The vast majority of our products reach consumers without testing any of their ingredients on animals. Our commitment to eliminating animal testing is underpinned by our work since the 1980s in developing and using alternatives to animal tests for assessing safety, eg biological and computer-based modelling and cell-based ‘in vitro’ methods.
Since 2004 we have made an additional €3 million a year investment in an innovative research programme on novel non-animal approaches for assessing the consumer safety of the ingredients in our products. Unilever’s conceptual framework for safety assessment is risk-based rather than hazard-based.
This means that before experiments to test a new product even begin, all the available data (including levels of exposure and types of ingredients) is analysed to judge the level of risk that can be attributed to each individual ingredient used. At this stage of the process, such procedures can overcome the need for animal testing.
We are making good progress in developing a non-animal approach for assessing ingredients which may cause skin allergy. To encourage acceptance of this new approach we continue to present and publish our results externally, and are working with international research and policy groups to share our experience.
In 2012 the risk-based approaches we are developing for assessing consumer safety were discussed with leading scientists, policy-makers, regulators and animal welfare organisations at key meetings in the EU, US and China, eg a joint Unilever–Chinese State Food and Drug Administration (SFDA) workshop on alternatives to animal testing for cosmetics safety assessment was held in Beijing in August 2012, which also involved two experts from leading institutions in the US.
Unilever is committed to the elimination of animal testing. We are equally committed to consumer health and safety, and to the safety of our workforce and the environment. We do not test finished products on animals unless demanded by the regulatory authorities in the few countries where this is the law. In such cases, we try to convince the local authorities to change the law. Where some testing of ingredients is required by law or currently unavoidable, we aim to minimise the number of animals used.
In pursuit of these goals, Unilever on the one hand applies strict internal control procedures to ensure that animal testing is only carried out when no alternatives are available and, on the other hand, invests in developing and applying alternative approaches to replace animal testing in safety assessments for consumer products.
By adopting this dual approach, we advance the elimination of animal testing and reduce the number of tests to the absolute minimum. We provide transparency both in the use of animals and in the progress made in developing alternative approaches.
How we act
At Unilever, using non-animal approaches is the norm and animal testing is the exception. Before any animal testing is carried out, Unilever’s internal control procedures require senior management to certify that there is no other way of proceeding. Unilever does not undertake animal testing, or commission others to do testing on its behalf, unless it is necessary to meet its health, safety and environmental obligations or it is demanded by government regulators or other official bodies.
When there is a need to generate new safety and efficacy data in support of product development, non-animal methods and studies with human volunteers are used to the maximum extent. Unilever develops products which can contribute positively to the health and well-being of consumers.
When developing these products, for ethical reasons it is not always possible to carry out tests directly on humans. Therefore, novel ingredients may have to be tested on animals first. Animal studies may need to be performed to establish the mechanism of action underpinning the health benefits of these ingredients as well as to assess their safety.
The EU has introduced a ban on the import and sale of cosmetic products that contain ingredients tested on animals after 11March 2013. Unilever will comply with this EU marketing ban, as well as with all other relevant regulations in and outside the EU. We will never compromise on the safety of our products and will not market products unless we have robust scientific evidence that they are safe for consumers, our workforce and the environment. The ban will not impact any existing products on the market.
However, implementation of the EU Cosmetics Regulation, before the non-animal approaches needed to ensure consumer safety are accepted by regulators, will prevent us marketing new products containing novel cosmetic ingredients with consumer benefits. We are therefore continuing to work with regulators on the acceptance of non-animal approaches.
Unilever's research investment
Scientists at our Safety & Environmental Assurance Centre (SEAC) have played a leading role, in partnership with academic researchers, other companies, industry groups and validation bodies, eg the European Centre for the Validation of Alternative Methods (ECVAM), in the development, validation and subsequent regulatory acceptance of several non-animal methods for use in safety assessment.
These include methods for assessing skin penetration, phototoxicity, skin corrosion and skin irritation. Our research is currently focused on finding alternative approaches for assessing the potential for chemicals to cause skin allergy and skin cancer. We have published more than 300 scientific articles on the development and application of alternative approaches to consumer safety risk assessment, and regularly present our ongoing research at scientific conferences.
During 2012, SEAC’s work on proposed risk assessment approaches for assuring consumer safety without animal testing resulted in 23 scientific publications. In August 2011, Dr Julia Fentem (R&D Vice President and Head of SEAC) was awarded the prestigious Russell and Burch Award from the Humane Society of the United States for her leadership and outstanding contribution to the advancement of alternative methods.
An example of our scientific partnerships with external organisations in this area is the work that many Unilever staff undertake with Cosmetics Europe (the European cosmetics trade association) on approaches to replace animal testing. As part of this work, Cosmetics Europe initiated a five-year research programme jointly with the European Commission (a total of €50 million in research funding) to help develop the tools that will ultimately make non-animal safety assessments for systemic toxicity possible.
Unilever was a founding member of the European Partnership for Alternative Approaches to animal testing (EPAA). Launched in 2005, EPAA is a voluntary collaboration between the European Commission, trade associations and companies from seven industry sectors. It promotes the development and implementation of alternative methods for safety testing, and in 2012 progressed several initiatives on international co-operation. Unilever is the industry co-chair of EPAA in 2013.
SEAC is working in strategic partnership with the Hamner Institute in the US on non-animal pathways-based approaches to safety assessment, as proposed in the US National Research Council’s report ‘Toxicity Testing in the Twenty-First Century: A Vision and a Strategy’.
To progress this new ‘pathways’ approach, Unilever is an active member of the EU AXLR8 project and the US-led Human Toxicology Project Consortium, and is involved in relevant OECD and EU Commission activities such as those on applying the adverse outcome pathway framework for assessing chemicals that may cause skin allergy.