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The animal testing ban five years on

  • February 9, 2018

 

2018 sees the 5th anniversary of the full implementation of the EU animal testing ban for cosmetics, a milestone in cosmetics regulation, and a development which still resonates around the world. Other jurisdictions have followed suit or plan to do so. The European Parliament is currently discussing a resolution calling for a global ban. While the objective of the ban – to eliminate cosmetics animal testing in the EU and for products and ingredients marketed in the EU -  has been completely achieved, controversies persist  over what the ban says and doesn’t say. The European Court ruled last year on aspects of the scope of the ban.

My point here is not to wade into the controversies, but rather to highlight  an area where every stakeholder– industry and activists alike – can agree: the need for alternatives to animal testing.

The key to an animal testing free world,  for cosmetics and other fields of research alike, is developing alternatives and getting them both validated and/or accepted.

These are three different challenges, and none of them is easy.

First, although the science is developing rapidly, there is still some way to go. Progress is being made in frontier areas such computer predictive modelling and  in vitro cell and tissue cultures but, as the EU was aware when it adopted the full ban, alternative methods are not yet available to predict all the effects of a chemical on the human body. The work is complicated by the fact that inevitably one single alternative test cannot replicate an animal test in its entirety, so multiple tests may be needed for some effects. And, while alternatives research addresses the so called ‘three Rs’ – reduction, refinement and replacement, only the latter is an option for our industry, the toughest one of the three.

Second, once an alternative method has been developed it needs to be independently certified to ensure that the method is robust, from both a technical and practical point of view. But validation is costly and uncertain,  the ‘Achilles’ heel’ of alternative methods according to a recent report by RIVM, the Dutch public health institute.  Some experts believe traditional validation methods may be unsuited to the complex, multifaceted science of alternatives.

Third, even validated alternatives must be accepted by regulators. Cosmetics manufacturers need to be able to demonstrate that products are safe, otherwise products don’t go on the market. That means regulators must agree that the safety test is reliable (nb cosmetic products are not pre-approved like medicines, but controlled once they are on the market). There is a significant degree of conservatism in this area, perhaps indicative of a general tendency in society to become more risk averse, or simply that the regulators are sometimes playing catch up with the science. To be fair, the industry together with the scientists developing the new approaches, needs to work to  build confidence with regulators in alternatives.

The cosmetics industry has been at the forefront of research , and Cosmetics Europe itself manages multi-million Euro alternatives research projects. The industry’s commitment to innovation and science remains as strong as ever. But achieving the win-win of optimising the industry’s capacity to create innovative products without animal testing is not something we can achieve on our own.

EU Parliamentarians understand this. A recent Opinion from the Parliament’s ENVI committee (which deals with health) on the future EU budget calls for more financial backing from the European Commission for alternatives research, and also for the Commission to work to ‘speed up’ validation and acceptance. Amendments to the draft resolution for the global ban also call for more resources to be allocated to alternatives.

Five years on, animal testing for cosmetics is well and truly a thing of the past in the EU. The same cannot yet be said of the challenges the ban bequeathed to us.

 

John Chave, Director General, Cosmetics Europe

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