Updated on June 8, 2023

5 Lies Your “Cruelty-free” Brand is Telling You

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Animal testing for cosmetics sucks and we all would want to see an end to the unnecessary animal cruelty the beauty industry subjects on millions of innocent animals per year to test cosmetics and its ingredients.

The truth is, in most parts of the world, animal testing for cosmetics is not required to prove their safety for humans. But just because it’s not required, doesn’t mean it’s illegal. In recent years, we’ve seen major progress in the EU, India, Israel, and Norway which have all banned the testing of cosmetics and its ingredients on animals, but there is still more work to be done globally.

While we eagerly wait to see a global ban on animal testing for cosmetics, we need be diligent compassionate shoppers and only buy from cosmetic brands that do not test on animals at any stage of product development and distribution.

The problem is, no company will openly admit to ever testing their products on animals, even if you ask them nicely.

Their animal testing policies are filled with loopholes and generic and shady AF claims. And you know what? It’s all done on purpose. Companies want to confuse and keep us in the dark without having to admit their products are tested on animals so that we keep buying from them.

I’ve been blogging about animal testing for cosmetics and cruelty-free beauty for 5+ years now and I can tell you, it has become increasingly challenging trying to decode and decipher a brand’s animal testing policy to ensure they’re cruelty-free.

And I’m here to share with you all some of the common cruelty-free loopholes to look out for when trying to figure out whether a brand is cruelty-free or not.

Loopholes in Products Labelled as “Cruelty-Free”

Be careful with companies claiming their products are “cruelty-free” with unclear statements, vague claims, and convincing bunny logos. When you see a company using any of these claims, be sure to ask for more information. If they don’t address your concerns and instead respond with a generic statement like “we are strongly against animal testing” then proceed with caution as they may be trying to cover something up.

But how are companies allowed to get away with making false claims and lying to us?

Companies can get away with misleading and deceiving cruelty-free claims because there are no standard or legal definitions for the term ‘cruelty-free’. Sadly, the FDA does not regulate or monitor the ‘cruelty-free’ label so companies can use them in whichever way they want.

Don’t worry, I got your back as I’ve taken the guesswork out of trying to spot and decipher some of the most common cruelty-free loopholes used by non-cruelty-free companies.

Below is a list of 5 common cruelty-free labelling loopholes and lies that companies are telling us:

Cruelty-Free Loophole No. 1

Claim: “We do not test on animals”

Some cosmetic brands claim they do not test on animals, however, they may hire others to test their products or its ingredients on animals on their behalf.

This loophole is commonly used by companies choosing to import and sell their products in mainland China where it is required by law for cosmetics to be tested on animals. Companies will try to rationalize that the animal tests administered on their products are being done by a third party or independent laboratories, and not by them.

Just because someone else is doing the crime for you, doesn’t mean you’re innocent and off the hook. Companies need to take responsibility for how and where their products are distributed and the consequences of those decisions. So if a brand wants to sell in mainland China and animal tests are mandatory then they gotta own up to it.

Real-life examples:

However, there are some countries that still believe that animal testing is necessary to ensure the safety of cosmetic products, and require animal testing by law. In those cases, the national governments conduct their own tests of our products—we do not and will never test on animals ourselves.” (Dr. Brandt)

“In China, where our products are marketed, authorities require that certain imported cosmetics products be tested on animals, considered the best way to guarantee consumer safety. We do not perform these tests, which are done by independent laboratories.” (Guerlain)

“In China, however, animal testing is mandated by law for the official registration and certification of the safety of certain product categories. In this case, the tests are conducted by local institutions authorized by the state not by the companies selling the product.” (Nivea)

This is a very common marketing ploy. A sweet innocent bunny with perhaps an X across it suggests the company is operating by a bunch of animal-lovers and wouldn’t dare to test their products on animals. But don’t let the cute bunny silhouette deceive you because unless it’s a trademark bunny logo from an established, reputable organization (like the ones below), an adorable bunny on product packaging is deemed meaningless.


Unofficial bunny logos do not signify or mean anything whereas certified cruelty-free bunny logos have some degree of legitimacy. In order for a company to be certified cruelty-free, they must meet a set of criteria and commit to a strict no animal testing policy by signing a pledge and showing proof of documents to the issuing organizations.

Whereas unofficial bunny logos is one that someone from the marketing or design department drew up and holds no merit to a brand’s animal testing policy.

Also, be sure to check the organization’s online searchable database to make sure the brand is listed. I’ve seen companies use a trademark cruelty-free bunny logo and wasn’t even approved or listed by the organization before.

Claim: “This product was not tested on animals.”

Cosmetic companies may claim their finished products were not tested on animals, but often times, safety and product testing are done at the ingredient level. So, it’s only half-true when companies claim their products are not tested on animals when in fact, their ingredients were.

You also want to ask whether a company’s raw material suppliers test on animals or not. Unless the company makes all of their own ingredients from scratch and basically have control over their entire manufacturing process to guarantee their ingredients have not been tested on animals, most cosmetic brands have to buy and source their ingredients from a manufacturer or supplier. And those suppliers need to also be cruelty-free too to ensure no animal tests have been conducted throughout the supply chain and manufacturing process.

Real-life example:

We cannot be certain that a raw material supplier has not now or at some time in the past tested an ingredient on animals. We do not knowingly purchase ingredients that have been tested on animals and inquire before purchasing ingredients but some staple ingredients that have been used in products for years may have been tested on animals in the past.” (Peter Thomas Roth)

We do not test our actual products on animals (any testing is undertaken on individual ingredients), and we do not undertake animal testing in our own laboratories (any studies are conducted by third party laboratories). A few countries still undertake product testing in their government laboratories.” (Tresemme)

“NeoStrata Company, Inc. endeavors to use raw materials that have not been tested by animals. However, NeoStrata Company, Inc. cannot guarantee that all of its raw material suppliers do not conduct any animal testing.”(Neostrata)

Claim: “We are Cruelty-Free!”

The term “cruelty-free” is so overused now and, unfortunately, there is no standard or legal definition to what qualifies a product/company to be labeled as cruelty-free. The label, “cruelty-free” can be used by anyone and in whichever way they like without any consequences or liability.

To get around this, avoid asking if a company is cruelty-free and instead, ask detailed questions like, “are your products tested on animals?” and “are your ingredients tested on animals” as well as, “do you ask or hire others to test your products or ingredients on animals on your behalf?”

Claim: “We do not test on animals, except when required by law.”

I’ve seen companies with lengthy animal testing statements proclaiming how much they love animals and would never test their products or its ingredients on animals and how much money they donate to support alternatives to animal test methods but at the very end of the 3000+ word document, it states, “an exception is made if a regulatory authority demands it.”

Claims that a company doesn’t test on animals, except when required by law, has got to be one of the oldest tricks in the book. And companies are definitely catching on to how savvy cruelty-free shoppers are at detecting this loophole that they now completely eliminated the disclaimer from their statement.

This cruelty-free loophole is very common for brands that sell their products in mainland China, where animal testing is required by law for all imported cosmetics. Companies will claim how they are against animal testing but then go on to say that their products may be required to be tested on animals by the Chinese government because they have decided to sell their products in their country.

Companies will try to justify their decision to sell in China by stating these tests are not done by them, but are administered by Chinese officials (sounds like loophole #1). Or they explain how they’re advocating for in-vitro and non-animal test methods in China from within.

Real-life examples:

“Neutrogena doesn’t conduct animal testing of our cosmetic products anywhere in world, except in the rare situation where governments or laws require it.” (Neutrogena)

That said, in China, where our products are distributed, authorities may impose random animal testing. We are of course committed to the abolition of this testing and our philosophy is to take action rather than criticise. This is why we fund the IIVS association, which is currently pressuring the Chinese government to practise alternative methods. IIVS is optimistic about the development of testing in China.” (Caudalie)

Blistex fully supports the elimination of inhumane animal testing. We verify the safety and efficacy of our products only on human volunteers and via in-vitro means rather than through animal testing in virtually all markets, including all of North America, South America, Europe, Australia, etc.  We consider the use of product testing on animals unnecessary given the many viable alternatives available to us at this time.The only cases in which such testing may occur on our products is in the rare circumstances when another government’s regulators mandate such steps during their registration processes.  But to be clear, we fully support further development of alternatives to animal testing and the continuing efforts of advocates on this issue in the hope that local authorities in those few foreign entities who continue to utilize animal testing protocols can be persuaded to change their course.” (Blistex)

Animal tests on their products and their ingredients can easily be avoided if they choose not to sell in mainland China. But unfortunately, brands are more interested in profits before the welfare of animals.

Don’t get duped into believing a brand is cruelty-free. You can help end animal testing by voting with your consumer dollars and avoid purchasing products that have been tested on animals.

Have you seen a “cruelty-free” company make any of these claims before?

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What do you think

6 thoughts on “5 Lies Your “Cruelty-free” Brand is Telling You”

  1. Another thing I often see on packaging is “against animal testing”; while the brand may be “against it”, it does not mean they don’t do it! In this day and age, I would’ve hoped to see animal testing completely banned. xxx

    1. YAASS. that’s a good one, Emma! I’ve seen that countless times and it definitely doesn’t mean anything! We’re all ‘against’ animal testing but doing something about it is gonna make the difference! I hear ya, most people are shocked to hear that we’re STILL testing on animals for cosmetics.. just gotta keep doing our part to raise awareness and hopefully we can end it in our lifetime! =)

  2. So what more can we do then other then recognize symbols and sending emails that gets automatic answers back? If the company claims to not test on animals, ahoe can you really find out if it’s a lie? And it must illegal to claim something I’m public and do something else behind th or doors.

  3. what is your opinion on this company, they use mink fur, which is not cruelty free, and labeling their product as cruelty free? What can be done?

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