Can Cosmetics Sold in China be Cruelty-Free?

Posted on 5 min read
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There was an interesting article in Huffington Post explaining how it’s nearly impossible to be 100% sure that cosmetics sold in China are cruelty-free and do not undergo any new animal tests.

Just as we thought China was making some progress to ending their animal testing requirements, it now sounds like caring consumers need to be even more careful of how some cruelty-free brands are distributing and selling their products in foreign markets, particularly, in China.

As of right now, there are a number of instances where a cruelty-free company can sell to their customers in China without having to test their products on animals. But as the Huffington Post article explains, we can’t be 100% certain..

“a company cannot provide a 100% assurance of no new animal testing for the Chinese market. New animal testing can still be required or undertaken for new ingredient notification, and/or post-market surveillance by provincial [Food and Drug Administrations] or related authorities, who will conduct sampling inspection including animal testing randomly, no matter [whether] the submitted data is animal test reports or safety assessment reports.”

1. Selling in Hong Kong

Hong Kong is part of China but Hong Kong has their own political system. In the case of animal testing for cosmetics, Hong Kong does not follow the same animal testing laws as mainland China. It is not required for cosmetics sold within Hong Kong to be tested on animals.

Some cruelty-free companies sell in China but only in Hong Kong.

Here is a statement from ATTITUDE, a vegan-friendly skincare and household cleaning brand.

“We don’t import our products directly in China but our products are available in China. It is true that China requires animal testing for personal care products and cosmetics before being registered by the government. Therefore, none of our products was registered in China. However, when importing products in Hong Kong, this process is not required. When Chinese distributors are interesting in buying and selling ATTITUDE products, they will buy them from our Hong Kong import agency.”

2. Selling Online Directly to Customers

Customers in China can purchase products from an online retailer where the products will be shipped directly to the customer. In this case, the products do not have to be registered in China and therefore are not required by China’s laws to be tested on animals. Those who wish to sell their products directly to customers must state on their retail product packaging whether or not their products are cruelty-free in accordance with the law in China.

This also extends to some online retailers operating in China. Here are two real life examples and responses I received from brands:

Wet N Wild is certified cruelty-free by PETA and I noticed they had a link to a Chinese consumer website at the top right of Wet N Wild’s website. When I asked them about this, they said:

“We don’t sell in stores in China but there are some websites that offer our products there.”


I noticed a similar example with Yarok, a Leaping Bunny certified brand, where they had several distributors in China. When I asked them about this, they said:

“We sell directly to five online accounts and because they can prove that they purchased small amounts online and then sell Yarok only online and in China, no animal testing is required, they can’t sell it in an actual shops except in Hong Kong.”


3. Domestically Produced Ordinary Products

Last year, China changed their animal testing requirements where domestically produced ordinary cosmetics are no longer required by law to be tested on animals.

Within the same year, Cruelty-Free International welcomed BA YAN KA LA, the first Chinese company to achieve the Leaping Bunny certification.

BA YAN KA LA actually reached out to me and were kind enough to answer and cooperate in explaining how they have managed to avoid testing their products on animals when operating in mainland China.

“To answer your question about how we ensure our ingredients and products are at all stages does not conduct animal testing, we have gone through the whole process of auditing with our suppliers, from raw material supplier to factories which produced our products. Auditing includes checking their factories and face-to-face meetings with our suppliers with formal signed agreement to ensure our suppliers will not at any stage conduct animal testing.

Our brand began in 2007, and immediately we established the issue about not testing on animal to all our suppliers. This issue has come to our attention since the very beginning when we form the brand, not because it’s a hype or a trend. And in addition, I’d like to clarify the regulation of animal testing in China.

By law, it is necessary for foreign brands who wish to establish their retail presence on mainland China to test on animals. Mainland-produced brands are not legally bound to conduct animal testing and we chose not to do it.

The whole process of us being allowed by the Chinese FDA to put our products on the market includes us providing all relevant information, product and ingredient background to demonstrate the absence of risk and therefore allowing us to not test on animals. Please be reminded that the new BA YAN KA LA products are formulated between 95.8-100% plant extract. Once we have obtained FDA approval and all products and manufacture has been audited there is no further random check and testing to our knowledge. If you have relevant legal sources from the Chinese government or Chinese FDA describing such a process we would be delighted to look into it and provide further information.

Final Thoughts

Even in these 3 cases where a company can bypass China’s current animal testing laws, we still can’t be 100% sure that no new animal tests occurred, especially when it comes to post-market surveillance testing where the Chinese authorities can simply just take a product off of a store shelf and test it on animals without the company’s knowledge or consent.

It’s sad to say that as caring consumers, we have to yet again be on the look-out of how brands are doing business elsewhere in the world in order to verify their cruelty-free standing.

I’m curious to know, what are some concerns or issues you have with cruelty-free companies selling in China? Do you believe it’s possible for a cruelty-free company to sell to customers in China?

What do you think?

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  • Kerri
    June 2, 2016

    Good info! I didn’t know that about Hong Kong. Do you know if Bourjois is cruelty-free? I really want to try one of their lipsticks but only if I can verify its cf status.

    • Chori
      June 3, 2016

      They don’t seem to be clear about it, which is on and by itself suspicious. The best practice to avoid cruelty is not to buy from companies/brands with unclear policies. Remember: lipsticks are a commodity; no need for them at all, much less when it comes with animal abuse (we live in a very absurd world)

  • Caitlin
    June 2, 2016

    unfortunately, it is really unsafe for companies to sell their products in china if they want to remain cruelty-free. the only caviat is that companies can sell direct to consumer, meaning they ship the order from the us/canada/etc. directly to the doorstep of the consumer. china is continuing to tighten the reigns and any “loopholes” can change at any minute.

    • Vicky Ly
      June 2, 2016

      I know, it’s all really shady in my opinion! I have the same feelings as you. Unless a company is selling and shipping directly to the consumers that purchase from their website.. you really don’t know what goes on or who can get their hands on your products and what they will do with it!

“Make ethical choices in what we buy, do, and watch. In a consumer-driven society our individual choices, used collectively for the good of animals and nature, can change the world faster than laws.”― Marc Bekoff

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Can Cosmetics Sold in China be Cruelty-Free?