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August 9, 2023

Animal Product Testing in China Decoded

For cosmetics and beauty brands looking to sell their products in China, pre-market animal testing had long been a strict requirement. However, this is no longer the case. Skincare, hair care, fragrance and other beauty products which are sold in China no longer need to be tested on animals. Despite this, many clean and vegan beauty brands are unaware of the changes to China’s rules and regulations.

What is the current situation?

On May 1 2021, Chinese authorities ended mandatory animal testing for most cosmetic and skincare products. Under the new regulations, various cosmetics products are now able to qualify for an exemption. This was welcome news for many clean beauty brands, as it meant that they could now enter the China market without violating their own cruelty-free practices. Previously, only companies that manufactured locally in mainland China were able to bypass pre-market animal testing. The new regulations now also cover products that are manufactured abroad and imported into China.

Do brands that only sell online to China need to test on animals?

If a company is only selling its beauty products online and shipping directly to its customers in China, they are NOT required to undergo animal testing. Therefore, cosmetics sold on online Chinese social commerce platforms such as RED, Tmall, JD.com and Taobao, DO NOT require animal testing.

There are a select few types of cosmetics sold in physical Chinese stores may require animal testing (some of these are covered below), however those sold online do not.

Has animal testing been totally banned in China?

No it hasn't. Although the pre-market testing requirement has been removed for general cosmetics, animal testing still exists in China.

The changes have lifted the requirement for most imported cosmetics, however it is not illegal if a company or supplier decides to conduct animal tests on its products in China.

What types of products does the exemption cover?

It is worth noting that the animal testing exemption does not apply to all cosmetic products.

First, the products which the exemption does cover:

1) General cosmetics are not subject to mandatory animal testing.

This covers the following categories: skincare, hair care, makeup, fragrance and nail care.

Second, the products which the exemption does not cover:

2) A select few special cosmetics still require pre-market animal testing.

This covers products that make a specific functional claim, such as hair dyes, hair perming products, sunscreens, whitening products, anti-hair loss products, and cosmetics claiming new efficacy.

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What are the implications of this change in the animal testing law?

In China, clean beauty has caught on rapidly, with year-on-year sales increasing by around 600% in 2021, and by 233% in 2022. At the end of 2022, surveys found that almost 50% of respondents bought clean beauty skincare products in China in the past three months.

Although China is the world’s second-largest market for cosmetics, with total annual sales of USD $30 billion, the clean beauty market in China remains relatively small and untapped.

The industry has palpable growth potential as the competitive landscape has yet to reach its peak. It is no surprise that industry experts are predicting that clean beauty will be the next big thing in the Chinese beauty market. Once animal testing requirements on products were lifted, this lifted a prohibitive barrier to market entry in China for clean/organic beauty brands.

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Historically, China has long required post-market animal testing on various products, limiting the growth and entry of clean beauty brands into China, as the laws would often misalign with many brands’ ethical ethos. Today, the outlook is much more different. Brands can now sell most cosmetic and beauty products without having to test on animals.

Following this change, brands are now able to maintain their “clean” or cruelty-free status. This has become one of the key drivers contributing to clean beauty’s increasing prevalence in the Chinese market. Brands do still need to follow specific criteria to qualify for an exemption to receive proper certificates from Chinese authorities, though this has become much easier to do.

The wealth of opportunities for clean, organic and vegan beauty brands in China is growing. With the right strategy and brand partner, the potential rewards for brands considering China market entry are seismic. Early entry into the market means that beauty brands occupy a larger market share and are able to establish what the clean beauty narrative should be.