Julia, please fill us in on the background to ECHA’s proposals
To comply with the EU Cosmetics Regulation bans on animal testing, which were fully implemented in March 2013, ingredients cannot be used in cosmetic products if they have been tested on animals anywhere in the world. This regulation is seen as the gold standard around the world – and a win for everyone who does not want their cosmetics to be tested on animals.
It has also paved the way for similar animal testing bans in more than 40 countries so far. In October 2018 Unilever was the first major international company to announce its support for a global ban on the animal testing of cosmetics.
But the new proposals from ECHA appear to contradict it. In August 2020, ECHA said that certain substances must be tested on animals even if they are solely for use in cosmetics. They say this is to assess any risks to workers in factories during product manufacture.
Which ingredients are we talking about?
The two chemicals for which ECHA mandated animal testing in August were sunscreens, the UV filters homosalate and 2-ethylhexyl salicylate. But there are hundreds of other ingredients used widely in many consumer products for which new animal testing is being requested.
You don’t believe such testing is necessary?
Absolutely not. Workers’ safety is non-negotiable. However, with the scientific tools we have available to us in the 21st century, we don’t believe that new tests on animals are needed to achieve this. The ingredients at the centre of ECHA’s testing decisions have a long history of safe use by consumers, and have been handled safely in factories for many years by ensuring effective exposure-based assessments and controls are in place.
Also, to comply with the EU’s laboratory animal protection legislation we should be maximising the use of non-animal assessment approaches to avoid unnecessary animal testing. We must therefore have the opportunity to apply our new scientific ‘next generation’ non-animal capabilities, mainly developed to comply with animal testing bans under the EU Cosmetics Regulation, also under the EU’s chemicals regulations. We use these non-animal approaches every day to make robust science-based decisions on the safety of Unilever’s products, ensuring we protect people and our planet.
These aren’t new ingredients?
No. These ingredients have been handled safely in factories – and used safely by consumers – for many years. ECHA’s assertion that there should now be more tests in animals, which will involve the use of many thousands of animals primarily for administrative reasons rather than to better protect the health and safety of workers, is a significant threat to the progress that our industry has made towards ending animal testing for cosmetics and other consumer products.
So why is ECHA doing this?
ECHA has recently reviewed old dossiers under the EU Chemicals Regulation, REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals). They concluded that in some cases animal tests should be conducted, whereas at Unilever we are confident we can assure the safety of these existing ingredients without new animal testing.
There are also proposals to amend various annexes to one of the REACH regulations which will significantly increase the number of animals needed for compliance purposes. The amendments proposed would further restrict the science-based application of non-animal approaches, and force additional animal testing for classification of substances which are manufactured or imported in relatively small volumes.
What’s Unilever’s position?
We categorically do not agree that animal testing is necessary to ensure safety and strongly encourage the use of new scientific knowledge and non-animal data. We believe that the lessons we have learnt from doing non-animal product safety assessments over many years can be applied to assessing the safety of ingredients to protect the workers in our factories.
The future of chemical safety assessment is animal-free and it’s time to embrace modern, human-relevant, non-animal scientific approaches for regulatory decision-making. Anything else is a step backwards – for animals, for consumers and for scientific and societal progress.