Updated on June 11, 2023

Decoding Cruelty-Free Cosmetics – What Does It Mean To Be ‘Cruelty-Free’ in 2023?

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Here’s the 101 and the basics on what you need to know about Cruelty-Free cosmetics, personal care, and household cleaning products in 2023.

What is ‘Cruelty-Free’?

Products labeled ‘Cruelty-Free’ generally imply it wasn’t tested on animals. However, there is no standard or legal definition as to what exactly is and isn’t allowed to be labeled as ‘cruelty-free.’

Simply put, ‘Cruelty-Free’ can mean different things to different people.

Companies can call themselves or their products ‘cruelty-free,’ and it can mean whatever they want.

So it’s possible to come across a brand advertising its products as ‘cruelty-free’ when in fact, they do test on animals. (Except in the EU, where labeling restrictions exist for products marketed as ‘cruelty-free.’)

Misleading? — Yes.

Illegal? — No.

The FDA, responsible for regulating cosmetics labeling in the US, states on its website, “Consumers sometimes ask about use of claims such as “Cruelty-Free” or “Not Tested on Animals” on cosmetic labeling. Some cosmetic companies promote their products with claims of this kind in their labeling or advertising. The unrestricted use of these phrases by cosmetic companies is possible because there are no legal definitions for these terms.”

Unrestricted Use. No Legal Definition. — Without proper regulation or an official checklist that brands must meet to call themselves or their products “cruelty-free,” the term “cruelty-free” is generally meaningless in 2023.

If you want to find companies or products that are committed to never testing on animals, avoid asking, “is it cruelty-free?” instead, here’s what you need to look out for:

How To Know If It’s “Cruelty-Free”

Animal testing for cosmetics is generally not done by the cosmetic company itself.

So if you were to ask, “does your company test its products on animals?” – most of them will tell you no, the company itself does not conduct any animal testing.

Instead, it’s generally the ingredient suppliers, a third party, or a government agency that has been instructed to do so under current laws or regulations. And whether the company consented to this or has done its homework to ensure its supply chain is free from animal testing is where it matters.

Cruelty-Free Checklist

Here’s a checklist we created to ensure brands are committed to manufacturing and distributing their products without animal testing.

  • Does the company test its finished products on animals?
  • Does the company test any of its ingredients on animals?
  • Does the company ask or commission a third party to test its products or ingredients on animals on its behalf?
  • Do the company’s ingredient suppliers test on animals? If not, how do they verify or ensure that they don’t?
  • Does the company allow its products or ingredients to be tested on animals when required by law?
  • Does the company sell in countries (like mainland China) under current conditions that may require animal testing by law?

📧 Get an Insider look at what we ask brands when verifying their cruelty-free commitments and animal testing policy with our email templates. (Only available to Ko-Fi members)

It’s important that a truly cruelty-free company is able and willing to answer all of the above questions to be considered cruelty-free in 2023.

All of the brands listed in our Cruelty-Free Directory have been vetted using the above checklist, and only brands that have cooperatively answered all of our questions are included in our lists.

If a company refuses to address any of the above questions or cannot provide clarification upon follow-up, we will not consider them cruelty-free, and they’re placed in our Unclear Policies — Grey Area Brand List.

Parent Company Animal Testing

It’s also worth mentioning that some brands that don’t test on animals are owned by a parent company that still engages in animal testing.

Some ethical consumers believe these brands shouldn’t be allowed to be called ‘cruelty-free’ as supporting and buying from them will indirectly fund more animal tests done by the parent company.

Whereas others believe we ought to continue supporting these brands as it will send a message to the parent company, and they’ll realize there’s consumer demand for ‘cruelty-free’ products and that they ought to stop testing on animals.

Because there are no legal or official guidelines on what is defined as ‘cruelty-free,’ the topic of whether we should buy or boycott brands owned by an animal-tested parent company is always a heated topic with no ‘right’ or ‘wrong’ answer.

All Ingredients Have Been Tested On Animals At Some Point

A comment I always hear is that all ingredients were tested on animals at some point, so nothing can truly be “animal cruelty-free.”

My thoughts on this is that, yes, it’s true that some ingredients used in so-called “cruelty-free” products were tested on animals in the past.

But we can’t change what happened in the past. All we can do now is to ensure no more animals are used for cosmetic testing.

So, instead of focusing on what we can’t change, we can ask that companies not conduct new animal tests at any phase of product development and manufacturing either by the company itself, its ingredient suppliers, or commissioned to a third party or government agency.


Since there is no legal definition of what is classified as ‘Cruelty-Free,’ brands can call their products ‘cruelty-free’ to mean whatever they want. But generally, the label ‘Cruelty-Free’ describes cosmetics, personal care, and household cleaning products as free from animal testing.

If you want to find products or brands that are ‘Cruelty-Free,’ I would advise you to avoid asking, “are your products cruelty-free?”

Instead, ask specific questions like those in our Cruelty-Free Checklist.

If you’re not sure, you can always reach out to me to ask about a specific brand or if you need a second opinion on a response you received from a company.

Together, we can help end animal testing for cosmetics once and for all.

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What do you think

4 thoughts on “Decoding Cruelty-Free Cosmetics – What Does It Mean To Be ‘Cruelty-Free’ in 2023?”

    1. Not quite just yet. Brands will have to meet a set of pre-conditions before they can be exempt from animal testing. As far as I know.. no brand has been approved to export its cosmetics to China without animal testing but this may change later this year. And this doesn’t apply to ALL cosmetics. It only applies to non-special use cosmetics.

      I have a more up-to-date post about what’s going on with China’s animal testing laws which can be found here: https://ethicalelephant.com/china-animal-testing-laws-2021/

  1. Why can’t I find Naturtint hair color on Leaping Bunnies website? You claim it’s cruelty free yet another website claims it’s not because it imports to China. Please clarify.

    1. Naturtint is not certified by any third-party cruelty-free certifications like Leaping Bunny. But that does not mean they test on animals. I was able to confirm with the brand that they do not test any of their products or ingredients on animals, nor do their suppliers. And in my most recent correspondence with them in March 2020, they had confirmed their products are NOT sold in China. As far as I know, since 2018, Naturtint is not sold in China as that’s what they told me.

      I just updated Naturtint’s brand page here to include my email response from them, see here: https://ethicalelephant.com/is-naturtint-cruelty-free-vegan/

      The other website you’re referring to may either be outdated or they were provided a list of countries that Naturtint ships to but they may not be selling their products in a retail store in those countries. China’s animal testing laws only require some imported cosmetics that are sold in physical stores to be tested on animals.

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