The European Commission has replied to our open letter, which urged Commissioners to protect the European bans on animal testing for cosmetics, and ensure that the EU’s roadmap to phase-out the use of animals in chemical safety assessments delivers real change.

The reply states that the Commissioners “share your vision for a future where innovation thrives without the use of animals” and “reaffirm the importance of upholding the ban on animal testing for cosmetics”. The reply was signed by EU Executive Vice-President for Prosperity and Industrial Strategy, Stéphane Séjourné, and Jessika Roswall, Commissioner for Environment, Water Resilience and a Competitive Circular Economy. In addition to Séjourné and Roswall, our letter was also addressed to Commissioner for Health and Animal Welfare, Olivér Várhelyi.

The Roadmap is due to be published by the end of March, or shortly thereafter.

Séjourné and Roswall “fully share the view that continued investment in innovative approaches is essential to achieve a progressive phase-out of animal testing”. They say that “the roadmap will underline the ambition of the EU as a global leader in humane scientific innovation. It will indicate a clear path towards a long-term switch to animal-free regulatory assessments, with concrete recommendations for the short- to medium term.”

Coordinated by Cruelty Free Europe, the letter sent in September 2025 was signed by nine MEPs from across the political spectrum, as well as 14 animal protection NGOs. It made three requests:

• Defend and strengthen the bans on animal testing for cosmetics to uphold the promise made to EU citizens;
• Promote cruelty-free scientific innovation by taking steps to boost the development and regulatory acceptance of non-animal methods;
• Ensure the forthcoming roadmap is ambitious, actionable, and delivers real change. It should serve as a launch pad for a broader EU strategy to enable the phase-out of animal testing across all areas of science, positioning Europe as a global leader in humane, human-relevant innovation.

Whilst this response could indicate agreement on the need for a more coordinated approach, and has an encouraging tone, it remains to be seen how far the Roadmap and upcoming legislation will go in addressing the longstanding inconsistencies between public opinion, political commitments and regulatory action across the wider chemicals regulatory framework. This is particularly relevant in light of ongoing concerns about the way different pieces of regulation interact, in particular the Cosmetics Product Regulation and the REACH regulation, and the undermining of EU policy objectives to phase-out of animal testing.

Currently, the REACH regulation triggers animal tests through its requirement for companies to generate data on chemicals even where they are used exclusively in cosmetics; this is despite the promises made that the animal testing bans brought into the CPR would mean that no animals are harmed for the sake of cosmetics. Atthe time the bans were proposed, the Commission said ‘it is essential that the aim of abolishing animal experiments be pursued and that the prohibition of such experiments becomes effective’. Later, in 2013, the EU said ‘there can be no new animal testing for cosmetics purposes in the Union – be it for cosmetics products or ingredients thereof’.

However, in 2023, the ban was made virtually meaningless by a European Court of Justice ruling which forced animal testing under the REACH regulation on two ingredients used only in sunscreens.

In 2023, the European Commission promised to start planning the total phase-out of animal testing for all chemical safety assessments, in their response to the ‘Save Cruelty Free Cosmetics – Commit to a Europe Without Animal Testing’ European Citizens’ Initiative. This initiative was signed by over 1.2 million people to demand the protection and strengthening of the EU cosmetics animal testing bans, the transformation of chemicals legislation and modernisation of science in the EU by signing. The ECI which was launched by a coalition of European animal protection groups including Cruelty Free Europe.

Finally, we are very concerned that under the EU’s plans to revise the Cosmetic Products Regulation (CPR), the bans on animal testing for cosmetic products and their ingredients could be even further weakened. The revision of this cornerstone regulation is a chance to do the opposite – to strengthen the bans and ensure that they do uphold the promise made that there would be no new animal testing for cosmetics purposes.

Our Director of Science and Regulatory Affairs, Dr Emma Grange, said: “We remain very concerned about what the European Commission has in mind for the revision of the Cosmetics Product Regulation. In our view, it is already not fit for purpose, and the regulation must be strengthened, not weakened. In line with the

Commission’s roadmap to phase-out animal testing for chemical safety assessment, innovation within EU industry must be supported by investing in humane, modern non-animal testing methods delivering a high level of protection for human health and the environment.