Our Real Beauties often call themselves “naturalistas” and tell us that they prefer natural products. But it’s tough to be an informed consumer in a world of unregulated product labeling!

In particular, we found two important product definitions – cruelty-free and vegan – that cause our readers all kinds of confusion. Today, we’ll tackle cruelty-free. It’s a complex issue that we thought deserved our first LRB long read.


Cruelty-free at its most basic means that a product was not tested on animals. But here’s where it gets tricky: because of different regulations around the world, cosmetics brands can make carefully worded claims to be cruelty-free while still testing on rabbits, mice, rats, dogs, and monkeys.

The strictest definition of cruelty-free means no animal testing of ingredients, formulations, or finished products by the holding company, manufacturer, or any of its suppliers in the entire world. Brands wiggle around this definition by:

  • Buying ingredients from suppliers that test on animals
  • Testing a formulation or partially completed product, but not the final packaged product
  • Paying a third party test on animals so that they can say they don’t animal test in their own facilities
  • Operating a cruelty-free brand but being owned by a larger company that is not cruelty-free

Confused yet? (We were!) The good news is that PETA, the Humane Society (HSI), and Logical Harmony all monitor cosmetics companies and independently evaluate their compliance with the strict definition. Use the links above check whether your favorite brands are on their cruelty-free lists.


Going Global: Animal Testing Around the World

 It’s up to you as the consumer to decide your personal position on cruelty-free and purchase accordingly.

The 28 countries of the European Union, Israel, India, and Norway have banned animal testing on cosmetics. But, that doesn’t mean all brands made there are cruelty-free.

Image credit: Ethical Elephant
Image credit: Ethical Elephant

In the U.S., the Food & Drug Administration (FDA) does not require animal testing for personal care products and cosmetics, but it also doesn’t ban it. Here’s the FDA’s current statement. Companies operating in the U.S. may choose to test on animals or use ingredients from suppliers who do so. Brands may claim to be cruelty-free when in fact the components or ingredients are animal tested. Their claims and labeling are not regulated.

That takes us to China, the world’s largest market for cosmetics sales – US$26 billion last year. China has complicated mandatory animal testing requirements:

  • Products manufactured in China and sold in China from local ingredients do not need to be animal tested. However, they most often have been animal tested.
  • Products manufactured in China but not sold there do not need to be animal tested. So a label that says “Made in China” does not necessarily imply the product was animal tested.
  • If a product has a cosmetic effect like bleaching, whitening, or anti-aging treatment, the active ingredients must be animal tested, even if the final product is not.
  • If a brand manufactures its products outside of China and sell them locally at retail, those products must be safety tested by the Chinese government on animals. This requirement trips up most U.S. and EU brands.


The most clearly we can say this is: once a U.S. brand decides to sell its product in China, it is required to test on animals. The Chinese market is incredibly lucrative – US$26 billion in 2015. Brands make the decision on whether they want to get a bit of bad press or boycott by a relatively small number of U.S. consumers to sell to over half a billion women in China. Many have decided to put profits over principles, which has led to confusing cruelty-free product labeling and media statements aimed at you.

China requires that cosmetics manufactured abroad, say in the U.S., and then sold in China at retail stores must be tested on animals. Even if the brand itself does not conduct the tests, it knowingly pays the Chinese equivalent of the FDA a fee to conduct required safety testing on rabbits, mice, and rats. For this reason, watchdog organizations currently consider any U.S. brand licensed to sell its cosmetics in China to fail a cruelty-free test.

Let’s take the example of MAC Cosmetics. You may notice on MAC’s web site and Instagram that the brand says it’s “cruelty-free except in places where required by law.” In other words, to sell in China, MAC’s finished products must be tested on animals. But, they use the caveat that they’re not conducting the tests, the Chinese government is. MAC doesn’t have to conduct the tests itself. It can pay a fee to the Chinese government, which has a third party do the testing. With this notable exception, MAC Cosmetics continues to claim it’s a cruelty-free brand. Is the brand a victim of an unfair system, or are its executives making a choice to profit from a lucrative country over its core values? That’s your call as an informed makeup buyer.

Many of the most popular U.S. cosmetics brands like MAC, Clinique, Maybelline, L’oreal, Cover Girl, and Lancome are owned by very large holding (or “parent”) companies that sell billions of dollars of product each year to Chinese consumers. The largest of these are Estée Lauder, L’oreal, Procter & Gamble, Colgate-Palmolive, and Coty. Estée Lauder owns primarily prestige brands sold in Sephora and department stores. L’oreal, Proctor & Gamble, Colgate-Palmolive, and Coty own a mix of drugstore and prestige brands. All of these companies are licensed to sell their brands at drugstores, Wal-marts, and department stores in China. To get that retail license, every cosmetic product that these brands sell in China must be animal tested.

These holding or parent companies are listening to your feedback and creating brands that they will not sell in China, like NYX. But they aren’t always on their best behavior. In the most notorious case of misrepresentation, in 2012, Estee Lauder was caught lying about its animal testing policy in China. Estee Lauder’s corporate site says:

The Estée Lauder Companies does not test on animals and we never ask others to do so on our behalf. If a regulatory body demands it for its safety or regulatory assessment, an exception can be made. (emphasis added)

Since this discovery, cruelty watchdogs have carefully monitored brands within the Estée Lauder family. Many consider buying any Estée Lauder brand, even those not sold in China, to be giving money to a company that condones animal testing. You can decide for yourself whether this company’s carefully-worded exception is a good enough commitment to your personal values.

Estée Lauder has recently purchased favorite cruelty-free brands Becca and Too Faced. The Too Faced acquisition was the most expensive in the history of cosmetic brands at US$1.45 billion. In the case of Too Faced, co-founder and Chief Creative Officer Jerrod Blandino took to Instagram to reinforce that his brand would never be tested on animals. In the comments, former fans lashed out at him for selling Too Faced to a company so notorious for being a testing offender.

PETA and HSI both have active campaigns and partners in China and around the world that are educating consumers on cruelty-free cosmetics and pushing the Chinese government to change its policies. These campaigns are working. On November 2, PETA reported that the Chinese government has approved the first non-animal testing protocol for cosmetic safety, similar to the one used in the EU.

However, this regime is not yet in use. Until it is, if cruelty-free matters to you, the safest bet is to assume that brands that sell in China are testing on animals at some level. You can monitor progress on changes to China’s animal testing requirements through the Humane Society International’s Be Cruelty Free China campaign.


Informed Shopping

 If you’ve decided you want to use cruelty-free products, great! The next step is to research your favorite brands.

Logical Harmony offers simple instructions for adding its cruelty-free shopping list to iOS and Android. This site independently monitors brands for very strict cruelty-free and vegan compliance and updates its lists every week. They call out which cruelty-free brands are owned by non-compliant parent companies. Logical Harmony’s site has handy guides like “Cruelty-Free Brands at Sephora” and “Cruelty-Free Brands at Target.

And if you discover a brand you love isn’t cruelty-free in your eyes, don’t be afraid to tell them that you will not buy their products. Tough love by way of your credit card and social media feedback is more powerful than you think.

Over 1,700 brands live their cruelty-free brands to the fullest, including Anastasia Beverly Hills, Kat von D, butter LONDON, and NYX. You don’t even need to change where you shop. If cruelty-free is something you value, there’s absolutely no reason that you need to compromise for any product or brand.

Thank you for making it all the way to the end of our first LRB long read! We hope that you are feeling ready to make informed choices on which brands get your money and your love. It’s your face and makeup your way!



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