Our founder Natalie talks to Julia Radzwill, expert from Doctors Against Animal Experiments e.V., about the current European citizens' initiative against animal testing and on the status of animal-free cosmetics in the EU in general
Natalie: Hi Julia, it's great meeting you today. We would like to talk to you about the European Citizens' Initiative (ECI) "Save Cruelty-Free Cosmetics - For a Europe without animal testing" and provide some insights on the current status of "animal testing & cosmetics" in Europe. Before we dive deeper, would you like to briefly introduce yourself and the ECI?
Julia: Julia: Yes, sure! I'm Julia Radzwill, graduate biologist and research associate at Doctors against Animal Experiments (German Ärzte gegen Tierversuche e.V., short ÄgT). At ÄgT, we prepare scientific information about animal experiments in such a way that even someone who has no scientific background can understand what is done with animals in the laboratory and how animal-free research works. Since I also have a professional background in the cosmetics sector, it was logical for me to get involved in the European Citizens' Initiative and thus campaign for cosmetics that are free of animal testing.
The ECI was created by European umbrella organizations, i.e. the European Coalition to End Animal Experiments (ECEAE), Eurogroup for Animals and Cruelty-Free Europe as well as PETA and the Humane Society International Europe (HSI). In Germany, Doctors Against Animal Testing and Peta Germany are actively involved. But of course the ECI would never succeed without all the committed citizens signing and striving to collect more signatures. In the end, the ECI is all of us! Everyone who wants cosmetics without animal testing in Europe!
Natalie: Why is it now time for a citizens' initiative at European level. Cosmetics without animal testing are required anyways by law, no? As far as we know, animal testing in cosmetics is generally prohibited in the EU.
Julia: Theoretically, animal testing for cosmetics is forbidden in the EU, yes. Since 2013, selling and importing of cosmetics and cosmetic raw materials tested on animals is illegal. So in theory, European cosmetics are cruelty free. Unfortunately, there are loopholes: this ban applies to ingredients that are found in cosmetics only and that is just about 10-20% of all the substances being used. Approximately 80-90% of the ingredients in cosmetic products are used in other areas as well (cleaning agents, furniture polish, ...) and are therefore subject to the Chemicals Act (REACH = Registration, Evaluation, Authorization and Restriction of Chemicals). According to this law, new chemicals are evaluated and analysed for potential hazards to humans, animals and the environment. This means that animal experiments are not prohibited by law for them, but sometimes even are required. This means: although the final cosmetic products are not tested on animals and no more tests will be carried out, some ingredients have been tested before on animals.
There is also another loophole for raw materials that are only used in cosmetics: when it comes to the safety of workers who come into contact with a certain substance during the production process, animal testing can be required by the European Chemicals Agency (ECHA). This is exactly what happened now: The specific case that led to the EBI is that of the German company Symrise: The ECHA required the German cosmetics company to carry out animal tests on two substances that are used in sun screen – so only in cosmetic cream. Therefore, these substances are part of the Cosmetics Ordinance and therefore animal testing is actually prohibited. The manufacturer complained that they only wanted to carry out non-animal tests, which is also required by law. However, the ECHA decided that the company must carry out the animal tests to ensure the safety of the workers. This position was supported by the EU Commission. Over 2,000 animals were to suffer and die for it.
Natalie: Why is animal testing needed for this? Cosmetics like this have been used and tested for a long time!
Julia: Exactly! Of course, it is important that the cosmetic substances are safe not only for consumers but also for the people who work in production and come into contact with the substances. But the absurd thing is: the two UV filters in question here have been used in sunscreens for decades! In addition, the EU Science Committee issued an assessment of these substances years ago. The documents are freely available; there is also a lot of animal test data in it. It is absolutely incomprehensible and pointless that new animal tests are now being demanded again for these substances that have been in use for a long time.
This incident provoked a large protest action, which then led to the founding of the ECI. The European citizens' initiative wants to prevent the EU from undermining its own cruelty-free cosmetics law. Because if the EU allows animal experiments in this single case, the way will be open to many more animal experiments in the future. That would be a crazy step backwards and an incredible number of animals would then have to suffer and die. Pointless at that, because animal test results cannot even be transferred prospectively to humans.
Natalie: What do you mean? Animal experiments for cosmetics or their ingredients do not provide a reliable basis for evaluation? Why are they being carried out then?!
Julia: In animal experiments, substances are to be tested for their danger and/or (healing) effect on humans. However, this is based on a false assumption, that an animal reacts like a human being, but animals react very differently than humans to many substances ! How differently animals and humans react can be observed very clearly in the licensing process of new medications: out of 100 substances that are considered safe (non-toxic) and effective in animal experiments, an average of 90 do not make it through the clinical phases in humans, i.e.: not on the market, meaning the “success rate” is only 10%! The main reasons for the failure: the substance causes serious side effects or does not help at all against the disease. In most cases, the animal experiment has provided an incorrect assessment. And this is the case in medicine and in cosmetics. Animal-free research, on the other hand, is much more reliable!
Natalie: Such incredible numbers! We had no idea that the success rate of animal experiments was so low. What are the alternatives in order to provide more cosmetics without animal testing?
Julia: There are a lot of animal-free, innovative test methods these days! They work with human cells and tissues and not animals that are made sick in cages. Just one example of animal-free cosmetic and medical research: Today, it's possible to grow mini-organs in the lab! The cells needed for this can be taken during a biopsy (tissue removal) or painlessly in the form of skin cells from a voluntary donor. The biopsy cells are multiplied. Once skin cells have been taken, they are "reprogrammed" and can develop into any cell in the body, e.g. liver cells. The great thing is that these are human cells - i.e. the RIGHT organism with its properties in terms of structure, cells, cellulose, genetic material, ... and not a wrong, namely animal organism. These human mini-organs can then be interconnected onto a multi-organ chip, just like in the real body, they are connected by a fluid system. This simulates the body and blood circulation. So here we have something that no animal model can represent: a relevant, human-based system! Drugs and other substances can then be tested on it in a targeted manner, and cosmetics without animal testing can also be mapped in this way!
Natalie: That sounds like Science Fiction, is this procedure already in practical use?
Julia: Yes! Pharmaceutical companies often work with these multi-organ chips because they know that animal experiments are expensive, take a long time and produce poor results. Unfortunately, the animal testing lobby is so strong that animal-free projects are hardly funded. In fact, less than 1% of funding goes to animal-free methods, 99% of research funds to animal-based projects. This uneven distribution needs to change!
That's why it's so important to sign the ECI Save cruelty free cosmetics
and to make it clear to the public: animal-free testing is not just different, it's even better! A shoutout to everyone who signs, shares and tells people about this! Cosmetics without animal testing is feasible in Europe if we only want it!
Natalie: We are totally convinced!!! By when should you sign if you want to support this ECI for cruelty-free cosmetics? And what exactly is the difference between a petition and a European citizens' initiative?
Julia: By August 31st (meaning in a few days!), we need to have collected over a million valid signatures, all supporting cruelty-free cosmetics. We've cracked the million, yes, but quite a few invalid or duplicate signatures will still be sorted out at the end, so that the plain million itself is not enough, there must be more. Help us and sign now! Normal petitions are just addressed to politicians - but with an ECI the EU has to deal with the issue as long as 1 million signatures are reached across Europe within a year. This can lead to real changes in the law - so you can actually make a difference, prevent animal suffering and make cosmetics without animal testing a reality!
The decision that animal testing must be carried out again for 100% cosmetic ingredients, on the other hand, would mean that the way get paved for many more animal tests - and countless more animals would suffer and die in laboratories. Also, it's going to be difficult for any company - including brands that carry a "cruelty-free cosmetics" seal - to be sure that there are no new ingredients used that aren't tested on animals.
Natalie: talking about labels. How can consumers even tell whether their cosmetics were produced without animal testing?
Julia: It is best to look out for seals. You cannot always rely on a voluntary self-disclosure of a manufacturer without an independent examination and certification. You can find an overview of the most common labels and what they mean exactly here. However, there are also small manufacturers or companies that may have just been founded and do not (yet) have the cash to get themselves and/or their cosmetics certified as cruelty-free. Certification costs real money because independent experts check and control the respective company and/or the products as well as the raw materials used. In cases of small manufacturers, we recommend asking them directly and if it all sounds plausible, you can trust that everything was really made without animal testing.
Natalie: Exactly, that's how we keep explaining to our customers why we, as a small company, don't have the label yet. In the past, we had even written openly on our website that our products were not tested on animals, but we got shut down by a lawyer for this. We were forced to completely remove all references to the topic "cruelty free".
Julia: Yes, that's true, as a manufacturer you are not allowed to advertise "with obvious things". According to the law, cosmetic products and cosmetic raw materials that have been tested on animals are not allowed on the EU market. Officially, all cosmetics are made without animal testing! If you then printed “free from animal testing” on a tube of cream, it would be illegal because consumers could be deceived into believing that the product has a special feature that others do not have. Some manufacturers still do this, but it is critical and if this is noticed, like in your care, it can lead to big trouble. It's really weird: on the one hand there is the law that cosmetics may not be tested on animals, which is now to be undermined, but at the same time companies are not allowed to work with the slogan "cruelty-free"...
Natalie: Simply incredible... Thank you for your commitment to change cosmetics and to free it from animal testing! How exactly can we support you the best now?
Julia: The ECI is currently the most important. Every signature
brings us closer to the goal of a cruelty-free Europe.
Please sign today, tell your friends, colleagues, and family how one signature can make cosmetics cruelty free! You can also order material free of charge in our shop in order to draw more attention to the EBI. Of course, we are always happy about donations and new members, as our work is exclusively financed by them. Get active with us! Take a look at our local groups. Perhaps there is a group near you that you would like to join. Our volunteers organise information stands and other activities, take part in protests and explain animal experiments to people. As an individual, you can find out more about the topic and share this information with those around you.
Natalie: Last question. We often see that consumers think that "natural", “vegan” and “cruelty-free cosmetics” are the same. Can you explain the difference in a few more sentences?
Julia: Of course. The indication "vegan" refers purely to the ingredients and sometimes, depending on the label's criteria, also to the packaging. If cosmetics are vegan, this only means that they do not contain any animal ingredients, they don't check on animal testing or animal-free cosmetics. Also, cruelty free and/or vegan does not mean that it is natural cosmetics - even if a product is vegan and cruelty-free, it can still contain inferior petrol-based substances instead of high-quality vegetable oils. Petrol based products cover the skin like a plastic film and might contain nasty preservatives or allergenic fragrances. So it's always worth taking a close look, because our skin is our largest organ and you don't want to harm it, you want to protect and care for it.
Natalie: Great summary. Thank you for the informative interview. We keep our fingers crossed for August 31st! We believe in a Europe and European cosmetics without animal testing!