Animal Testing Cosmetics in China – UPDATE


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 leaping-bunnybrands 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.

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