Consumer goods giant, Unilever, has announced its support for the #BeCrueltyFree campaign led by Humane Society International (HSI).
HSI emphasises Unilever’s active support for strong bans on cosmetic animal testing and trade in the United States, Canada, Brazil and Australia; a major step forward in its global #BeCrueltyFree campaign.
The UK-headquartered beauty heavyweight has pledged to support the organisation's efforts to ban animal testing for cosmetics internationally within the next five years.
HSI and Unilever have participated in various national and international forums. For example, Unilever has cooperated with the scientific committee of the EU-funded research coordination project AXLR8 and is also a founding member of HSI's Human Toxicology Project Consortium.
“Our legislative goal is to move from the current 37 national animal testing bans to at least 50 within 5 years, thereby bringing an effective end to animal testing in the beauty industry globally. Our targets are Australia, the ASEAN region (7 countries), Brazil, Canada, Chile, Mexico, South Africa, Sri Lanka and the United States,” shared Hannah Stuart, HSI Campaign Manager for #BeCrueltyFree Australia.
Together, the company behind household brands including TRESemme, Dove and Degree, hopes that this new collaboration will speed up policy change relating to contemporary non-animal approaches to consumer safety assessment. And in doing so, this will create worldwide regulatory acceptance.
Unilever and HSI’s ultimate aim is that this drive will spur a shift in the international cosmetics space and lead to animal testing bans in 50 major beauty markets worldwide by 2023.
1. Industrial Chemicals Bill 2017 and global harmonisation
A key part of this new partnership will see Unilever back HSI’s move to strengthen Australia's proposed cosmetic animal testing data ban within the Industrial Chemicals Bill 2017 and associated rules. In a bid to ensure these rules are consistent with European Union precedent, the duo want to ensure that the ban fully prohibits the use of new animal test data for cosmetics sold in Australia.
Commenting on the importance of this total prohibition in the use of new animal test data in Australia-based cosmetics, Hannah Stuart, HSI Campaign Manager for #BeCrueltyFree Australia, states: “Humane Society International strongly believes that animal testing for the purpose of developing new cosmetics should be eliminated, and the overwhelming majority of Australians agree — a Nexus Research poll on behalf of Humane Research Australia found 85% of Australians oppose using animals in the development of cosmetics.”
“The level of suffering caused to animals in this context cannot be justified, particularly in view of the fact that thousands of existing cosmetic ingredients can be reformulated to create new products without the need for animal testing,” added Stuart.
As this form of safe innovation without animal suffering is now standard in the EU, HSI would like Australian regulators to “move in the same direction”.
The Australian Department of Health, which is responsible for the implementation of the proposed cosmetic animal test data ban, has stated its desire to align Australian regulations as much as possible with that of major trading partners, such as the European Union, the world's largest cosmetics market.
However, HSI expressed that the proposed wording of the Australian ban would still allow the submission of new animal test data for the purposes of safety substantiation of some cosmetic introductions. This scenario is prohibited under EU regulation.
Cosmetic chemicals that also have end uses in other product sectors would not be covered by the ban under the current wording of the ban within the Industrial Chemicals Bill 2017 and associated draft regulations.
Stuart goes on to say that here lies the problem as it is “very common for cosmetic chemicals to also be introduced for other purposes”. As a result, the “proposed ban wording would leave consumers exposed to buying newly animal tested cosmetics even after the ban comes into force, deviating from the EU and Australian Government election commitments”.
At present, HSI is currently “negotiating with the Government to ensure that this and other unnecessary ban exemptions are removed so that new animal-test data is banned for any and all cosmetic uses of chemical introductions, not just some”.
There are two core elements to achieving this: Incorporating complementary ban measures within the rules to ensure that cosmetic end uses of all chemical introduction categories are captured by the ban, and revising or removing unnecessary ban exemptions currently proposed in the draft rules.
“Collectively, these measures would ensure that post-ban animal test data could not be used to substantiate the safety of any cosmetic use of a chemical introduced in Australia,” Stuart expressed.
2. The launch of a multi-year, open collaboration to develop non-animal approaches
Set to launch early 2019, Stuart shares HSI and Unilever’s initial plans and hopes for the work of the multi-year, open collaboration to develop capability across companies and regulatory authorities. As a result, safety decisions for cosmetics are based exclusively on non-animal approaches.
Cosmetics brands including Unilever are using non-animal approaches to assess the potential hazards of cosmetic products and ingredients. They are also, however, using non-testing approaches such as combinations of exposure-based waiving such as threshold of toxicological concern, computational, and other tools to inform risk-based decision-making.
“This combination of hazard-focused ‘Tox21’ and exposure-led ‘Risk21’ approaches represents the future of safety assessment,” confirmed Stuart.
Unilever and HSI share a common interest in promoting these non-animal approaches for the benefit of both government health authorities and other product and ingredient manufacturers, contract research organisations and safety scientists.
3. Investment in training for non-animal next generation risk assessments
The priorities for building capability for the long-term revolve around the development and dissemination of education and training resources to share how Unilever and similar brands make cosmetic safety decisions using risk-based non-animal approaches, and gain broad acceptance for these approaches in key markets by 2023.
HSI and Unilever are currently at the beginning stages of curriculum development as their intent is not to duplicate in vitro method educational videos/hands-on training that already exist. Instead, they are set to analyse how the data produced from these can be combined with other information and applied to practical decision-making relating the safety of cosmetic product formulations and ingredients, using real-world case studies.
“One possibility we are exploring is the creation of a stand-alone module in the well-known e-learning platform Coursera in order to reach as wide an audience as possible, from students through to front-line safety assessors in industry and government," Stuart went on to say.
It will then aim to adapt the content into languages other than English, such as Chinese, Portuguese, Spanish, and others, and identify suitable online platforms and other dissemination strategies to reach key audiences on a country-by-country basis.
Sharing insights on how its global #BeCrueltyFree campaign is at the forefront of lobbying efforts to ban cosmetic animal testing and trade in the world’s 50 largest beauty markets within five years, Stuart emphasised: “This is an ambitious goal, and we need all the help we can get to win - from caring consumers, cruelty-free brands, and especially from influential multinationals like Unilever. Unilever has enormous power to influence lawmakers and national associations representing cosmetic manufacturers (which have traditionally fought against our efforts).”
“Regulatory differences between the EU and Australia with respect to data requirements and animal testing can also make it necessary for companies to conduct duplicative testing, entailing unnecessary cost, delay, and animal suffering.”
“It is therefore of critical importance that the proposed ban is strengthened so that it better aligns with EU Regulations and international best practice. This can be achieved through complementary ban measures being made that would prohibit new animal-test data being used to substantiate the safety of any and all cosmetic uses of a chemical introduced in Australia, Stuart concluded.