Insisting that regulators "use science, not animals," Unilever is demand that the European Chemicals Agency resist calls for some ingredients that have been widely – and safely – used for years to undergo new animal testing.

In an open letter, Unilever noted that the EU Cosmetics Regulation animal testing and marketing bans have been used as the gold standard around the world – setting the precedent for cosmetics products and ingredients to be used safely without subjecting animals to cruel and unnecessary tests.

"These bans have now been dealt a devastating blow following a series of regulatory decisions made by the European Chemicals Agency (ECHA), with support from the European Commission and ECHA's own Board of Appeal.

"ECHA is now requiring some widely used cosmetics ingredients (and ingredients used in many other types of consumer products) to be tested on thousands of animals under the guise of the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulation. As a direct result of these decisions, the use of thousands of rats and rabbits in tests is required, some of whom will be force-fed a cosmetics ingredient throughout pregnancy before they and their unborn offspring are killed and dissected. REACH must not be used to circumvent the Cosmetics Regulation and render the cosmetics testing and marketing bans meaningless.

"The approach of ECHA and the Commission is at odds with the European Parliament’s call in May 2018 for a worldwide ban on testing cosmetics on animals by 2023. It undermines the purpose and value of the Cosmetics Regulation, which many of us have worked determinedly over many years to shape, implement and leverage with non-EU countries in developing their own cosmetics legislation.

"The approach also has consequences for citizens around the globe who want to purchase cruelty-free products: 84% of respondents to a recent global survey said they would not buy a cosmetics product if they knew it (or one of its ingredients) had been tested on animals.

"The bans are further threatened by the Commission's future policy for chemicals regulation – the Chemicals Strategy for Sustainability – which is set to expand testing requirements for substances including cosmetics ingredients, at the cost of potentially thousands of animals' lives.

"One of the principal objectives of the Cosmetics Regulation is the protection of human health, with the intention that this be safeguarded in all situations. The ingredients at the centre of ECHA's decisions have a long history of safe use by consumers and have been handled safely in factories for many years. It is perfectly possible to use exposure-based weight-of-evidence assessments, using a variety of non-animal data, to fill any perceived critical information gaps in order to be assured of the safety of these ingredients.

"Indeed, as clarified by the Court of Justice of the European Union in the 2016 European Federation for Cosmetic Ingredients case, new safety-assessment data for cosmetics substances imported into the EU must rely only on non-animal assessment methods. Logically, precisely the same approach must be adopted for testing within the EU, whether under REACH or any other EU legislation. We call for the EU cosmetics animal testing ban to be upheld as intended, with no new tests on animals allowed."

See all the companies, brands and animal protection agencies which co-signed this open letter (PDF | 340KB).