As of October 2026. This dossier accompanies the Instagram carousel by @derveganist. All figures are referenced in the sources below.

Summary

“Vegan”, “not tested on animals” and “cruelty free” are three different claims. None of them is legally protected, and none covers the others. In the EU, animal testing for cosmetics has been banned since 2013, and that applies to every product on the shelf, with or without a bunny. The ban does have two loopholes, though: tests for other countries and tests under the chemicals regulation REACH. And the argument “we don’t sell in China because animal testing is mandatory there” has only held to a limited extent since 2021 and hardly at all since July 2026.

Three terms, three meanings

Term	What it says	What it does not say
Vegan	No animal ingredients.	Nothing about animal testing. That depends on the specific label.
Not tested on animals	For labels: no new animal tests after a fixed cut-off date, neither by the manufacturer nor by its suppliers.	Nothing about ingredients. Carmine, lanolin, beeswax or collagen are allowed.[7]
Cruelty free	The same as “not tested on animals”, just in different words.	The term is not legally protected. Anyone can print it on the packaging.

The example that explains it all: carmine (CI 75470, E 120) is a red dye made from dried and crushed cochineal insects.^[12] A lipstick containing carmine can carry the Leaping Bunny logo, because the label explicitly checks animal testing only, not ingredients.^[7]

Not all labels are equal

	PETA “Animal Test-Free”	Leaping Bunny
Basis	A signed declaration by the company (Statement of Assurance). PETA itself calls this a matter of trust.[7]	A fixed cut-off date after which no animal testing may take place.[7]
Suppliers	Contractual assurances from suppliers, but no documents required.	Written declarations from every raw material supplier (supplier monitoring).
Oversight	No external audits.	Independent audits every few years, annual recommitment.
Parent company	Does not have to be certified.	Does not have to be certified. The brand must operate as an independent unit with its own supply chain.
Ingredients	Only checked with the additional “Vegan” label.	Not checked. Leaping Bunny: “We are not a vegan certifier.”

The cut-off date is key to understanding the principle: almost every cosmetic raw material was tested on animals at some point. “Never tested” practically does not exist. That is why labels only say: not after this date.

What applies in the EU

Regulation (EC) No 1223/2009 bans animal testing for cosmetics in three stages:^[1]

1. 11 September 2004: No more tests on finished cosmetic products.
2. 11 March 2009: No more tests on ingredients. First marketing ban, with the exception of three complex types of tests.
3. 11 March 2013: Complete marketing ban. Nothing that was tested on animals to meet the requirements of the EU Cosmetics Regulation may be sold in the EU. Not even if there is no animal-free method.

This applies to every cosmetic product sold in the EU. To the drugstore’s own brand just as much as to the natural cosmetics with the bunny.

Can “not tested on animals” even appear on packaging in the EU?

That is more complicated than it sounds. Two rules apply at the same time.

Rule 1: Article 20(3) of the Cosmetics Regulation allows the claim that no animal tests were carried out only under a very strict condition: neither the manufacturer nor its suppliers may ever have carried out or commissioned animal tests on the product, its prototype or any of its ingredients, and no ingredients may be used that others have tested on animals for the development of new cosmetics.^[1] According to Commission Recommendation 2006/406/EC, it does not matter where or when the test took place.^[1] Very few brands can prove this.

Rule 2: Regulation (EU) No 655/2013 sets common criteria for cosmetic claims. The criterion of “legal compliance” prohibits claims that suggest a special benefit when in fact they only reflect compliance with minimum legal requirements.^[2] Industry associations such as the British CTPA and several legal experts read this as follows: “not tested on animals” is, in the EU, advertising with the minimum standard, because every product on the shelf could say the same.^[2] The Commission’s Technical Document on Cosmetic Claims (2017) does not use this example verbatim; it names hydroquinone as an example instead. The interpretation is nonetheless widespread and was put forward by member states in the Commission report of 2016.

Conclusion: legally, the bunny is a borderline case. For the product on the shelf, it is a given in the EU.

Loophole 1: Testing for China and selling in the EU?

This is the point most people don’t know. In 2016, the European Court of Justice ruled in case C-592/14 (EFfCI): the marketing ban applies when animal testing data from other countries is used to demonstrate the safety of the product for the EU market.^[3] If a company tests the same ingredient to meet another country’s regulations and does not use the data for the EU safety assessment, sales in the EU remain permitted. There is no blanket ban on animal testing for other markets.

The tests must be documented in the product information file, explicitly including those carried out to meet the regulations of non-EU countries.^[1] Documented does not mean prevented.

Loophole 2: The EU itself orders animal tests

Alongside cosmetics law, the chemicals regulation REACH applies. Under it, the European Chemicals Agency ECHA can still require animal tests for substances that also end up in cosmetics.

The best-known case: in 2018, ECHA required the German manufacturer Symrise to carry out animal tests on the two UV filters homosalate and 2-ethylhexyl salicylate, which are used exclusively in sunscreen. Symrise refused, citing the cosmetics ban, and took the case all the way to the General Court of the EU. On 22 November 2023, Symrise lost (cases T-655/20 and T-656/20). The court’s reasoning: the cosmetics ban protects consumers. Workers in production are exposed to the substance differently, and their protection falls under REACH.^[4] According to Cruelty Free Europe, the required testing programme involves more than 5,500 rats, rabbits and fish.^[5] The ruling itself does not give a number of animals. An appeal to the European Court of Justice was announced.

Since then, Cruelty Free Europe has called the cosmetics ban “virtually meaningless”. That is overstated, but the core is true: the ban prevents animal testing for the EU safety assessment of cosmetics. It does not generally prevent animal testing on cosmetic ingredients.

Further limits of the ban

The cosmetics ban only applies to what is legally classified as a cosmetic. Medicines, medical devices and biocides have their own rules, and animal testing is partly mandatory there. Borderline cases include disinfectants, toothpaste with medical claims and sunscreen, which counts as a medicine in the USA or Australia. In Japan, animal testing is mandatory for “quasi-drugs”, which include products that would be cosmetics in Europe. For food and supplements, too, approvals for novel foods or health claims can require animal studies. A “vegan” label says nothing about this.

China: status 2026

For a long time, China was the only country that explicitly required animal testing for imported cosmetics. That was the main argument of many brands for not selling there, and the main argument of labels for excluding brands that did so anyway. This is no longer the case.

1. Since 2014: General cosmetics manufactured in China no longer require animal testing if a safety assessment is available.^[6]
2. Since 2018: Cosmetics that enter China via cross-border e-commerce (CBEC) are treated like personal imports. No registration, no animal testing, neither for general nor for special-use cosmetics.^[6]
3. Since 1 May 2021: Imported general cosmetics are exempt from animal testing if an official GMP certificate from the country of origin and a safety assessment are available.^[6]
4. Since 29 July 2026: The exemption also covers perm products, non-oxidative hair dyes, physical skin-lightening products and general cosmetics with new ingredients (except children’s cosmetics).^[6]

What still requires testing: sunscreen, oxidative hair dye, chemical skin lighteners, children’s cosmetics and products from companies without a recognised GMP certificate, in each case only for regular imports. Animal testing after market entry is not explicitly ruled out, but according to industry consultants it has not been practised for years, and companies can withdraw products instead of allowing tests.^[6]

Anyone who still has animal tests carried out for China today does so because they want to sell sunscreen, hair dye or children’s products through regular imports and forgo CBEC or local production. That is a business decision, no longer a compulsion imposed by the state.

Did the boycott help or hurt?

The question comes up often: wouldn’t the brands have achieved more if they had been present in China? The evidence suggests otherwise. China itself justifies the relaxations with alignment to the rules of its trading partners.^[6] The condition for the exemption, the official GMP certificate, was first issued by the British and French governments. NGOs such as PETA and the Institute for In Vitro Sciences trained Chinese laboratories in animal-free methods. Cruelty Free International and Humane Society International negotiated with the Chinese authority for years.^[11] The brands staying away was part of the pressure that led to this alignment. There is no evidence that being present while testing on animals would have sped up the change.

So what does a label still do for me when shopping?

Within the EU: nothing, when it comes to new animal tests for the EU safety assessment. The same law applies to all products.

A controlled label tells you three things that no law regulates: whether the supply chain is checked, whether the brand has testing done for other markets, and from when it stopped. What it does not tell you: whether the product contains animal ingredients, and what the parent company does.

The vegan position: veganism requires both

An animal test uses an animal as a tool. Carmine, lanolin or beeswax in a product use an animal as a raw material. For the animal, it makes no difference. In both cases, it is used for a product that nobody needs.

“Cruelty free” pretends that testing is the only problem. The word promises a product without cruelty and means just one kind of it. A vegan product needs both: no animal ingredients and no animal testing. More on the basics: warum-vegan.com.

Shopping checklist

1. In the EU, the bunny alone says nothing. What matters is whether a controlled label is behind it (Leaping Bunny) and whether the brand states clearly on its website whether it has testing done for other markets.
2. “Vegan” and “not tested on animals” are two different checks. You need both. The ingredient list (INCI) shows you carmine (CI 75470), lanolin, cera alba (beeswax), collagen, keratin, silk (serica).
3. Look at the parent company. The brand is only as honest as the company behind it, and that is where your money ends up.
4. Since 2026, the China argument mainly still holds for regular imports of sunscreen, oxidative hair dye, children’s cosmetics and brands without a recognised GMP certificate. Anyone using it for lipstick or shampoo has not read the new rules.
5. Products that are legally not cosmetics (disinfectants, medical toothpaste, medicines) are not covered by the ban.

Figures

In 2023, around 6.4 million animals were used in experiments of all kinds in the EU-27, and almost 8 million including Norway. 15.8 percent of uses served regulatory purposes, meaning safety tests required by authorities.^[8] Cosmetics-specific figures have not existed since 2009; they are part of the chemicals statistics. Between 2015 and 2023, more than 15 million animals were used for regulatory testing, almost 40 percent of them for chemical safety.^[9]

In response to the European Citizens’ Initiative “Save Cruelty Free Cosmetics” (more than 1.2 million signatures), the European Commission presented a roadmap for phasing out animal testing in chemical safety assessments on 1 June 2026. 22 measures, three pillars, no end date.^[9]

Sources

1. Regulation (EC) No 1223/2009 on cosmetic products, Art. 11, 18 and 20 · Commission Recommendation 2006/406/EC · European Commission, Ban on animal testing
2. Regulation (EU) No 655/2013 · European Commission, Technical Document on Cosmetic Claims (2017) · CTPA, Cosmetic Product Claims
3. Court of Justice of the EU, judgment C-592/14 (EFfCI), 21.09.2016, Press release 105/16
4. General Court of the EU, judgments T-655/20 and T-656/20 (Symrise / ECHA), 22.11.2023, EUR-Lex
5. Cruelty Free International, Statement on the Symrise ruling, 22.11.2023
6. China NMPA, Provisions for Management of Cosmetic Registration and Notification Dossiers (2021) · NMPA Announcement No. 70 (29.07.2026) · ChemLinked, China Cosmetic Animal Testing Regulation (as of 21.08.2026)
7. Leaping Bunny Corporate Standard and FAQ · PETA, Beauty Without Bunnies FAQ
8. European Commission, statistics on the use of animals for scientific purposes 2023 (ALURES) · EARA summary
9. European Commission, Roadmap towards phasing out animal testing for chemical safety assessments, 01.06.2026
10. Humane World for Animals, Cosmetics animal testing FAQ (2026)
11. ACTAsia (2021) · PETA/IIVS, training of Chinese laboratories in animal-free methods
12. European Commission, CosIng database, entry CI 75470 (Carmine)