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What's in a Name?

Navigating the murky world of product labels

All Animals magazine, March/April 2014

In addition to checking for companies that partner with the Be Cruelty-Free Campaign, the best way to know for certain that no animals were recently harmed in the making of a cosmetic or personal care product is to look for the Leaping Bunny logo.

  • Look for the Leaping Bunny logo on products to make sure that they're certified cruelty-free. 

The mark certifies that the manufacturer meets the stringent criteria set by the Coalition for Consumer Information on Cosmetics, of which The HSUS is a founding member. Those manufacturers that pledge to uphold the internationally recognized Corporate Standard of Compassion for Animals confirm that no new animal testing is done at any stage of production; they also guarantee that their ingredient suppliers have taken the same pledge, and they agree to be audited for recertification.

Vigilance over product labels is a necessary strategy for humane consumers in today’s complex marketplace. Aware that buyers today reject animal testing, many manufacturers are labeling their goods with rabbit logos and phrases like “animal friendly,” “not tested on animals,” and “we never test on animals.” Consumers buy with the assurance they are purchasing compassionately produced merchandise.

Five easy ways to celebrate Be Cruelty-Free Week »

But that confidence is not always warranted. Such phrases may refer only to finished products and not their individual ingredients. “We never test on animals” may be technically true; a company may not do its own testing but instead farm it out to independent labs. Another common disclaimer—“not tested on animals except where required by law”—gives companies an out if they expand into lucrative markets such as China, which mandates animal testing of imported cosmetics.

Says Jen Mathews, who researches companies’ test methods for the My Beauty Bunny product review blog, even contacting corporate representatives directly can be unhelpful. “It’s difficult because a lot of times they have no idea and they will just say yes. … Brands that I know aren’t cruelty- free … I have had PR people tell me that they are.”

Further muddying the waters is a product’s classification as a cosmetic or drug, which can determine whether it will be subjected to animal testing.

Further muddying the waters is a product’s classification as a cosmetic or drug, which can determine whether it will be subjected to animal testing.

In the U.S., the Food, Drug, and Cosmetic Act defines cosmetics as “articles intended to be rubbed, poured, sprinkled, or sprayed on, introduced into, or otherwise applied to the human body ... for cleansing, beautifying, promoting attractiveness, or altering the appearance.” Included are moisturizers, perfumes, makeup, fingernail polish, and hair coloring.

Cosmetics don’t require pre-market FDA approval, and there are no laws mandating animal testing, or specific tests of any sort, for these products. While manufacturers and marketers are legally responsible for ensuring their products’ safety, the FDA has no regulatory authority over cosmetics, aside from banning the use of certain toxic and carcinogenic substances. It simply advises that safety be substantiated, stating that this can be done through “reliance on already available toxicological test data on individual ingredients and on product formulations that are similar in composition to the particular cosmetic.”

On the other hand, drugs are defined as “articles intended for use in the diagnosis, cure, mitigation, treatment, or prevention of disease” and “articles (other than food) intended to affect the structure or any function of the body of man or other animals.” Thus, a deodorant crosses into the over-the-counter drug category when an antiperspirant is added, as does toothpaste with fluoride, moisturizer with sunscreen, skin cream with wrinkle-reducing ingredients, shampoo with dandruff treatments, and so on.

These cosmetic drugs are subject to FDA pre-market approval, which may or may not require animal testing. Many OTC items can be approved through comparison to specifications for already existing products, known as “monographs.” When monographs don’t exist, such as for a novel ingredient, testing must be done.

Go back to feature story: "Do You Know How Your Mascara Is Made?"

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