Next month, China is expected to implement the most significant change to its cosmetics testing regulations in more than 20 years - removal of mandatory animal testing for ordinary cosmetics manufactured within China. For the first time ever, Chinese companies will be able to choose to use a state-of-the-art non-animal test instead of a decades' old animal test.
This is a welcome development for animal welfare in China, where as many as 300,000 animals may be used each year in cosmetics animal testing. It's also a vitally important first step towards transforming China's research sector to take advantage of faster, cheaper and more human-relevant and predictive non-animal test methods.
However, the true impact of this regulatory change will largely depend on how available and familiar these OECD-validated tests are to the average Chinese scientist or regulator. While they may soon no longer be legally obliged to conduct animal tests for cosmetic formulations, they will be inclined to continue doing so if they simply don't have the necessary expertise in making product safety assessments based upon test results for raw ingredients and newer, more sophisticated non-animal methods, as is standard practice in most other countries.
That's why toxicity testing experts from Humane Society International and the Institute for In Vitro Sciences have teamed up to head to China. It's the start of an intensive training program, funded as part of an $80,000 grant from Humane Society International, The Humane Society of the United States and the Human Toxicology Project Consortium. Chinese scientists will be given laboratory-based hands-on training in how to use state-of-the-art in vitro methods such as the BCOP test to assess eye irritation and the 3T3 NRU to measure phototoxicity in cosmetics instead of using live animals.
Through its Be Cruelty-Free China campaign, HSI has found Chinese scientists and regulators to be interested in non-animal test methods, but assistance in implementing the new technology is key. While in vitro and other non-animal techniques are routinely used across Europe, where cosmetics animal testing has been banned since 2009, in China such methods have only recently been adopted. Most Chinese scientists have limited access to non-animal techniques and testing facilities.
Organized through China's Guangdong Inspection and Quarantine Bureau, HSI and the IIVS's training aims to help fill this knowledge gap, making the option to move away from animal testing a practical alternative. China's consumer and science sectors have much to gain from such a transition - animal toxicity tests are some of the least scientifically credible methods still in use. Indeed, when you consider the scale of uncertainty associated with some of these approaches, it's astonishing that in so many countries and across so many sectors we're still gambling consumer safety on methods that were devised in the 1940s.
Let's take the Draize rabbit eye irritation test as an example. Developed in 1944, it's used to evaluate how irritating or corrosive a substance may be to the eye. Albino rabbits are traditionally used, not because their eyes are similar to humans - indeed they differ in significant ways that can skew the results - but because they have very large eyes which makes it easier to observe ocular damage. The test chemical is applied to the eye and then a lab technician scores any resulting damage over the next 21 days. The scoring is entirely subjective and therefore vulnerable to human over- or under-estimation. As a test approach it lacks scientific rigour and this is amply demonstrated by its propensity to throw up conflicting results between different laboratories where an identical test chemical is used.
Animal tests for skin irritation and corrosion have similar problems. Like the rabbit eye test, differences exist in the thickness, structure and permeability of human skin and that of other animal species, which means results are of questionable relevance. Rabbits and guinea pigs are most commonly used, the fur on their backs shaved so that the chemical can be applied direct to their bare skin for four hours, after which subjective observation occurs with all the same variability consequences.
Reconstructed human epidermis models such as EpiDerm (MatTek Corporation), and EpiSkin and SkinEthic (SkinEthic, L'Oreal) are well established across the European Union for skin irritation testing. These consist of human cells grown on a culture membrane to form mini pieces of human skin in the wells of a petri plate. These tests have been shown to be more accurate in predicting a chemical's likely irritancy potential than animal testing, as well as taking a fraction of the time and cost.
China still has a long way to go. The impending rule change doesn't yet apply to foreign imported cosmetics so cruelty-free companies can't yet sell their products without compromising their principles. And the risk of post-market animal testing remains. Indeed, HSI believes post-market testing could even increase after the rule change. That's why HSI's Be Cruelty-Free China campaign combines political lobbying to advance legislative change, with scientific outreach to secure research progress. Together with raising consumer awareness, it's a campaign formula that is proving highly successful with Be Cruelty-Free campaigns driving change across Brazil, the United States, Canada, New Zealand, Taiwan and beyond.
Find out more at hsi.org/becrueltyfree