The burning question on most independent beauty brands lips is when will China change their animal testing policies. The simple answer is no one really knows. However, there have been several updates recently that show we are moving in a positive direction and give good reason for brands who are serious about this market to start getting everything in order so you can take advantage as soon as the changes are announced.
Currently if you want to enter the China market without animal testing the details of your options can be read about here.
However if you are waiting for changes here are the latest updates.
Animal testing regulation updates
It is impossible to say for sure when animal testing regulations in China will change but here are the latest updates from this year and our best predictions from 2020:
Pre-market animal testing
This is currently in place for all products being imported into China through general trade (not e-commerce)
- This is still very much in place
- In June 2019 there was an announcement by the NMPA (China’s equivalent of the FDA) that they were looking into alternative testing methods for non-special use cosmetics and were asking for general comment.
- In January 2020 there was an announcement that the State council had given the green light for long awaited cosmetics regulatory changes. They said that imported cosmetics should come in line with domestic cosmetic regulations however the details of what this means have not yet been released.
- We are hopeful that this means an end to animal testing for imported non -special use cosmetics as domestic non special use cosmetics have not required this since 2014.
- From discussions it seems that the NMPA are comfortable to move forward with these alternative testing methods however it still needs to be officially announced.
- Look out for possible announcement by end March 2020!
- However, there will still be a period of implementation needed and probably a pilot project so best guess is end 2020 we can start seeing first non-animal tested products go through general trade (as long as the trade war doesn’t deter the Chinese government from a favourable decision!)
Post market animal testing
This is where a product is already on sale in physical retail but authorities pull from shelf to test it.
Reality is, it has not been abolished in all provinces so if you sell in physical retail your product still has a risk. However, experts say authorities have not used it in years and are very unlikely to as there are other means and methods that would give a much quicker result as to toxicity levels etc.
Domestic Production
Since 2014 domestically produced Non-special use cosmetics have not been required to undergo animal testing. This means brands who produce products in mainland China or send bulk product and fill and repackage locally do not require animal testing.
There are no changes here – so this continues to be a route to market for brands who are willing to produce in China.
Leaping Bunny pilot
In November there was an announcement that some 
brands who have global leaping bunny certification were able to go through a special pilot project in China and sell in physical stores.
This pilot is a collaboration between Leaping bunny and Knudsen a regulatory consultancy in China. The way it works:
- The brands manufacture in a Fengxian district in China under the supervision of Leaping bunny and Knudsen
- Products are then sold within the Shanghai and other key districts where there is an agreement that no post market animal testing will every take place. If there is ever any product safety issue with these pilot brands, they have to fully recall all products in the market.
- These products can also be sold online through Tmall and JD
Get ready for China animal testing changes
You can prepare for the hopefully imminent changes to animal testing regulations in China. Currently registration of products including testing takes 6-12 months. Once the tests change from animal to other methods it is unlikely that the lead time for product registration will reduce significantly. So you can get prepared now – the paper work preparation is the longest part of the registration process so you can get this all organised now if you want details on how to do this get in touch.
Learn more about the routes to market that don’t involve animal testing through my masterclass dedicated to Cross border e-commerce.
Hi,
Do brands like Mary Kay and Forever Living, who sell through private distributors, have to do pre market animal testing on their products before selling in China? If not, Is it possible that they will be post market tested on animals?
In short, are they considered cruelty free, and if not, when does the animal testing happen?
Sincerely
Bente
Hi Bente, Thanks for visiting the site. Yes brands who sell in physical retail shops in China do need to go through pre-market animal testing. And it is also possible that the product would be subjected to post market animal testing however in practice post market animal testing has not been used for years. The two routes for cruelty free are cross border e-commerce (online only & sent into China directly to end consumer usually from a Hong Kong warehouse or special bonded warehouse in China) or manufacturing locally (non special use cosmetics) within China as these are not subject to pre market animal testing although technically could still be subjected to post market testing. Hope that makes sense. Let me know if you have more questions. Thanks Allie
Thank you for the answer. I have two more questions.
The two brands I mentioned does not sell in physical retail shops. These companies sell their products through people who get the products from the company and sell them to people at parties, for example. Where and when do the testing happen when there’s no physical retail store?
The person who sell products at a party probably order the products from the company online. Is this considered online shopping and are the products therefore not subjected to pre market animal testing?
Thank you. Bente
Hi Bente, I don’t know exactly how these two companies get their stock to the individual sellers but most likely the company imports the products through general trade which includes animal testing to a local warehouse and then the consultants order online. Mary Kay has been in the market for a long time so I am pretty sure that they would have gone through registration and animal testing. In order to take advantage of cross border e-commerce the individual has to place the order before the stock is shipped to them and there are quotas on the amount 1 individual can purchase. Hope that helps. Thanks Allie
Thank you for the answer. I have two more questions.
The two brands I mentioned does not sell in physical retail shops. These companies sell their products through people who get the products from the company and sell them to people at parties, for example. Where and when do the testing happen when there’s no physical retail store?
The person who sell products at a party probably order the products from the company online. Is this considered online shopping and are the products therefore not subjected to pre market animal testing?
Thank you. Bente