosmetic that’s physically sold anywhere in mainland China and the Chinese government decides safety tests are necessary

China’s Animal Testing: Moving Away From Animal Models

The most recent changes to China’s product safety testing laws came about due to China’s National Medical Products Administration’s acceptance of nine non-animal (alternative) test methods.

These alternative methods will now be the preferred methods of verifying product safety, but animal testing still remains an option and has not been banned.

Cruelty-Free Resources:

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