Cruelty Free International and Australian aromatherapy, natural skincare and wellness brand, Subtle Energies have announced the successful shift of the animal welfare organization’s Shanghai-based Leaping Bunny pilot project to an all-China route to market for cruelty free certified international brands. As a matter of fact, Subtle Energies will now supply Peninsula Spa, based in the Chinese capital.

Back in 2018, Cruelty-Free International launched its Leaping Bunny China Pilot Program, which helps leaping bunny approved brands to enter the Chinese market without having to test perform animal tests.

Avoiding animal tests

Before entering this new phase in their Chinese journey Cruelty Free International worked closely with Shanghai-based regulatory advisors Knudsen&CRC to carefully review the recent regulatory changes announced by Chinese authorities, in particular the possible end of compulsory animal testing for imported “ordinary” cosmetics (also named “general cosmetics”). [1]

Our pilot allowed us to ensure that expertise was on hand to allow companies to remain free from pre-market animal testing and expertly find a way through all the other requirements. To manage the complex issue of post-market testing - testing that could take place on a product after it has hit the shelves - we worked closely with Oriental Beauty Valley and Fengxian district, Shanghai to be sure this would not happen,” explained the organization.

All international Leaping Bunny brands wanting to sell in China using this all-China route must:

- Agree plans with Cruelty Free International;
- Manufacture the products at approved facilities within China;
- Maintain ongoing contact with their distributors and retailers to monitor any risks of animal testing;
- Only use ingredients that already feature on the list of approved cosmetics and personal care ingredients in China (in other cases, animal tests will be required by Chinese authorities);
- Not include special use cosmetics in their sales offer (as animal tests are required for these products).

Announced regulatory changes

As an increasing number of countries globally, and lately Colombia, are prohibiting animal testing for cosmetic purposes, in the wake of the EU initiative in 2013, China’s rules requiring that all “special cosmetics” and imported “general cosmetics” (locally made “general cosmetics” are exempted under certain conditions) has long been see as a major impediment to trade.

Indeed, some brands have given up their prospects regarding the Chinese market so as not to be forced to test their products on animals. However, the situation could change.

Following the publication on 29 June 2020 of the long-awaited Cosmetics Supervision and Administration Regulation (CSAR), which will replace the existing Cosmetics Hygiene Supervision Regulations, which was first released in 1989, it is expected imported "ordinary cosmetics" will no longer have to be tested on animals. While the CSAR is note clear on this issue, a formal and official clarification should come in the next few months.

Although it is anticipated that regulations will follow to spell out that non-special use imported cosmetics would no longer require animal tests as part of their safety assessment if other specified requirements are fulfilled, until these are published and details become clear, Leaping Bunny brands remain unable to export into mainland China,” highlights Cruelty Free International.

For so-called “special cosmetics”, the legal situation is even worse, since hardly any exemption from animal testing is expected yet.