Updated on May 22, 2021

The Truth About Post-Market Animal Testing in China

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We’ve seen a lot of progress being made in China regarding its animal testing laws for cosmetics in recent years.

But the spread of misleading headlines and their unclear policy changes have left us unsure of who or what to believe is the truth. This has been especially the case in the last couple of years about whether China is still conducting post-market testing on animals.

This has resulted in conflicting opinions among animal rights organizations, cruelty-free bloggers, and experts about the issue of post-market testing in China.

The issue: It’s debated whether animals are still being used in the event where post-market testing is required for cosmetics sold in China.

Background on China’s Post-Market Testing

If you’re not familiar with China’s animal testing laws, I highly recommend checking out this post first. But if you want the TL;DR version – Pre-market animal tests are no longer required for ordinary cosmetics that are produced and sold in China but the risk of post-market animal tests may still occur.

And in the last few years, some cruelty-free brands have been claiming that post-market testing in China is no longer done on animals. As conscious consumers, it was hard to take what these brands were saying at face value as we weren’t sure if they were telling the truth or just trying to get us to buy from them.

So I’ve done my own extensive research on the topic of post-market testing and China’s animal testing laws to figure out whether it’s still being done on animals or not. And here’s what I found out.

I’m going to link to as many sources and articles as possible so that you can do your own research. If you have any questions, feel free to leave a comment or email me directly.

What is Post-Market Testing?

To understand China’s animal testing laws, one needs to know the difference between pre-and post-market testing.

Pre-market testing is when cosmetics are tested during product registration and before they’re sold to customers.

And post-market testing is when officials conduct routine or non-routine tests on cosmetics after the product is available for sale in stores.

What’s changed? In 2019, it was announced that post-market testing for finished imported and domestically produced cosmetics in China will not include animal tests. But it was later confirmed by HSI the new policy does not apply to all post-market tests. Only routine tests or ‘confirmatory’ tests will no longer involve animals.

Routine vs. Non-Routine Post-Market Testing

Routine Tests – where cosmetics are randomly pulled from store shelves to confirm the product is authentic and consistent with what’s in their records

Non-Routine Tests – cosmetics are investigated in the event of a customer complaint, safety concern, or suspected serious public health issue

As mentioned earlier, as of 2019, routine tests in China no longer involve animals

And it’s been reported that non-routine tests rarely involve animals. Knudsen & CRC, a Shanghai consultancy group, says that’s because animal testing is expensive and time-consuming. Costing 5-10 times more and taking 3 months to complete compared to other safety assessments.

Product Recalls If It Does Happen

From my research, it seemed like most experts agree that non-routine tests are rare and highly unlikely.

And if it ever does happen, companies will be given the opportunity to remove their products from China if post-market animal tests were required.

In fellow cruelty-free blogger, My Beauty Bunny’s interview with Leaping Bunny, they both agreed that post-market testing on animals isn’t a thing anymore. And that product safety recalls were more likely to happen than animal tests.

Additionally, Knudsen & CRC, the consultancy group working alongside Cruelty Free International on its China Pilot Program, also agreed that “in the highly unlikely event of any safety concerns, the authorities have agreed that the companies will be able to recall products rather than face animal tests.”

Post-Market Animal Tests Hasn’t Been Done in Years

Many reports claim that post-market animal testing in China hasn’t been done in years. My Beauty Bunny discovered that it’s in fact, all public record. It again goes back to the fact there are cheaper and faster non-animal methods and alternatives available so experts say animals have not been used for post-market testing in years.

Post-Market Animal Tests Can Happen Here Too

My Beauty Bunny wrote an insightful post about how post-market animal tests are not just limited to China, but that it can possibly happen here in the US, EU, or Canada too. She explains that regulators, authorities, and academia can pull a product off store shelves and conduct animal tests. The same way Chinese officials have been claimed to do.

If cosmetic products sold here in the US or Canada are also at risk of being pulled from store shelves and tested on animals, then shouldn’t we also be boycotting all brands that are sold here too?

But It’s Not 100% Guarantee

The fact that China’s laws do not explicitly exclude the use of animals for post-market testing has many consumers feeling uneasy with supporting companies that choose to put their products at risk of possibly being tested on animals in China.

Jen from My Beauty Bunny spoke with the Director of Scientific Communications & Animal Welfare Advocacy at P&G and he told her “We have been told by Chinese authorities that no products of other P&G beauty brands have been tested on animals over the past couple of years. While there is no 100% guarantee, they told us that in case of a health-related consumer complaint, they would reach out to us to provide further safety perspective.  If they then believe more is necessary, they would consider follow up testing, but usually patch testing with human volunteers, not animal testing.

But because it’s not 100% certain that post-market testing will never be conducted on animals, some cruelty-free consumers don’t think it’s good enough to support these brands yet.

The most recent article I could find from HSI from 2020 also states they’re not sure, “The regulation also provides for routine post-market sampling inspections by provincial authorities, including for cosmetics with reported safety problems. It is unclear whether such inspections and investigations could involve animal testing. This uncertainty has long been a barrier to cruelty-free beauty brands entering the Chinese market.”

In the end, it’s still not 100% certain whether animal tests have been completely removed from post-market testing in China. And the fact that animal testing for cosmetics is not banned in China allows officials to issue and conduct whatever test methods they want.

Summary of Post-Market Testing in China

What I gathered is that post-market testing using animals is highly unlikely but not 100% guaranteed. However, it’s not only a risk in China, but that post-market animal test is also possible for all cosmetic brands selling anywhere in the world including the US.

And in China, in the unlikely event that it does happen, companies can remove their products from China than allow them to be tested on animals.

All that being said, China has a public record for all animal tests conducted and it appears that animals used for post-market tests haven’t been done in years. But I need to restate again that it’s still not 100% guarantee that animals will never be used for post-market testing on animals in China because their laws do not explicitly exclude the use of animals.

Unfortunately, it’s not a clear or straight answer of whether China’s post-market testing still involves animals or not. I’m only sharing my research and what I found to hopefully shine some light on this topic.

But you’ll have to use your own judgment and personal preference of whether you would consider brands that are selling in China that claim to be ‘cruelty-free’ is worthy to be considered cruelty-free to your standards.

This issue is complex and unfortunately, there’s no straight answer. So I hope I could provide you with another resource on your journey to create positive change.


Side note: I rewrote this post three times. My first two drafts were too long and information overload. But if you have any questions or want references to my sources, or would like to read more into anything I wrote about, please just let me know!

I hope you found this post helpful. It took me months to research this topic and if you’d like to support me and my work ~ any contribution, big or small ~ would be greatly appreciated!

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What do you think

0 thoughts on “The Truth About Post-Market Animal Testing in China”

    1. Hi Laura,

      Hm.. that’s an interesting article. Based on what I know and read about their China Pilot Program is that CFI is NOT working with China’s FDA or any governing regulatory body.

      In their original article of when they first announced the China Pilot Program, they never claimed to be working with China’s FDA. Cruelty Free International says they’re partnering with Knudsen&Co and Fengpu Industrial Park.

      From my research, Knudsen is a specialized consulting company in Shanghai. They’re NOT a government regulatory agency of China. Their role in this is to basically supervise the manufacturing and processes of these brands in China and report back to CFI.

      And according to Knudsen’s website, Fengpu Industrial Park acts as another safeguard of the process just outside of Shanghai.

      So none of these companies that CFI is working with on their China Pilot Project are “Chinese authorities” per se .. they’re more specialists and consultants.

      I personally was never under the impression that CFI was working with any “Chinese authorities” on their China Pilot Program. So I’m not sure what happened here… but it’s really interesting! I’m going to have to dig deeper into this one.

  1. The new regulation is only for general cosmetics. This leaves a wide range of cosmetics and skincare subject to testing, both pre and post market.
    China has a horrible history of abuse to humans. So I have a difficult time trusting that they will no longer abuse animals.

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