On 5th February 2018, China’s NIFDC published a bulletin inviting comments from the public on the consideration to implement two validated and internationally recognised non-animal methods for safety assessment of cosmetic ingredients – the in chemico Direct Peptide Reactivity Assay for skin sensitisation (OECD TG 442C), and the in vitro Short-Term Exposure test for eye irritation (OECD TG 491).
In response, Troy Seidle, Senior Director, Research & Toxicology Department at Humane Society International, an advocator of global animal protection issues, welcomes the “continued progress at NIFDC to embrace validated alternatives to animal testing to strengthen international regulatory alignment and trade in the cosmetic sector”.
Commenting on the impact this will have on the non-animal testing environment in the Chinese cosmetics industry, he asserted: “Adoption of the DPRA and STE methods, and others within the toolbox of OECD test guidelines, will benefit not only animal welfare but the competitiveness of the Chinese beauty industry in the global marketplace, which is increasingly moving toward the European cruelty-free model.”
Cosmetics animal testing in China
In China, the cosmetics industry is governed by NIFDC, which sets out federal guidelines that producers and sellers in the Chinese marketplace must adhere to.
While “acceptance of non-animal testing methods differs among Chinese product sectors and government authorities”, 2016 marked an important year in the animal-testing story for the cosmetics power nation.
Before 2016, the only non-animal tests accepted by NIFDC for the purposes of cosmetics were for genetic toxicity. Since 2016, however, this has been broadened to allow two additional alternative methods to be applied: the Transcutaneous Electrical Resistance test for skin corrosion (OECD TG 430) and the in vitro 3T3 Neutral Red Uptake test for sunlight-induced phototoxicity (OECD TG 432).
Potential new methods
Two years later and the NIFDC has now initiated a consultation to gather the stakeholder response to the possible inclusion of two others: the Direct Peptide Reactivity Assay for skin sensitisation (OECD TG 442C) and the Short-Term Exposure test for eye irritation (OECD TG 491).
“These four methods combined represent approximately one-quarter of the OECD toolbox of non-animal test guidelines for human health effects,” Seidle emphasised.
Asking whether the uptake of these two methods points indicates a move in the right direction for realising non-animal testing methods in the global cosmetics industry, Seidle enthused: “Yes, absolutely!”
Looking at the likely reaction of brands, consumers and China as a whole, this consultation has reopened the lines of communication on cosmetics testing in China. It drives information and education that help businesses and buyers talk about, and understand, the current climate and what can be done to improve it.
“There has traditionally been less public awareness in China of animal testing and the potential for cosmetics to be cruelty-free relative to other beauty markets, but this is beginning to change,” shared Seidle.
US and EU comparisons
Sharing the main differences between China and the EU and US, Siedle stated: “As the EU and US as signatories to the OECD Mutual Acceptance of Data decision, they have an obligation to accept data generated according to any/all OECD guideline methods.”
“In the EU, such acceptance is an unconditional legal requirement for cosmetics in accordance with Regulation 1223/2009, since reliance upon animal test data for animal cosmetic safety assessment purposes has now been outlawed,” he went on to say.
While, on the whole, there is a low level of public awareness in China, this is in stark contrast to Chinese beauty brands seeking to export their products to the EU and other lucrative markets.
These companies, are, on the other hand, “acutely aware of the global trend toward banning cosmetic animal testing and sales, and have been actively working to augment their technical proficiency and infrastructures to carry out non-animal testing methods”.
Pointing towards Chinese cosmetics names’ strong willingness to learn and understand more about non-animal testing methods, Seidle added that the last alternative methods hands-on training supported by HSI attracted more than 1,200 Chinese participants on-site and via webcast.
“Moreover, the ‘Made in China 2025’ plan and ‘Consumer Product Standards and Quality Improvement Plan (2016-2020)’ expressly call for international harmonization of standards and advanced concepts for Chinese brands, which is an additional positive driver in this area,” Seidle concluded.