Abstract: of testing on animals has been one of

Abstract: This paper looks at the cosmetics industry
and practices it has traditionally adopted to ensure the suitability and safe
delivery of its products to final consumers, i.e. testing of the ingredients
and the products on animal specimens. The environmental impact of testing on
animals has been one of the key drivers in changing testing procedures, and we
give prime importance to investigations on the sustainability of animal
testing. Non-animal alternatives have been developed and promoted, and we
discuss their advantages while contrasting them with conventional methods. Standards
and processes have evolved differently across cultures, and companies have
adopted varying approaches to animal welfare and the environment. On the demand
side, the emergence of cruelty free beauty is a sign of greater consumer
consciousness and compassion.


Introduction: An Overview

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In the animal rights movement, cruelty-free is
a label for products or activities that do not harm or kill animals. With the
advent of discussion on the ecological footprint of all industries, the beauty
industry has not escaped the scrutiny of environmentalists and animal rights protection
groups, due to the exploitative and harmful methods it has employed to maximise
the safety and suitability of its final products for human consumption. Any
beauty and hygiene product, whether it as basic as a shampoo or as exclusive as
a foundation, is extensively tested before it is released in the market. The
margin of permissible error is far lower than it is for many other industries.

Animal rights activists and many others who
decry the mistreatment of animals for human use — be it intensive confinement
on massive factory farms or excruciating experiments in laboratories — have long
been dismissed as sentimental and naïve to economic realities. There has
emerged fresh research towards legitimizing the concerns surrounding the
testing of cosmetics on animals. Arguments against animal testing tend to be
focused on moral and ethical grounds. Scientific research, on the other hand,
tends to pride itself in its objectiveness. The ideal approach is








We will briefly traverse the trajectory of the
cruelty-free and sustainable beauty movement. In 1957 Charles Hume and William
Russell introduced the concept of the three R’s (reduction, replacement and
refinement) in their book Principles of Humane Experimental Technique, to be
discussed later on in the paper. In 1963, animal rights activist Baroness
Muriel Dowding launched the first vegan beauty brand. 1 In 1996, eight national
animal protection groups banded together to form the Coalition for Consumer
Information on Cosmetics (CCIC), and promoted an internationally recognized
Leaping Bunny Logo to certify cruelty free cosmetics and help consumers
identify cruelty-free products. 2

In 2004, the testing of finished cosmetics on
animals is banned within the EU, followed by a ban on the testing of cosmetic
ingredients on animals, in 2009. In 2013, Israel becomes the first region in
the world to ban the sale and manufacture of animal tested cosmetics, followed
shortly by India and the EU. 3 Over the last two
years, Asian countries have witnessed gradual changes in legislations and
regulations on cruelty free manufacturing of cosmetics, even though China
necessitates the use of animals in testing, and has in fact banned the
production and sale of cruelty-free cosmetics. Events such as the Sustainable
Beauty Awards and Sustainable Cosmetics Summit have sprung up, to laud companies
who undertake responsible testing for their cosmetics. 4

In 2017, Euromonitor stated that the end goal
for cosmetics companies is to maximise awareness and accountability amongst its
customers of the importance of ethical concerns and the environment. 5



What Cosmetic Testing Entails


The tests are conducted on large numbers of
mice, rats, rabbits, hamsters and guinea pigs for each step and phase. The
creatures are rarely provided pain relief or treatment, kept in torturous
conditions, and killed when they outlive their usefulness. These tests are
responsible for the unbearably painful suffering and distress millions of
animals endure every year. Tests on the eyes and skin are known as the
notoriously cruel Draize test.  6

sensitization: Tests for
allergic reaction on skin.

irritation or corrosion:
Tests for skin irritation (reversible skin damage) and skin corrosion (severe
and irreversible skin damage).

irritation or corrosion:
Tests for eye irritation (reversible eye damage) and eye corrosion (severe and
irreversible eye damage).

oral toxicity: Determines
the amount of a substance that causes half of the exposed animals to die within
14 days of exposure when the substance is swallowed.

dermal toxicity: Determines
the amount of a substance that causes half of the exposed animals to die within
14 days of exposure when the substance is applied to the skin for 24 hours.

inhalation toxicity:
Determines the amount of a substance that causes half of the exposed animals to
die within 14 days of exposure when the substance is inhaled.

dose (28 day) and subchronic (90 day) toxicity: Tests for changes in the cells or organs
caused by repeat exposure.

or chronic toxicity:
Tests for cancer and other long-term effects of exposure.



Proponents of Animal Testing


The cosmetics industry was born at a time when
not only were technology and research nascent, but social responsibility
towards animals was not a priority. Testing on humans always has been and
always will be considered morally reprehensible and legally punishable. The
prevailing assumption therefore was that the easiest and most obvious way of
ensuring the safety of the products, was to test on other living specimens,
believed to be similar to humans in some biological sense. 7

the status quo implies going against a multi-billion dollar industry in which
commercial interests have high stakes. This is one of the major reasons why the
use of animals not only continues, but also is fiercely defended despite
obvious limitations. Apart from the costs of conducting experiments, animals
must be housed, fed, and cared for by trained animal welfare technicians and

dominant mindset is intensely anthropocentric, as proponents argue a
utilitarian moral case based on ‘the greatest good for the greatest number’,
even if this has been proven a myth. When animals are seriously harmed or
killed for relatively trivial human benefit, such as cosmetics testing, the
moral standing of animals is considered extremely small.

is on the grounds that alleged “alternatives” are not sophisticated enough, and
currently tend to complement, rather than replace, the use of animals. Even
Stephen Hawking is quoted as saying that computer modeling is no substitute for
animals in biomedical and cosmetic research. Other alternatives such as microdosing
and in vitro tests have been criticized for the same, and it has been argued
that expecting them to be perfect alternatives is an unrealistic hope.

young cosmetic companies do not have access to alternatives and hence advocates
argue that it would be wrong to castigate them for testing on animals or to bar
them from entering the market.







Environmental Ramifications of Animal Testing in


The ecological footprint of animal research in
the beauty industry is staggering. Several writers have argued that our
anthropocentric approach to the world has led to the ecological crisis in which
we find ourselves. Millions of animals are used in research and toxicity
testing for the cosmetics and personal care sectors, but the major hazards to
our already fragile environment, especially its sink function, are yet to be
adequately addressed.

While there are few specific studies on the
environmental consequences of animal use in research, evidence demonstrates
that their use and disposal, and the associated use of chemicals and supplies,
contribute to pollution as well as adverse impacts on biodiversity and public
health. In the following paragraphs, we elucidate the adverse effects of animal
testing on the environment, as supported by scientific investigations and
obtained from available research literature. 8

Resource Intensity of Animals Exploited in
Research: The number of
animals used in research and testing is believed to be growing due in part to
the development of genetically modified (GM) mice. The creation of GM mice has
inherent scientific flaws which lead to significant waste in the form of
animals bred which are not actually used in research or testing, and instead
become waste or unusable industrial by-products. In one report, a medical
school euthanized 33,348 of their 55,435 laboratory mice as surplus.

According to the U.S. National Institutes of
Health Office of Laboratory Animal Welfare (OLAW), “A research animal facility
generates a significant amount of waste that must be removed and disposed of on
a regular, frequent basis”. At a fundamental level, records regarding the total
number of animals used in testing are not reported to or required by the USDA,
making an environmental analysis difficult. However, clearly a staggering
number of animals are used and discarded, or simply discarded without being
used because they are determined to be excess or develop a laboratory–acquired

Toxicity tests are often conducted in rodents
and rabbits, with at least three groups of animals receiving a chemical and
another group serving as the control. The numbers of animals used varies
depending on the type of test being conducted. For example, the number of
animals per group ranges from 10 rats in 28-day toxicity studies to 20 rats per
group in sub-chronic studies to 100 rats per group in combined chronic toxicity
and carcinogenicity assays, which last for a minimum of two years. Animals used
in toxicity tests may be held and dosed with chemicals for months or years.

Energy Consumption: The quantity of energy consumed by research
animal facilities is up to ten times more than offices on a square meter basis.
Animal research facilities require total fresh air exchanges for ventilation,
using large volumes of air, resulting in a high consumption of energy and
carbon emissions. Additional energy demands are due to the environmental and
space needs of the animals, protection from outside pathogens, indoor air
quality and lighting.

Chemical Intensity: Like other testing methods, animal research
in cosmetics involves the use of many toxic substances, including irritants and
corrosive substances e.g. hydrogen peroxide, ammonia. Laboratories also use
many chemicals with unknown hazardous and carcinogenic properties. Chemicals
are used for veterinary care, analgesia, anesthesia, and euthanasia. As a
result, hazardous chemicals may be present in feed, feces, and urine. Finally,
large amounts of chemicals also are used to maintain sanitized or sterile
environments in laboratories. Because many animal tests are long-term studies,
chemicals may be used for extensive lengths of time.


Waste Generation: Millions of rodent specimens, many of which
are contaminated with toxic or hazardous chemicals, viruses, or infectious
diseases, and significant amounts of laboratory waste such as animal excrement,
bedding, excess feed, caging, needles and syringes, are discarded after use in
research and testing every year. The animal research industry also regularly
and routinely must dispose of large amounts of hazardous wastes.


Carcasses are infectious due to exposure of
the animals to diseases and chemicals, and also may contain a combination of chemical
and biological hazards. For example, animal tissue that contains a
radioactively labeled toxic chemical is sometimes produced in toxicological
studies. Examples include rodents that have been fed lead or other chemicals in
toxicity studies. Wastes that are chemically and biologically hazardous are
difficult to dispose of, and few waste facilities can handle them.


Disposal methods for these biological wastes
raise additional environmental concerns. Incineration is the preferred method
for managing radioactive animal carcasses and tissue, and the most common
disposal method for U.S. laboratories. Many facilities maintain incinerators on
their property, while other facilities contract with commercial disposal


Air Pollution: Air pollution is produced by the emission of
gases and particulates resulting from incineration of animal carcasses and
laboratory supplies such as animal bedding that may contain experimental
chemicals, drugs, and other toxins. Incineration is an environmental concern
due to fuel consumption to maintain required temperatures, the disposal of ash
from incineration in landfills, and resultant air pollution. It is known to
release toxic wastes containing dioxins, lead, and other harmful substances
into the air as waste is burned, to emit particle pollution and produce toxic


A study in Taiwan demonstrated that stack
gases from animal carcass incinerators contain higher concentrations of toxic
heavy metals than standard medical waste incinerators. When a carcass which has
accumulated heavy metals from research or testing is incinerated, the metals
gather in the bottom ash in the incinerator, release into the atmosphere, or
collect in the pollution control devices. Carcinogenic polycyclic aromatic hydrocarbons
(PAH) are also emitted in animal incinerator stack gases.


Incineration of animal carcasses also has been
associated with ash barium levels exceeding accepted standards, and barium can
cause gastrointestinal disturbances. People living in communities near
incinerators of all types are potentially exposed to chemicals through the air
or contact with the soil. Epidemiological studies have shown the health
hazards, including bronchitis and decreased life expectancy. In addition to
global warming pollutants, incineration releases gases, such as carbon monoxide
that can cause or exacerbate respiratory and cardiovascular diseases.


Water Pollution: Soil contamination and runoff of animal
waste and other debris related to chemical testing may result in ground water
contamination. Animal waste containing chemicals that may have unknown
toxicities due to their experimental nature exacerbates the growing problem of
drugs in public water supplies. Public drinking water supplies are contaminated
by animal testing, because public water treatment facilities often cannot
filter out drugs, hormones, and chemical solvents in wastewater. There are serious biological consequences for
aquatic animals, and potentially serious health effects for humans.


Soil Contamination: Incinerator residues and water runoff from
animal testing facilities may result in soil contamination. Several studies
have shown increased levels of heavy metals and dioxins in the soil near
incinerators. The specific dioxin 2,3,7,8-TCDD, a byproduct of incomplete
combustion, is according to the International Agency for Research on Cancer
(IARC) a definite human carcinogen. Animal incinerator soil contaminants in
bottom ash and fly ash also include calcium, phosphorus, and potassium, which
can have toxic effects.





Ending Animal Testing for Cosmetics –
A Complete View of Sustainability



Activists against the usage of animals for
testing cosmetics and ingredients advocate a well-rounded and complete approach
to sustainability.


Environmental Sustainability: As exhaustively discussed, bringing an end
to animal testing would dramatically reduce the ecological footprint of the
beauty and cosmetics industry.


Non-Anthropocentric, Holistic Approach: Sustainability implies deeper respect,
greater compassion, and a heightened awareness of animal welfare, instead of
being exclusively concerned about how the human species is affected. The use of animal species for testing
is an example of excessive interference in the nonhuman world. Ethics and social responsibility are part of
the drive towards sustainability.


Economic Sustainability: As will be elaborated in the next section, non-animal
alternatives to testing cosmetics have proven to be hugely successful and
economically viable. With advances in research and development, and economies
of scale being realized, many companies have overcome initial difficulties in
finding alternatives.


Improving Welfare of Most Parties Involved: Referring to the end of animal testing in
cosmetics as a Pareto superior solution is still tricky, considering some
corporate profiteers stand to lose and always resist change. However, most
companies are either making a gradual shift to cruelty free alternatives or
have already entirely abolished animal testing in their laboratories. While some
consumers still cannot afford cruelty-free cosmetics sold in exclusive stores
and boutiques, most consumers are arguably better off. Cruelty-free cosmetics
are identical and often far superior to those manufactured after testing on
animals, so consumers do not have to compromise or face a welfare loss due to buying
poor quality products. And last but most importantly, the obvious improvement
in the well-being of innocent animals is tremendous.



Cruelty-Free Alternatives to Animal
Testing in Cosmetics



As mentioned in the history of the
cruelty-free movement, solutions to heinous animal testing procedures revolve
around three principles – the three Rs. 9


Replacement: It is the substitution of conscious living
higher animals with insentient material, in either all or part of a procedure.
Instead, experiments are conducted in vitro with tissue culture and
slices, perfused organs, and cellular fractions.

Reduction: This is to reduce the numbers of animals
used to obtain information of a given amount and precision. Studies are
designed to be scientifically and statistically valid, only the minimum
numbers of animals are to be used, and studies should not be repeated

Refinement: It is to decrease the incidence or
severity of inhumane procedures applied to those animals that still must be
used. It is important to assess the impact of any procedure or condition on the
well-being of the animal, and to eliminate or minimise that impact.


Alternatives that have been carefully
formulated and successfully implemented, are as follows. 10


models: With the
growing sophistication of computers, the ability to model or replicate aspects
of the human body is more possible than ever. Computer generated simulations
are used to predict the various possible biological and toxic effects of a
chemical without involving animals.

on Human Volunteers:
It is an innovative technique that can be used in volunteers to measure how
very small doses of potential new chemicals behave in the human body.

Vitro Methods: Almost
every type of human and animal cell can be grown in laboratories. Cell cultures have been central to key
developments in chemical safety testing. Cells and tissues are removed from an
animal and kept outside the body, in a suitable growth medium, for a few days
to several months or even for a few years. Both healthy and diseased tissues
donated from human volunteers can provide a more relevant way of studying human
biology than animal testing. Skin and eye models made from reconstituted human
skin and other tissues are used to replace the harsh Draize tests.


Animal testing for cosmetics has proven to be
frightfully unreliable and dangerously inaccurate. Interspecies variation is
itself the main reason for the invalidity of animal testing. Since each species
of animal is a different biochemical entity, it follows that each species of
animal will react differently to various substances, not only from another
species of animal, but also from the human species. Scientists argue that from
these experiments, massive amounts of ambiguous, contradictory and invalid data
are compiled. Any effort to extrapolate animal data to humans is ludicrous.
Non-animal alternatives have statistically been proven to have better powers of


Non-animal methods have also proven to be far
more economically feasible over the exorbitant costs of using animals in tests
for cosmetics and ingredients. For example, the difference between cruelty-free
testing and animal experimentation is upto $21,000 for toxicity tests, and upto
$400 for eye and skin irritation/corrosion tests. Moreover, economic
feasibility is not only about costs, but also about speed, and time is often of
the essence in very competitive cosmetics brands. Testing the effects of
chemical ingredients on rodents takes anywhere between a couple of weeks to a
couple of years, whereas non-animal methods can yield results within a day.



Success Stories in Cruelty-Free Cosmetic


Many beauty brands have eliminated animal
research for ingredients and final products in cosmetics, and are highly
successful. Ranging from soaps and lotions to perfumes and deodorants, their
products rival the quality and variety of products in companies that have not
yet been able to go cruelty-free. Some brands are hugely popular and famous,
such as The Body Shop, NYX, Kat Von D, Lush, and Urban Decay. They have become
the face of cruelty-free beauty and role models for the rest of the industry.

Other major companies such as Hindustan Unilever,
Procter and Gamble, and L’Oréal, have come under the
scanner for not abolishing animal testing, but they claim to have heavily
invested in research in non-animal methods, and are in a phase of transitioning
from conventional methods to cruelty-free alternatives.





Conservatism, corporate interests and
anthropocentric mindsets have upheld the status quo of exploiting animal
specimens for testing ingredients and final products in the cosmetics and
beauty industry. Nonetheless, a wave of kindness and sympathy have ushered in
the cruelty-free movement, and this movement has over the years received steadily
growing support from highly influential international organisations and

Conventional, inhumane methods are
increasingly frowned upon, and legal measures have been consistently enacted
against them. There have been leaps and bounds in scientific investigations,
that have proven that not only do these cruel methods have a devastating impact
on the environment, but they are also extremely expensive, inefficient, and often
unacceptably inaccurate.

This has fueled an entire revolution in
scientific research and developmental technology, to find solutions and
alternatives that are far more reliable and accurate, cost effective and
feasible, ecologically sustainable and environmentally friendly, while still maintaining
standards of excellence in the quality of products. This has been accompanied
by growing awareness and compassion among consumers, and larger rewards for
companies that successfully go cruelty-free, ranging from economic incentives
to greater acknowledgements to enhance their reputation and brand image.




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