Our presentation, at ECHA’s headquarters in Helsinki, showed a joint proposal from five animal protection NGOs, including Cruelty Free Europe, to reduce animal testing through measures which would serve to strengthen the requirement to only use animal testing as a last resort.  

The last resort requirement, which states that animal testing should only be conducted if there is no other way to assure the safety of new chemicals, was introduced through the EU’s main chemicals law, REACH, in 2007, but is yet to be effectively implemented.  

Under REACH, when certain types of animal tests are planned, a testing proposal has to first be submitted to ECHA. After the proposal to conduct animal testing is made, a public consultation is opened so that new information can be submitted, potentially meaning that the animal test is avoided. Such proposals are currently only required ahead of some types of tests that are performed with substances which are produced in high volumes. Expansion of this requirement to any new test on animals would help improve adherence to the last resort rule. 

We showed our support for the recommendations that the European Commission has already made to improve the testing proposal process by extending it to all new tests on animals – irrespective of the volume. The five NGOs also put forward several other recommendations, including: 

• the lengthening of the public consultation period; 

• the ability to submit proposals for testing for groups of substances; 

• adding a requirement to supply a justification document alongside each proposal to explain why non-animal approaches were not possible; and  

• ECHA being available to talk with registrants before they submit their testing proposals.  

Together, the recommendations from the Commission and the animal protection NGOs would reinforce compliance with the last resort requirement by helping to ensure that every effort is made to consider available non-animal approaches, and all existing data, prior to a new test being performed on animals. These recommendations would also help to strengthen the scientific rigour of chemical safety assessments and increase transparency on the types of animal tests being performed. 

Our Senior Chemicals Regulatory Advisor, Dr Charlie Stevenson, who gave the presentation on behalf of the five NGOs said: “A number of these proposals are already common practice and would benefit from being formally written into legislation. Most significantly, an expansion of the testing proposal provision would serve to improve adherence to the legal requirement to perform tests on animals only as a last resort.”