A Look Into the World’s Largest Cosmetics Market Animal Testing Procedures and How to Bypass Them

Cosmetics companies have long awaited the day when their products may be sold on the Chinese market without needing to go through animal testing. Thanks to Knudsen&Co’s partnership with Cruelty Free International and Shanghai Fengpu Industrial Park, that day has finally arrived! Soon the internationally renowned Leaping Bunny China Pilot Project will make its debut, allowing companies to sell cosmetics in China, but avoid animal testing. The Leaping Bunny certification is recognized as the leading global standard for ensuring that no animal testing has occurred throughout the supply chain.

For the past few years, China has been considered a “no-go” market for foreign, cruelty-free cosmetics brands. While many countries have moved towards abandoning animal testing, Chinese regulatory authorities still mandate the practice for imported cosmetics. Under current Chinese regulations, imported and domestic special-use cosmetics must undergo animal testing.

Animal Testing during CFDA Certification

While imported cosmetic products (both special use and non-special use) are subject to animal testing, domestic non-special use cosmetics that undergo CFDA filing are able to bypass animal testing as the practice is not required. To bypass animal testing, foreign cosmetics brands that are looking to either obtain or maintain Leaping Bunny certification should opt to undergo CFDA filing and make use of the solutions provided below.

Even though animal testing has not been officially substituted as a method of examination for cosmetic and skincare products in China, the CFDA removed the mandatory animal testing requirement in 2014. As such, domestically produced non-special use cosmetic products including skincare, hair care, nail care, make-up, and fragrance products, are now able to undertake a safety assessment report instead. This report does not require animal testing, given the product’s ingredients are found on the CFDA ‘approved’ ingredients list.

Pre-market Solution: Domestic Manufacturing

Knudsen&Co has come up with a solution by which foreign companies may sell cosmetics in China while avoiding animal testing. By producing the final product domestically, companies can circumvent regulations requiring animal testing on non-special use products. This way, the company may produce products that qualify for CFDA filing for domestic non-special use cosmetics, a process that does not require animal testing. These solutions will allow Leaping Bunny-certified companies (and companies seeking Leaping Bunny certification) to access the world’s largest cosmetics market. Through the Leaping Bunny China project, companies may manufacture their products domestically in China to avoid animal testing, while not requiring a “Made in China” label. It is important to remember that companies are still required to provide manufacturer information. 

Companies may either:

  • Ship the raw cosmetic materials to China for manufacturing
  • Ship the bulk pre-mixed product and perform filling processes in China
  • Move the entire production process to China

To withhold The Leaping Bunny’s rigorous standards, Knudsen&Co and Shanghai Fengpu Industrial Park will provide strict supervision of the mandatory safety assessment tests during the CFDA filing of domestic non-special use cosmetics.

Post-market Animal Testing

Though non-special use CFDA filing is available to foreign brands should the product be assembled domestically, there remains concerns regarding potential “post-market” testing, which could include animal testing. Companies must respond accordingly to the risk of post-market tests that may include animal testing. Though post-market tests have the possibility of including animal testing, these tests generally consist of label checks and physiochemical tests. Although animal testing has yet to occur in recent years, Knudsen&Co recognizes that the potential for such tests has been a barrier to access for companies either seeking  or maintaining Leaping Bunny certification. As mentioned previously, the likelihood of post-market animal testing occurring is very low, but it is the utmost priority of Leaping Bunny brands that their products undergo absolutely no animal testing. This is why Knudsen&Co has been working with Cruelty Free International and the Chinese Authorities, to remove the remaining barriers for international brands who wish to enter China and maintain their cruelty free status and consumer confidence.

Post-market Solution: Recalls

Knudsen&Co’s solution to this small, yet possible, risk is a recall of all the products should there exist a known safety issue. As the product is no longer on the market, the recall would effectively remove any need to conduct animal testing.

As Leaping Bunny certification is provided to companies who perform animal testing, Knudsen&Co is dedicated to helping brands circumvent processes that would threaten their ability to remain or become Leaping Bunny certified. Our partnership with Shanghai Fengpu Industrial Park specifies that the Industrial Park’s authorities will provide additional assistance with safeguarding against animal test used as part of the post-market test due to the sales of a product with a suspected safety hazard.

In Total

Foreign cosmetic companies looking to sell their products in China without animal testing and wishing to be a part  of the Leaping Bunny program should:

  • Sell products made only from ingredients on the CFDA approved list
  • Incorporate an element of production in China (e.g. product mixing in China)
  • Recall products should there be any safety concerns

This solution provides a pathway for foreign companies with ethical concerns over animal testing to access the Chinese market. As long as the ingredients are listed on the CFDA’s ‘approved’ ingredients list, and the final stages of production are carried out domestically, then foreign brands will be able to avoid animal testing by opting for the safety assessment report. With increased consumer awareness resulting in demand for products that meet the Leaping Bunny standard, this pathway is set to benefit the local economy and the foreign brands that are eager to tap into the Chinese market.


For additional questions, please email info@knudsenchina.com