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A little boy kissing a rabbit on the nose. The image is from Persil's Dirt is Good/Use science not animals campaign.

Safe and sustainable ingredients and products – without animal testing

The ingredients in our products must be safe for people and the planet – but we don’t need to test on animals to achieve this. Here Dr Julia Fentem, Head of our Safety & Environmental Assurance Centre, explains why we’re calling for chemical regulations to change.

Julia, what’s Unilever’s stance on animal testing?

Dr Julia Fentem

We firmly believe that animal testing is not necessary to assure the safety of our types of products (personal care, home care and foods) or the ingredients in them – for the people who use them, the people who manufacture them, or for the planet.

Advances in science and technology mean that we can generate much more relevant safety data to protect people and the environment using modern non-animal approaches relevant for the species of concern (for example humans, fish and so on). We have developed and used a wide range of non-animal methods for more than 40 years and advocate that others also ‘use science, not animals’.

We’re calling for transformative change to chemicals regulations so they are based on advanced animal-free safety science in place of outdated animal tests.

So much progress has been made in recent years to ban animal tests for cosmetics around the world. But now that progress is at risk?

That’s right. A full ban on selling cosmetics in the EU where the ingredients had been tested on animals was introduced in 2013. At Unilever, we’ve worked closely with government regulators and scientists all over the world to share our expertise in non-animal approaches for assessing ingredient safety and we support calls for a global ban. Currently, 41 countries prohibit animal testing for cosmetics.

Advances in science and technology mean that we can generate much more relevant safety data to protect people and the environment using modern non-animal approaches.

Dr Julia Fentem, Unilever

However, in 2020 a new threat emerged, which is reversing this great progress. Under the EU’s chemicals regulations, which cover workers and the environment, the European Chemicals Agency (ECHA) began to ask for new animal tests to be carried out on chemicals which are ingredients in a wide range of consumer products with a long history of safe use and manufacture – even those solely used in cosmetics. The move is destroying the EU’s 2013 ban.

Virtually everything on the planet is comprised of chemicals. The water we drink. The air we breathe. The plants around us. And so are the ingredients in our products – even the plant-based ones. We design our products so that every ingredient included is at a level which we can show to be safe for people and the planet based on scientific evidence – and we don't need to test on animals to achieve this.

Instead, we assess the interactions of a chemical with biological pathways at relevant exposure levels using a wide range of cell-based, analytical and computational modelling tools. These provide us with data that enable us to include ingredients in our products at levels well below those which may be harmful to consumers or our environment.

So the EU’s rules banning animal testing for cosmetics and the rules governing chemicals contradict each other?

Yes they do. There are currently significant inconsistencies between the EU’s approaches for establishing the safety of products such as cosmetics and foods compared with how chemicals (some of which are used in those products) are regulated, based mostly on data from animal tests.

The EU’s REACH* regulation, which governs the production and use of chemicals, rules that animal testing should only be carried out as a last resort. This is not happening in practice due to ECHA’s requests for new animal testing. And that’s why we want policymakers to transform EU chemicals regulations so that they are based on the modern (so-called ‘next generation’) safety science that now exists.

Without change, ECHA’s approach will continue to result in needless harm to countless animals.

What action is Unilever taking to help achieve regulatory change?

Through our brands and as a global business, we’re supporting a European Citizens’ Initiative asking for the EU’s ban on animal testing of cosmetics to be upheld, and for chemicals regulations to be transformed to be based on using non-animal safety science.

We have submitted comments to recent EU Commission public consultations calling for amendments to REACH and the Cosmetics Products Regulation. We’re urging them to enable and encourage use of the latest non-animal safety science to ensure any animal testing is truly a last resort and to uphold the EU’s animal testing ban on cosmetic ingredients.

We also fully support the European Green Deal and the EU Chemical Strategy for Sustainability (CSS) ambition to better protect citizens and the environment and boost innovation for safe and sustainable chemicals. In line with the CSS strategy, we welcome the opportunity to fundamentally change the chemical assessment paradigm to ensure chemical ingredients are safe and sustainable by design. Safe for products, people and the planet.

Based on our internal Safe & Sustainable by Design approach, which has been in place for many years, we are involved with other scientists and trade associations in the development of assessment frameworks. As well as working with industry trade associations to engage directly with the EU Commission on these opportunities for a safer and more sustainable future, we are playing a lead role scientifically with organisations such as the European Partnership for Alternative Approaches to Animal Testing (EPAA) ) and the Animal-Free Safety Assessment (AFSA) Collaboration to accelerate the transition to animal-free innovation using safe and sustainable ingredients.

What one change would you like to see in this space?

I would love to see the EU being bold and progressive in re-thinking its regulatory approaches to chemicals

Dr Julia Fentem, Unilever

Europe has outlined leadership ambitions for safe, sustainable innovation to rebuild trust in the safety of chemicals and there is a huge opportunity to do so using advanced science and technology, not animals, to better protect people and our planet.

I would love to see the EU being bold and progressive in re-thinking its regulatory approaches to chemicals, so they enable use of the best science available rather than continuing to be anchored in animal tests dating back many decades.

Finally, how can people help call for regulatory change?

In Europe, an EU Citizens’ Initiative is running until 31 August. Once it reaches one million signatures, EU policymakers will have to consider its three aims: protecting the ban on animal testing for cosmetics, transforming chemicals regulations and modernising science in the EU.

If you’re an EU citizen, please visit https://eci.ec.europa.eu/019/public/ to sign. If you’re not, please help spread the word.

* REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals. It’s a European Union regulation dating from December 2006. REACH addresses the production and use of chemical substances, and their potential impacts on both human health and the environment.