Lush Lobbying Prize 2013

Background Paper

Lush Lobbying Prize 2013 – Background Paper - August 20131

1

Executive Summary

The Lush Prize seeks to reward excellence and innovation by organisations working
to end animal testing.
The Lobbying category focuses on policy interventions promoting the use ofalternatives:
Scientific innovation needs to go hand-in-hand with policy change to ensure that
end-users of new testing approaches – industry and regulators – are receptive andresponsive to the new methods. Such change requires a multifaceted, global
approach, including science-based lobbying at the national level or supra-national
level to:•Entrench non-animal testing methods in national, EU or OECD programmes oftest guidelines•

Revise existing guidelines to reflect best practices, including the removal ofanimal tests, or•Achieve a mandatory requirement for non-animal testing in legislation, regulatory
policies, testing guidance, etc.

The Lush Prize is not a 3Rs prize but a 1R prize. By this we mean it is only seeking
projects working on replacements (rather than reduction and refinement) and seeks
to avoid funding projects or initiatives linked to animal testing in other ways.

1.1 Key findings
Organisations opposed to animal testing are becoming increasingly skilled atlobbying at a variety of levels and are accepted by regulatory and legislative bodies
as informed and reliable stakeholders.
NGOs (Non-Governmental Organisations) have formed coalitions such as theInternational Council on Animal Protection in OECD Programmes, which was formed
to incorporate alternative methods that can replace, reduce, and refine animal use inOECD guidelines and programs.
The European Coalition to End Animal Experiments (ECEAE) has a stakeholder seatat the European Commission’s committee CARACAL (the Competent Authorities for
REACH and CLP, an expert group that advises the European Commission and theEuropean Chemicals Agency) and the European Chemicals Agency’s newcommittee, the Biocides Products Committee (BPC).
PETA India has an official seat on the Bureau of Indian Standards PCD 19
Cosmetics Sectional Committee meeting and the Soaps and other Surface Active
agents committee. This has been instrumental in their lobbying to successfully ban
cosmetics testing on animals.

Lush Lobbying Prize 2013 – Background Paper - August 20132

Lobbying initiatives by NGOs covered in this report have led to animal testing bans in
Europe, India and Israel in recent years.

1.2 Table of groups active in this sector
The core of this report is a table of NGOs active in the area of lobbying to end animal
testing. It covers dozens of organisations in Europe, Asia, Australasia and America.
Although there are thousands of organisations working in some way to createawareness and lobby regulators and industry to end animal testing, our focus has
been on those working to a larger extent on a national or international level andwhose campaigns specifically include topics relevant to the Lush Prize (rather thanon wider issues such as pharmaceutical research).

1.3 Conclusions and recommendations
This study analysed the lobbying work of dozens of NGOs around the world to
encourage industry and regulators to replace the outdated and unscientific use ofanimals with 21st century, cruelty-free methods. The following organisations havebeen shortlisted because they are recognised for their particularly effective work onthese issues. This list has been drawn up from a combination of nominations
received and additional NGOs identified during research for this report.
Stop Vivisection
A European Citizens’ Initiative calling for the repeal of European Directive
2010/63/EU ("on the protection of animals used for scientific purposes") and the
proposal of a new directive aimed at ending animal experiments and making the useof data relevant to humans in biomedical and toxicological research compulsory, inthe place of data obtained on animals.
This campaign makes use of the European Commission’s Citizens’ Initiative and ismade up of a committee consisting of scientists, activists and politicians.
HSI (Humane Society International) – Brazil
Brazilian national guidelines still recommend a series of tests on animals for thesafety evaluation of new cosmetics products and ingredients.
HSI’s Science Team is working with the Brazilian authorities and companies in thecosmetics and other sectors to gain acceptance and use of proven non-animal
methods and testing strategies and to update regulatory testing requirements to
replace or reduce animal testing to the greatest possible extent.
European Coalition to End Animal Experiments (ECEAE)
The coalition of 18 member NGOs in 11 countries is particularly active in scientificallyobjecting to animal testing under EU chemicals legislation REACH.

Lush Lobbying Prize 2013 – Background Paper - August 2013

3

The ECEAE:•

Has Expert Observer status at the ECHA, the body that is responsible for
implementing REACH•

Has a stakeholder seat at the ECHA’s new committee, the Biocides Products
Committee•

Has a stakeholder seat at the European Commission’s REACH committee
called CARACAL

Physicians Committee for Responsible Medicine (PCRM) – USA
PCRM are lobbying on the Chemical Safety Improvement Act to make it arequirement for the use of non-animal test methods where reasonably andpracticably available.
Many of the suggestions PCRM scientists provided to Congress in past hearing
testimony and meetings are included in the CSIA, but it urges Congress toharmonise the bill with the European Union law, which requires that new animal tests
only be conducted as a last resort, when all other methods of obtaining data havebeen used.
Center for Alternatives to Animal Testing
Actively lobbying for a legal implementation of 21 st Century Toxicity in the US and theEU, educating legislators and politicians about the urgent need for regulatorychange, and the availability of new methods.
PETA India
For its major role in the successful campaign to ban the testing of cosmetics onanimals in the country.
International Council on Animal Protection in OECD Programmes (ICAPO)
Working to incorporate non-animal testing methods into the activities of theOrganisation for Economic Co-operation and Development (OECD), co-ordinating
the development of chemical testing programmes and financial support for theInstitute for In Vitro Sciences to attend OECD expert meetings.
Forska Utan Djurförsök / The Swedish Fund for Research Without Animal
Experiments
For promoting the development and validation of replacement alternatives to animal
experiments and lobbying for Sweden to establish a centre for alternatives to animal
testing.

Lush Lobbying Prize 2013 – Background Paper - August 20134

2 Introduction
A great deal of progress has been achieved over the past twenty years in helping
change legislation to encourage non-animal testing methods. These changes not
only meet the expectations and demands of a public concerned about animal
protection but, given the unreliability of experiments on animals, provide safer
methods of testing new products for the consumer market.
The biggest recent success has of course been the EU-wide ban on testingcosmetics on animals and the marketing of any animal-tested cosmetics (even if
those experiments were conducted outside the EU). Similar bans have been
implemented in India and Israel, whilst China and Brazil’s insistence on animal
testing is being firmly challenged.
The use of animals in chemicals testing remains high on the agenda for many
NGOs. In Europe, toxicity tests required under REACH (Registration, Evaluation,
Authorisation and Restriction of Chemicals) usually involve the poisoning of guinea
pigs, rabbits, fish, birds, rats and mice.1 Lobbying has helped to significantly reduce
the number of animals used in testing for REACH, but scrutiny needs to be applied
to limit animal use as much as possible.
In the USA, the Chemical Safety Improvement Act of 2013 is currently the focus ofattention. Although, thanks to lobbying efforts, principles to replace and reduceanimal-based test methods have been integrated into the legislation, Congress isbeing urged to harmonise the bill with the European Union law, which requires that
new animal tests only be conducted as a last resort, when all other methods ofobtaining data have been exhausted. 2

3 Lobbying“Lobbying is the process of seeking to shape the public policy agenda in order toinfluence government (and its institutions) and the legislative programme.” 3
Public policy is dictated and influenced by a range of bodies and individuals, fromlocal government to the media, groups which are home to Key Decision Makers and
Key Opinion Formers.

3.1 What is effective lobbying?
Clearly each country has different political systems and governing operations, butsome lobbying techniques are universal and just need adapting to meet conditions
on the ground. Equally, “you will need to tailor your approach to accommodate the

1 REACH. ECEAE. Accessed 15.8.12
2 Physicians Committee Statement on the Chemical Safety and Improvement Act of 2013.
3 Lobbying: The art of political persuasion. Lionel Zetter. Harriman House, 2011

Lush Lobbying Prize 2013 – Background Paper - August 20135

personal and political sensibilities of a wide range of politicians”, even within an
individual political body.4
There are several key factors to making lobbying effective:
1. Be credible: the message has to be based on evidence and withstand scrutiny
and criticism.
2. Understand what you want and how to achieve it: Have a short-term and longterm strategy and fully understand what your objectives are.
3. Get involved at the earliest stage: This can be as early as political parties’
policy reviews or responding to government consultations on policy proposals.
Research shows that one in five MEPs believe that lobbyists do not provide
information in a timely enough manner. 5
4. Understand how policy is made at various levels (local, national,
international): “it helps to ensure that you arrive with the right arguments at
the right time.”6
5. Prepare a list of key stakeholders: keep this updated so you know who tolobby. Few people actually influence a decision, so strategic communication
with them is far better than mass briefings to people with little influence.
6. Establish relationships with Key Decision Makers and Key Opinion Formers:
Being on relevant consultation lists ensures that government seeks your input
at an early opportunity. This is known as ‘insider campaigning’. “This status as
an insider will have been established through longevity, having developed a
track record of being a trusted source of policy and opinion”. 7 (Outsider
campaigning “involves attempting to influence decision-makers through theparticipation of the general public in lobbying action.”) 8
7. Know your opponent’s arguments: formulate what their strategy would be andwhat you need to put together a stronger case than theirs.
8. Use the media to impact both political and public opinion on your issue: achange in public opinion often leads to a corresponding change in politicalopinion rather than the other way around.
9. Form a coalition: this shows a common cause which can have a greater
impact on policy makers, who crave consensus. Managing the differing key
messages and ‘rivalries’ amongst coalition organisations can be difficult, so“ad hoc and temporary issue-specific coalitions can be just as influential as
4 A Common Sense Guide to Effective Lobbying on Capitol Hill. Pete Levitas. Antitrust, Vol. 21, No. 2, Spring2007. The American Bar Association.
5 Quoted in Robert Mack 2005. Lobbying effectively in Brussels and Washington – Getting the right result.
Journal of Communication Management. Vol. 9, 4, 339-347.
6 A Guide to Effective Lobbying In Europe 2009. Burson-Marsteller, 2009.
7 Lobbying: The art of political persuasion. Lionel Zetter. Harriman House, 2011
8 A Guide to Effective Lobbying for Women’s Groups in Ireland. The National Women’s Council of Ireland, 2006.

Lush Lobbying Prize 2013 – Background Paper - August 20136

longstanding partnerships.”9(For further information on effective lobbying read Lobbying: The art of politicalpersuasion,10 which covers UK administrations in detail as well as examining USA,
Brussels, Asia, Arabian Gulf and Middle East; and The National Women’s Council of
Ireland’s A Guide to Effective Lobbying for Women’s Groups in Ireland 11 which gives
very useful information for lobbying as well as covering in detail the political situationin Ireland.)4 Key campaign issues
Key issues remain the same as those identified in 2012 research paper:• EU cosmetics animal testing ban• REACH• China’s demand for animal testing• Emerging countries – Brazil, China, India, Russia
In this updated report we look at what progress has been made on these issues andwhich NGOs have been particularly active and successful.

4.1 EU cosmetics animal testing ban
4.1.1

Introduction

Testing cosmetics products and their ingredients on animals has been banned inEurope since 2009. Since then, any animal testing done for products sold in Europe
has been done in other countries, with around 27,000 animals being used each year
outside the EU for this purpose.12
At the time of producing the 2012 research paper for the Lush Prize, it was still legal
to sell cosmetics in the EU which had been tested on animals in non-EU countries.
The European Commission had set a deadline of March 2013 for a full marketingban to come into place but many NGOs expressed concern that this could be further
delayed because of perceived difficulties with finding non-animal testing methods forthree ‘toxicological endpoints’: repeated dose toxicity, reproductive toxicity andtoxicokinetics.

9 A Guide to Effective Lobbying In Europe 2009. Burson-Marsteller, 2009.
10 Lobbying: The art of political persuasion. Lionel Zetter. Harriman House, 2011
11 A Guide to Effective Lobbying for Women’s Groups in Ireland. The National Women’s Council of Ireland, 2006.
12 European Commission MEMO: Questions and Answers: Animal testing and cosmetics. 11 March 2013.

Lush Lobbying Prize 2013 – Background Paper - August 20137

NGOs opposed yet another extension to the marketing deadline. The BUAV (British
Union for the Abolition of Vivisection) stated:13 “there are insufficient scientificgrounds for any extension to the 2013 deadline. Extending the deadline will notsignificantly help the cosmetic industry. Any extension would instead remove the
incentive to validate and accept the alternatives that already exist. This would be ahighly retrograde step.” Eurogroup for Animals added: 14 “Our interest is not increating new deadlines for the full introduction of the marketing ban, but in ensuringthat the 2013 deadline remains in place regardless of the availability of alternative
methods.”
The marketing ban did finally come into force on 11 March 2013, meaning thatcosmetics tested on animals can no longer be sold in Europe, even if the testing
happened outside the EU.
According to the European Commission, where a ‘conclusive safety assessment’cannot be carried out because data is missing and because new animal tests cannot
be conducted for cosmetics, “the respective ingredient should not be used.” Further,it points out that companies can no longer carry out testing for cosmetic products or
ingredients outside the Union and then use the data here to claim the safety ofcosmetics: “consumers can therefore be sure that the cosmetic use of an ingredientin Europe cannot be the reason for any new animal testing.” 15
In the light of the marketing ban there appears to be some mixed messages given to
the public about what it actually means. PETA has stated: 16 "The sales ban meansthat all new cosmetics products sold in Europe will no longer be tested on animals,
nor will they contain ingredients that were tested on animals, after the 11 Marchdeadline. You, can, therefore, buy any product in Europe, safe in the knowledge thatno new animal testing has been performed for that product and that no animals will
suffer and die in a laboratory for it."
The Animal Welfare Intergroup, however, points out: 17 “it should be noted that theCommission has interpreted the ban in such a way as to allow continued use ofingredients tested on animals to meet the requirements of ‘non-cosmetics related
legislative frameworks’. This means that there is still a loophole that needs to beclosed.”The European Commission confirms the concerns of the Intergroup. It points out 18
that “the majority of ingredients that go into cosmetics are ingredients that are also in
use in many other consumer and industrial products, such as in pharmaceuticals,
detergents, food, paints etc. They may therefore be subject to animal testing
requirements under these respective legal frameworks.” The Commission recognises
13 Meeting the Deadline of the 2013 EU Marketing Ban: A Scientific Review of Non-Animal Tests for Cosmetics.
14 Questions Impact Assessment: 2013 Implementation Date Marketing Ban Cosmetic Directive. Submission by
Eurogroup for Animals.
15 European Commission MEMO: Questions and Answers: Animal testing and cosmetics. 11 March 2013.
16 PETA UK: The New EU Cosmetics Testing Ban – Your Questions Answered
17 Entry into force of a full EU ban on animal testing for cosmetics welcomed but loophole needs to be closed
Intergroup 12/03/2013
18 European Commission MEMO: Questions and Answers: Animal testing and cosmetics. 11 March 2013.

Lush Lobbying Prize 2013 – Background Paper - August 20138

that the legislation most likely to require an ingredient also used in cosmetics to be
subject to animal testing is REACH and “it therefore is for Member States to assessand decide whether such testing for compliance with other frameworks is considered
to be falling in the scope of the 2013 marketing ban” 19
So, despite the success of the marketing ban, the best way for compassionate
consumers to be totally sure that products they buy do not contain even ingredientsthat continue to be animal tested for other purposes is to look for labelling such asthat of the Leaping Bunny Program. Companies certified by this scheme “may nottest their products or ingredients on animals regardless of any international
regulatory requirements and we will not allow testing for environmental toxicity. In
addition, the Leaping Bunny Program also certifies household products, which areunaffected by this new animal testing ban”.20
4.1.2

Ban due to extensive lobbying

Implementation of the 2013 marketing deadline is the result of effective lobbying at
Member State and EU-level. The ban applies even though non-animal testing
methods are not yet available in all cases. The EC states 21 that “this reflects a
sector-specific political choice by the European Parliament and the Council” and thata ban was not “dependent on the availability of a full set of replacement methods.”
It has long been clear that setting a deadline for the marketing ban has acted as anincentive for companies to work harder towards finding and implementing non-animal
methods of testing. The EC states 22 that it did not delay the 2013 marketing ban as it“could seriously diminish determination to swiftly develop alternative test methods”,
noting that the proposed ban has “been a key accelerator in relation to thedevelopment of alternative methods and have sent a strong signal far beyond thecosmetics sector and far beyond Europe.”
Despite the Commission’s apparent keenness to implement the marketing ban, it has
also commented.23 “considering that the non-availability of alternative test methods
could have an impact on the innovation in cosmetic ingredients and products and thecompetitiveness of the sector, the Commission will closely monitor the situation in
the coming years”. No doubt NGOs will keep a close eye on the situation to ensure
the ban is not relaxed in any way in any Member State.

19 Communication from the Commission to the European Parliament and the Council on the animal testing andmarketing ban and on the state of play in relation to alternative methods in the field of cosmetics. Brussels,
11.3.2013
20 The Coalition for Consumers Information on Cosmetics. FAQ about the EU Cosmetics Testing Ban. What
does the new European Union (EU) Cosmetics Regulation say about animal testing?
21 Communication from the Commission to the European Parliament and the Council on the animal testing andmarketing ban and on the state of play in relation to alternative methods in the field of cosmetics. Brussels,
11.3.201322 Communication from the Commission to the European Parliament and the Council on the animal testing andmarketing ban and on the state of play in relation to alternative methods in the field of cosmetics. Brussels,
11.3.201323 Communication from the Commission to the European Parliament and the Council on the animal testing andmarketing ban and on the state of play in relation to alternative methods in the field of cosmetics. Brussels,
11.3.2013

Lush Lobbying Prize 2013 – Background Paper - August 20139

4.1.3

Taking the EU ban to a global level

The EU ban on testing cosmetics on animals and marketing those products within
Europe is a hugely successful outcome of a 20 year campaign by numerous NGOs
and cosmetics companies across Europe. The European Cosmetics and Toiletries
industry is worth more than €70 billion and represents almost half of the global
market for cosmetics 24 so the importance of this achievement cannot be overstated.
The next step now is to take this success global.
The EC considers the ban can be used as an opportunity for the EU “to set an
example of responsible innovation in cosmetics with positive impact beyond Europe.
Impacts go beyond the cosmetics sector – the objective is to develop strategies thatwill lead to better and more predictive, faster and cheaper tools to assess consumer
safety of chemical substances.” It is eager to ensure that its new requirements are
adopted by other countries around the world, being “convinced that the overall longterm objective to replace animal testing wherever possible and to move to new waysof improved safety assessment will eventually be shared by many of the Union´s
trading partners, even though different regions may be at different steps of theprocess and the approaches to achieve the objective may differ.” It is “convinced thatthe issue of alternative test methods for cosmetics merits a prominent place on the
EU's trade and international cooperation agenda. It will endeavour to put theseissues on the agenda of all relevant multi and bilateral meetings in the cosmetics
field in 2013, notably with the United States and China, but also in contacts with
Brazil and India. The Commission will in this effort look for synergies with theinternational initiatives of industry and animal welfare organisations”. 25
Two comparative initiatives by NGOs aim to take the cruelty-free cosmetics message
and the success of the EU-level lobbying to audiences, industry and governments
around the world:
Humane Society International’s (HSI) Be Cruelty-Free campaign:
Launched in 2012, Be Cruelty-Free has been rolled out across the United States,
Canada, Australia, New Zealand, Brazil, India, South Korea, Russia and Taiwan.
HSI offices work in partnership with local organisations in these key regions, as wellas cruelty-free companies, national cosmetics regulators and supportive policymakers.
Cruelty Free International, an initiative of the BUAV:
Also launched in 2012, CFI has partner organisations in 22 countries.
During 2013, CFI have:

24 European Commission MEMO: Questions and Answers: Animal testing and cosmetics. 11 March 2013.
25 Communication from the Commission to the European Parliament and the Council on the animal testing andmarketing ban and on the state of play in relation to alternative methods in the field of cosmetics. Brussels,
11.3.2013

Lush Lobbying Prize 2013 – Background Paper - August 201310

• Met with regulatory authorities in China with the aim of gaining acceptancethere for alternatives to testing on animals.

• Given a keynote speech at Asia’s premier cosmetics industry event attended
by the region’s leading cosmetics industry regulators.

• Given a keynote speech to the North American Sustainable Cosmetics

Summit in New York, highlighting the global trends in ending animal testing forcosmetics.

• Given a presentation to Food and Drug Administration's hearings on US policy
in cosmetics regulation, urging it to follow Europe’s lead.

• Funded non-animal alternatives in Vietnam, the only country of the 10

members of the Association of South East Asian Nations to actively test
cosmetics on animals. CFI has provided a grant for a detailed scoping study
by alternatives experts The Institute for In Vitro Sciences.

• Met with the Ministry of Health, the Food and Drug Administration and theCosmetics Association in South Korea.

4.2 REACH
REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is theEuropean Community Regulation on chemicals and their safe use (EC 1907/2006)
which entered into force in 2007. Its aim is “to improve the protection of humanhealth and the environment through the better and earlier identification of the intrinsic
properties of chemical substances”.26
REACH requires manufacturers and importers to collate information on theproperties of all chemicals sold in the EU in annual quantities of more than one
tonne, and to register the information, along with toxicity data, in a central databaserun by the European Chemicals Agency (ECHA) by 2018. The required test methods
are described in OECD (Organisation for Economic Cooperation and Development)
guidelines.27
The first phase of REACH envisaged the registration of 30,000 chemical substances,
but the total number of substances submitted by the 2008 deadline for registration
was 143,000.28
Many of the testing methods specified by REACH use animals. Toxicity tests usually
involve the poisoning of guinea pigs, rabbits, fish, birds, rats and mice. 29
26 REACH. European Commission 6.6.12 (last updated). Accessed 15.8.12
27 OECD Guidelines for the Testing of Chemicals. OECD.. Accessed 16.8.12
28 REACH, animal testing, and the precautionary principle. Andre Menache & Candida Nastrucci. Medicolegal
and Bioethics, August 2012, Volume 2012:2 Pages 13 – 29. Accessed 16.8.12
29 REACH. ECEAE. Accessed 15.8.12

Lush Lobbying Prize 2013 – Background Paper - August 2013

11

The use of animals in testing to meet REACH requirements is huge. The Health and
Safety Executive, the UK’s Competent Authority for REACH, estimates that “for asingle substance, with no pre-existing data, and no attempt to minimise animal
testing, registration and subsequent fulfilment of the information gaps could require
over 5,000 animals, assuming little or no avian testing.” 30
The total numbers of animals who could be used in testing have been estimated to
be as high as 54 million and to cost €9.5 billion.31
Lobbying conducted by NGOs helped to significantly reduce the number of animals
used in testing for REACH. Non-animal testing methods were not even mentioned in
the 2001 White Paper, but due to lobbying this became a major issue high up on theagenda of the EU 32 and a number of changes were made:33
1. Mandatory sharing of animal test data: companies registering the samechemical are obliged to share their data and, if animal testing is required by
REACH, the tests will only be done by one of the registrants. Duplicate animal
testing should thus be prevented.
2. For some chemicals approval must be given by the ECHA before new animal
tests can be performed. The public and NGOs have 45 days during which tocomment, challenge the need for the tests, or suggest alternatives.
3. Alternatives to animal testing are strongly promoted throughout the REACH
text which stresses that animal testing must only be undertaken as a lastresort.

The ECEAE is one NGO coalition that has been particularly active on REACH.
Further details of its campaign are listed in section 6.3 below, but this includes
having Expert Observer status at the ECHA, the body that is responsible for
implementing REACH, and being a member of the International Council on Animal
Protection in OECD Programmes, commenting on testing guidelines. 34

4.3 Emerging countries – Brazil, China, India, Russia
Whilst Europe leads the world’s market for perfumery and cosmetics, followed by the
US and Japan, a number of other markets are in continuous expansion. In particular,
China, Brazil and Russia, “motivated by the gradual access of their population to
fragrances and personal care products”. 35
30 REACH - Minimisation of Animal Testing. Health and Safety Executive, January 2010. Accessed 15.8.12
31 Opinion: Chemical regulators have overreached. Thomas Hartung & Costanza Rovida. Nature 460, 10801081.
32 REACH - cruel and unscientific mass animal testing. Ärzte gegen Tierversuche. Accessed 29.8.12
33 REACH – the new EU chemicals law: An RSPCA information paper. Accessed 15.8.12
34 What We’re Doing. ECEAE. http://www.eceae.org/en/what-we-do/campaigns/reach/what-were-doing-reach.
Accessed 15.8.12
35 Revision of European Ecolabel Criteria for Soaps, Shampoos and Hair Conditioners. Market Analysis. Albert
Ferrer et al. JRC, European Commission. January 2012

Lush Lobbying Prize 2013 – Background Paper - August 201312

4.3.1

BrazilThe Brazilian cosmetics market is the fastest growing in the world. 36
Brazilian national guidelines still recommend a series of tests on animals for thesafety evaluation of new cosmetics products and ingredients. The National Agency
for Sanitary Surveillance (ANVISA) continues to rely heavily on toxicity tests using
rabbits, guinea pigs and other animals to assess the safety of ingredients and evensome finished products.37
However, NGOs are confident that, according to HSI, “Brazil will advance the use ofalternative methods through the National Network of Alternative Methods(RENAMA). The National Council for Scientific and Technological Development isinvesting $1.1 million in RENAMA for alternatives to animal testing”. 38
HSI has been working with scientists there to establish non-animal testing
methods.39 “HSI’s Science Team is working with Brazilian authorities and companies
in the cosmetics and other sectors to gain acceptance and use of proven non-animal
methods and testing strategies and to update regulatory testing requirements to
replace or reduce animal testing to the greatest possible extent.”
In November 2011, HSI co-sponsored a training course “to better familiarise
government authorities and industry scientists with internationally recognized nonanimal tests. The event was very successful as it gathered broad participation ofBrazilian regulators, industry and university scientists. The cosmetics sector wasparticularly well-represented, and expressed its willingness to further explore
regulatory aspects of cosmetics testing in Brazil.”
4.3.2

China

China is the world’s fourth largest beauty market, worth an estimated US $22 billion
globally .40
China’s State Food and Drug Administration (SFDA) require animal toxicology test
reports to be provided prior to licensing a new cosmetic ingredient. 41 Due to theserequirements, some multi-national cosmetic companies which had not tested onanimals for two decades, such as Avon, Estée Lauder and Mary Kay, dropped thispolicy in order to sell in China.42

36 HSI asks the Brazilian government ban on animal testing for cosmetics. 11.3.13.
37 Rabbits and rodents of HSI and ProAnima visit the Ministry of Health to ask that the government put an end toanimal testing for cosmetics in Brazil. 13.3.13.
38 HSI asks the Brazilian government ban on animal testing for cosmetics. 11.3.13.
39 HSI’s Work in Brazil to Promote Non-Animal Testing. HSI, 15.12.11.
40 Be Cruelty-Free Campaign to End Cosmetics Animal Testing in China Launches with Pop Singer Wang Feifei,
NGOs and Industry. 28.6.13.
41 Registration of New Cosmetic Ingredient with SFDA in China. Yunbo Shi, March 2012. Chemical Inspection
and Regulation Service (CIRS). Accessed 14.8.12
42 Avon, Mary Kay, Estée Lauder Paying for Tests on Animals. Michelle Kretzer, 16.2.12.

Lush Lobbying Prize 2013 – Background Paper - August 201313

In 2012, Urban Decay, long known for its strong stance against animal testing, waslambasted for initially planning to submit to China’s testing regime. Followingpressure from various NGOs and customers, it quickly performed a U-turn anddecided not to market in the country. 43
Due to pressure not only from NGOs but also companies which have avoided animal
testing for other markets, China has started recognising test results that use
alternatives to animal testing.
March 2011 saw the first congress on alternatives to animal testing for cosmetics in
China, supported by major cosmetics companies.44 PETA says that its funding
allowed scientists at the Institute for In Vitro Sciences to travel to China to offer
expertise and guidance in replacing animal-based tests. In 2013, HSI announced an$80,000 partnership with the Institute for In Vitro Sciences to provide Chinesescientists with hands-on training using advanced non-animal methods. 45 The Institutesays China is making efforts and “has been receptive to investigating the use of welldeveloped and validated non-animal methods such as the 3T3 Neutral Red Uptake
test for phototoxicity. And this assay should be expected by the Food and Drug
Administration, sometime later this year or next year”. 46 The 3T3 Neutral Red Uptake
test is the only non-animal test to achieve official acceptance in China.
The BUAV-led Cruelty Free International has established the ‘China Task Force’ withleading companies, the cosmetics industry and regulators to gain acceptance in
China for non-animal testing methods. In June 2013 it also gave a keynote speech at
the Asia Cosmetics Innovation Summit 2013 in Shanghai titled 'Will Asian Markets
Follow the European Ban on Animal Tests for Cosmetics?’.47
Also in 2013, HSI’s Be Cruelty Free campaign launched in China in conjunction with
Capital Animal Welfare Association, Lush and Chinese pop singer Wang Feifei 48
The EU ban on marketing animal-tested cosmetics provides an example of how
policy change in one country affects policy in others. In June 2013, the EU HealthCommissioner Tonio Borg urged the Chinese government to follow the EU’s example
and end animal testing for cosmetic products. During a four-day visit to China, Borg
said “I have encouraged the Chinese authorities to avoid unnecessary testing forcosmetics.” He added:49 “I see first signs of acceptance of alternative methods in
China which I welcome very much. Acceptance of validated alternative methods,
starting with those that are OECD accepted, is clearly key to limit animal testing forcosmetics internationally”.
43 PETA Protest Leads Urban Decay to Boycott China, Win PETA Award. Abe Sauer. Brand Channel, 10.7.12.
44 First congress on alternatives to animal testing in China. 8 March 2011.
45 Be Cruelty-Free Campaign to End Cosmetics Animal Testing in China Launches with Pop Singer Wang Feifei,
NGOs and Industry. 28.6.13.
46 Animal Protectionists Call for Ending Cosmetics Animal Testing in China. Liu Yuanhui, 29.6.13.
47 Cruelty Free International in China. 05.06.13.
48 Be Cruelty-Free Campaign to End Cosmetics Animal Testing in China Launches with Pop Singer Wang Feifei,
NGOs and Industry. 28.6.13.
49 Andrew McDougall. 26.6.13. Health Commissioner urges China to follow EU’s animal testing ban forcosmetics.

Lush Lobbying Prize 2013 – Background Paper - August 201314

China is the EU’s second biggest trading partner behind the USA and the EU is
China’s biggest trading partner.50
The EC is promoting the EU-wide ban on animal testing of cosmetics and marketingof such products for adoption by other countries. It is “convinced that the issue ofalternative test methods for cosmetics merits a prominent place on the EU's tradeand international cooperation agenda. It will endeavour to put these issues on theagenda of all relevant multi and bilateral meetings in the cosmetics field in 2013,
notably with the United States and China, but also in contacts with Brazil and India.
The Commission will, in this effort, look for synergies with the international initiativesof industry and animal welfare organisations”.51
4.3.3

India

An “emerging urban elite” and “increasing female workforce” is said to be behind aforecast that India’s cosmetics market is set to double in value by 2014, from a 2011
estimate of INR 100bn.52
Following campaigns by a number of NGOs, the Drug Controller General of India
announced in June 2013 that the testing of cosmetics and their ingredients on
animals will no longer be permitted in India. The announcement was made during
the Bureau of Indian Standards PCD 19 Cosmetics Sectional Committee meeting, on
which PETA India has an official seat (it is also an official member of the Soaps andother Surface Active agents committee, which has enabled it to submit evidence insupport of an animal testing ban). PETA India was one of the winners of the
Lobbying awards in the 2012 Lush Prize for this work, along with the Federation ofIndian Animal Protection Organisations (FIAPO).
PETA India had obtained wide support from international cosmetics companies,
worldwide NGOs and Indian politicians for its call for a ban on animal testing.
In 2012, the BUAV-led Cruelty Free International launched in India to add to thecampaign, partnering with People for Animals, which is run by Indian MP Maneka
Gandhi.53
PETA India say they are now campaigning to urge the Drugs Consultative
Committee to amend the Drugs and Cosmetic rules (1945) to ban the marketing ofcosmetics or their ingredients tested on animals. 54
4.3.4

RussiaIn 2013 the Moscow-based VITA Animal Rights Centre partnered with the Humane
Society International to launch the Russian arm of HSI’s Be Cruelty-Free campaign.
50 Andrew McDougall. 26.6.13. Health Commissioner urges China to follow EU’s animal testing ban forcosmetics.
51 Communication from the Commission to the European Parliament and the Council on the animal testing andmarketing ban and on the state of play in relation to alternative methods in the field of cosmetics. Brussels,
11.3.201352 India market for cosmetics could double in value by 2014. Simon Pitman, 7.12.11. At 2013 exchange rates
INR 100bn is €1.2bn.
53 BUAV welcomes India’s move towards a cosmetics testing ban. 4.1.13.
54 Personal Communication. 3.7.13

Lush Lobbying Prize 2013 – Background Paper - August 201315

Animal testing for cosmetics is still commonplace in Russia, so VITA and HSI will
work with companies, policymakers and regulators to end to these tests. The twoNGOs launched Be Cruelty-Free Week with an eye-catching poster campaign on the
Moscow Metro.
HSI recently joined forces with the Institute for In Vitro Sciences to co-fund aworkshop for 11 selected scientists from Russia, in order to provide them with handson laboratory training in non-animal tests. The delegates gained first-handknowledge of how non-animal test methods can be used to assess the safety ofcosmetic and personal care products and improve the quality of their research. 55

4.4 USA: Safe Cosmetics Act
The Safe Cosmetics and Personal Care Products Act (2013) was introduced early inMarch 2013 and is a repeat of attempts to introduce similar legislation in 2010 and2011. The law gives the Food and Drug Administration authority to ensure that all
personal care products are free of harmful ingredients. 56
The Coalition for Consumer Information on Cosmetics (CCIC), a coalition of antivivisection organisations, has raised concerns about the Safe Cosmetics Act.
Although the legislation is intended to ensure that cosmetic and personal careproducts are safe, they say it “will likely require a significant number of animals totest and retest finished products and ingredients for safety”. 57
The Act does support the development and use of non-animal test methods, but
animal protection NGOs are instead calling for US law to harmonise with that of the
EU in relation to a ban on the use of animals to test cosmetics and their component
ingredients while ensuring consumer safety.
Following concerns raised during previous versions of the legislation, the Campaign
for Safe Cosmetics, which is behind the law, has stated that it “supports uses of nonanimal testing methods where available and effective, and fully supports initiatives tofund research on alternative, non-animal health and safety testing”. 58 It apparently
works “to minimise animal testing”.
The CCIC told us that no major campaigns had been launched against the Safe
Cosmetics Act as it is unlikely the legislation will pass 59 despite having large support:
the Campaign for Safe Cosmetics has ten founding NGO members and is endorsedby more than 150 others (mostly environmental and health organisations).

55 Be Cruelty-Free Campaign to End Animal Testing for Cosmetics Launches in Russia with Moscow Metro
Poster. 11.3.13.
56 Campaign for Safe Cosmetics Press Release, 21.3.13. Toxic Chemicals in Cosmetics, Shampoos, Targetedby Congress
57 Press Release, 14.5.13.
58 How does the bill address animal testing?
59 Personal Communication 22.7.13

Lush Lobbying Prize 2013 – Background Paper - August 201316

4.5 Israel
In 2007, the Israeli government banned using animals to test personal care andhousehold products. 2,000-3,000 animals were used in such experiments annually. 60
This was followed by legislation passed in 2010, which came into effect in January
2013, blocking the marketing of animal-tested products. 61 Israel’s laws are now thesame as those for the EU.
In 2012, the Israeli Ministry of Health banned the use of the leaping bunny logo on
cruelty-free cosmetic products on the grounds that animal testing of cosmetics was
already banned in the country and a ban was soon to come into effect banning thesale of products animal tested elsewhere.
Two NGOs, Let the Animals Live and the Israeli Society for the Abolition ofVivisection, submitted a petition to the Supreme Court against the Ministry’s ruling,arguing that the instruction made by the Ministry “harms the freedom of choice andconsciences of the conscious consumer as well as the public's right for
information”.62 The bunny logo would allow consumers to further ensure that
products they buy were not recently tested on animals.
The animal organisations were successful in their petition and the Court ruled in May
2013 that the bunny logo could be used on cruelty-free products. 63

60 Ministerial committee approves bill banning animal testing for cosmetics. Tamara Traubmann. 28.1.07.
61 Import ban on animal-tested products goes into effect. Gabe Fisher, 1.1.13.
62 Press release: Animal protection organization appealed to the Supreme Court against the Ministry of Health.
Let the Animals Live and the Israeli Society for the Abolition of Vivisection. 6.12.12
63 High Court victory - Rabbit label back!

Lush Lobbying Prize 2013 – Background Paper - August 201317

5 Who is active in the sector? NGOs active in lobbying to end animal testing
The table below lists groups across the world currently active in the area of lobbying against animal testing. The list is certainly notcomprehensive. Attempts have been made to include a range of organisations, from grass-roots volunteer-led groups tointernational, well-funded NGOs. Attention has also been paid to NGOs in ‘emerging’ countries where the demand for consumer
products is increasing. This research has been largely web-based and although effort has been put into researching websites inmany different languages, we are aware that not all NGOs will have websites, that information available on websites will in somecases be limited and that there will be other effective NGOs which have been missed during our research.
Organisation
Campaign
Phone
Email / web
Australia
1
Choose Cruelty Free
“An independent, non-profit organisation which actively promotes a cruelty-free lifestyle.” Surveys and accredits companies not
testing on animals+61 39328 1377
admin@choosecrueltyfree.org.au / www.choosecrueltyfree.org.au
2
Replace Animals in Australian Testing
Based at University of Wollongong. Aims to "create a network of researchers and other individuals or groups interested in
advocating non-animal based research and in strengthening the Australian Government/NHMRC guidelines and their enforcement"+61 24221 3387

Lush Lobbying Prize 2013 – Research Paper - August 201318

Dr Denise Russell: deniser@uow.edu.au / www.uow.edu.au/arts/research/raat/index.html

Lush Lobbying Prize 2013 – Research Paper - August 201319

3
Humane Research Australia“Challenges the use of animals in research and promotes the use of more humane and scientifically valid non-animal
methodologies”+61 38823 5704
info@humaneresearch.org.au / www.humaneresearch.org.au

Austria1
Internationaler Bund der Tierversuchsgegner / Ein Recht fur Tiere (Rights for Animals)
Animal testing. Long term lobbying on issues such as REACH+43 1713 08230
tierversuchsgegner@chello.at / www.tierversuchsgegner.at

Belgium
1
Eurogroup for Animals
Various animal protection: animal testing, farmed animals, wildlife,; companion animals, animal welfare in EU legislation+32 2740 08 20
info@eurogroupforanimals.org / www.eurogroupforanimals.org

Lush Lobbying Prize 2013 – Research Paper - August 201320

Brazil1
Humane Society International
Be Cruelty Free campaign+55 (21) 8342-4163
Helder Constantino:hconstantino@hsi.org / www.hsi.org/world/brazil

China
1
Humane Society International
2013 launched Be Cruelty Free campaign in China with Chinese NGOs and academic scientists.
HSI launched an $80,000 partnership with the Institute for In Vitro Sciences to provide Chinese scientists with hands-on training
using advanced non-animal methods.
China mobile: + 86 13718914649
Peter Li, China Policies Specialist: pli@hsi.org

Europe1
Stop Vivisection
A Citizens Initiative to end animal experiments. Committee includes scientists, activists and politicians. June 2013: Arranged
presentations in the European Parliament as part of the campaign.
representative.stopvivisection@gmail.com / www.stopvivisection.eu

Lush Lobbying Prize 2013 – Research Paper - August 201321

France1
The Anti-Vivisection Coalition France (CAV)International Toxicology Centre switch to non-animal testing; Stop Huntingdon Animal Cruelty; air transport of animals for labs
info@cav.asso.fr / www.cav.asso.fr/en

Germany1
Deutscher Tierschutzbund e.V. (German Animal Welfare Association)
Various animal protection: animal testing, animal circuses,; factory farming, hunting.
ECEAE member.
Lobbied actively to end animal testing under REACH.
www.tierschutzbund.de2
Animal2000
Various animal protection: animal testing, rodeos,bullfighting, hunting.
Pays the salary of a toxicologist who works on behalf of ECEAE to oppose animal testing under REACH.
+49 89-5 46 90 50
www.animal2000.de3Ärzte gegen Tierversuche e.V. (Doctors Against Animal Experiments)“We are a charitable organisation of several hundred doctors and scientists who work in the medical field. We support theimmediate abolition of all animal experiments on ethical and scientific grounds.” ECEAE member. The NGO’s toxicologist works toprevent animal testing under REACH by submitting scientific evidence.
+ 49 89 - 35 99 349
info@aerzte-gegen-tierversuche.de / www.aerzte-gegen-tierversuche.de

Lush Lobbying Prize 2013 – Research Paper - August 201322

India1
Humane Society International
Be Cruelty-Free campaign for marketing ban on animal-tested cosmetics in India.
+91 9849094113
Alokparna Sengupta: asengupta@hsi.org
www.hsi.org/world/india/work/end_animal_testing/be_cruelty_free/be_cruelty_free.html
2People For Animals
Cruelty Free International partner.
PFA members are board members of every Laboratory Ethics Committee.
+91 - 11 - 23357088
www.peopleforanimalsindia.org
3
PETA India
Lobbying and public awareness to help achieve ban on animal testing of cosmetics. Now working to prevent products animal tested
elsewhere from being marketed in India.
+91 22-4072 7382
Info@petaindia.org
www.petaindia.com

Lush Lobbying Prize 2013 – Research Paper - August 201323

Israel1Israeli Society for the Abolition of Vivisection Society (ISAV)General anti-vivisection campaigns. Successfully lobbied against Ministry of Health’s ban on cruelty-free products using ‘bunny’logo (2012)+972 76-5403257
Isav@isav.org.il / www.isav.org.il
2
Behind Closed Doors
Campaigns against animal experiments and breeding animals for labs in Israel.
Undercover investigations of Israeli laboratories in cooperation with Let the Animals Live and Animal Log.
+972 54-6462170
anat@invitro.org.il / www.invitro.org.il

Italy
1
Coordinamento Fermare Green Hill (Co-ordinate to Close Green Hill)
Campaign to close Green Hill beagle breeders. Protests with up to 10,000 people and rescue of dogs led (in 2012) to 2,700
beagles being seized by authorities and re-homed. Green Hill to be closed down.
Public support for the campaign led to some cities banning construction of labs and legislation being passed to ban the breeding ofdogs, cats and primatesfor animal testing (a law specifically designed to close down Green Hill).
+39 339-2144345
info@fermaregreenhill.net / www.fermaregreenhill.net

Lush Lobbying Prize 2013 – Research Paper - August 201324

Japan1
Japan Anti-Vivisection Association (JAVA)
Lobbies for end of animal testing as Asian representative member of ICAPO (International Council on Animal Protection in OEC
programmes); Publishes guide to cruelty-free cosmetics; Campaign partner of Cruelty Free International+81 (3) 5456-9311
java@java-animal.org / www.java-animal.org/english

Korea, Republic of
1
Korean Society for Animal Freedom / Korean Animal Welfare Association
Various animal protection: animal testing,pets, farmed animals, illegal animal slaughter programme; animal use in sports andentertainment.
benicetobunnies.org website educates public on animal testing and gathers signatures for their campaign ‘No to cosmetics testingon animals’. Signatures will be used in persuading government organisations to ban animal testing and dissuade companies fromtesting on animals in producing cosmetic products.
+82 2-2292-6337
admin@animals.or.kr / hjl@animals.or.kr / www.animals.or.kr
Campaign website: www.benicetobunnies.org

Lush Lobbying Prize 2013 – Research Paper - August 201325

New Zealand1
Save Animals From Exploitation (SAFE)
Various animal protection: animal testing, factory farming, rodeos, poisoning.
Produces guide to cruelty-free cosmetics; organising Cruelty Free Cosmetics week; is part of the Be Cruelty Free campaign.
+64 3 379 9711
info@safe.org.nz / www.safe.org.nz / www.safeshopper.org.nz

Spain
1
Igualdad Animal (Animal Equality)
Various animal protection: animal testing, zoos, animal circuses, fur, bullfighting/fiestas, veganism.
Conducts undercover investigations and animal rescues.
June 2013: Animal Equality gave a presentation in the European Parliament on the campaign ‘Stop Vivisection’.
+34 915 222 218
info@igualdadanimal.org / www.igualdadanimal.org
2
Animanaturalis
Various animal protection: animal testing, zoos, animal circuses, fur, bullfighting/fiestas, vegetarianism.
June 2013: Animanaturalis gave a presentation in the European Parliament on the campaign ‘Stop Vivisection’.
www.animanaturalis.org/home/es

Lush Lobbying Prize 2013 – Research Paper - August 201326

Sweden1
Forska Utan Djurförsök / The Swedish Fund for Research Without Animal Experiments
Promotes the development and validation of replacement alternatives to animal experiments. Grants are awarded annually toresearch, validation and information projects.
+46 8749 03 40
info@forskautandjurforsok.se / www.forskautandjurforsok.se/in-english

Switzerland
1
Ligue suisse contre la vivisection (LSCV) (Swiss League Against Vivisection)
Supports development of non-animal testing methods and takes legal action to prevent animal tests. Publishes list of cruelty-freecosmetics.
+41 (0)22 349 73 37
admin@lscv.ch / www.lscv.ch
2
Zurcher Tierschutz Association (Zurich Animal Protection Association)
Various animal protection: animal testing; fur; farm animal welfare.
Funds non-animal testing; has a representative on the Zurich Animal Experiments Committee and the Federal Animal Experiments
Committee.
+41 44 261 97 14
info@zuerchertierschutz.ch / www.zuerchertierschutz.ch

Lush Lobbying Prize 2013 – Research Paper - August 2013

27

UK
1
British Union for the Abolition of Vivisection (BUAV)Key issues include: primates in research; cruelty-free cosmetics; animal testing of household products in UK; REACH; Freedom of
information. Conducts undercover investigations.
Co-ordinates the European Coalition to End Animal Experiments and Cruelty Free International (global campaign to end animal
testing for cosmetics).
+44(0)20 7700 4888
info@buav.org / www.buav.org / www.crueltyfreeinternational.org
2
National Anti-Vivisection Society (NAVS)
Part of Animal Defenders International (ADI).
Animals in space research; freedom of information; World Day for Laboratory Animals; Good Charities Guide (charities funding nonanimal medical research).
+44 (0)20 7630 3340
www.navs.org.uk
3
InterNICHE (International Network for Humane Education)
Network of students, teachers and campaigners working for fully humane education and training in medicine, veterinary medicine
and biological science. Produced award-winning video on alternatives available in nearly 20 languages; book describing over 500
products designed for progressive life science education; offers a global Alternatives Loan Systems - libraries of products available
for free loan, as well as literature, support and advice for teachers and students. Conferences, seminars and training.
+44 (0) 116 210 9652
coordinator@interniche.org / www.interniche.org

Lush Lobbying Prize 2013 – Research Paper - August 2013

28

USA
1
Coalition for Consumer Information on Cosmetics (CCIC)
Coalition of 8 national animal protection groups. The CCIC “promotes a single comprehensive standard and an internationallyrecognised Leaping Bunny Logo”.
+1 888546-CCIC
info@LeapingBunny.org www.leapingbunny.org
2
The American Anti-Vivisection Society (AAVS)
Key issues include: Ban Pound Seizure; End Animal Cloning; Compassionate Shopping.
In 2006, AAVS assumed the leadership role as Chair of the Coalition for Consumer Information on Cosmetics (CCIC).
Free phone app with guide to over 200 cruelty-free cosmetics companies.
+1 800-729-2287
aavs@aavs.org / www.aavs.org
3
Humane Society International (HSI)
Launched ‘Be Cruelty Free’, a global campaign in partnership with NGOs worldwide. Active in key emerging countries such as
Brazil, India, China.
+1 202-452-1100
info@hsi.org / www.hsi.org
4
Physicians Committee for Responsible Medicine (PCRM)
PCRM is Secretariat of the International Council on Animal Protection at OECD (ICAPO), which was formed to incorporate
alternative methods that can replace, reduce, and refine animal use in OECD guidelines and programs.
+1 202-686-2210
pcrm@pcrm.org / www.pcrm.org

Lush Lobbying Prize 2013 – Research Paper - August 201329

5Center for Alternatives to Animal Testing (CAAT)
Promote humane science by supporting the creation, development, validation, and use of alternatives to animals in research,
product safety testing, and education. Seek to effect change by working with scientists in industry, government, and academia.
+1 410-614-4990
caat@jhsph.edu / http://caat.jhsph.edu
6International Council on Animal Protection in OECD Programmes (ICAPO)ICAPO works to incorporate non-animal testing methods into the activities of theOrganisation for Economic Co-operation and Development (OECD), an influential international organisation that develops
guidelines and programmes for the testing of chemicals.
+1 202-686-2210
icapo@pcrm.org / www.icapo.org
7
Beagle Freedom Project
The Project negotiates with labs to hand over animals for re-homing to suitable private homes. In its lobbying work, BFP put
forward the Beagle Freedom Bill in November 2012, to mandate that research facilities that receive tax-dollar support would have tooffer dogs and cats to non-profit rescue organisations for public adoption. From January to May 2013 BFP ran this legislative
campaign in the State of Minnesota. The bill passed the committee with unanimous support but did not pass into law. For the next
legislative session BFP will be advancing this same bill again in Minnesota, California and Michigan.
+ 1818-330-4040
shannon@beaglefreedomproject.org / www.beaglefreedomproject.org

Lush Lobbying Prize 2013 – Research Paper - August 201330

6 Lobbying Prize Winners 2012
In the inaugural Lush Prize in 2012, three winners shared £50,000 of prize money for
their outstanding lobbying work:•

Humane Society International, USA (£40,000): For their work on removing
animal tests from the EU’s non-food pesticide regulations. http://www.hsi.org•

Federation of Indian Animal Protection Organisations (FIAPO), India (£5,000):
For their research and lobbying on animal testing in India. http://www.fiapo.org•

People for the Ethical Treatment of Animals (PETA) India (£5,000): For theirwork with Indian regulators on a cosmetics testing ban.
http://www.petaindia.com

Also short-listed:•

Center for Alternatives to Animal Testing, USA: For their work in Washington
on informing regulators about 21st Century Toxicology. http://caat.jhsph.edu•

Stop Vivisection (European Citizens’ Initiative), Italy: For their project to attract
1,000,000 signatures on a stop vivisection petition in Europe.
http://www.stopvivisection.eu•

Doctors Against Animal Experiments, Germany.: For their lobbying against
primate experiments and botox animal testing. http://www.aerzte-gegentierversuche.de•

Physicians Committee for Responsible Medicine, USA.: For their lobbyingaround changes to the Toxic Substances Control Act. http://www.pcrm.org•

The Swedish Fund for Research Without Animal Experiments, Sweden.: For
their lobbying to enforce to the European 2013 cosmetics testing ban.
http://www.forskautandjurforsok.se

7 Shortlist of potential winners for the Lobbying category of the2013 Lush Prize

7.1 Stop Vivisection
Organising committee STOP VIVISECTION
c/o Secretariat Sonia Alfano, Viale Strasburgo, 382 - 90146 Palermo, Italy

Lush Lobbying Prize 2013 – Research Paper - August 201331

E-mail: representative.stopvivisection@gmail.com
Website: www.stopvivisection.eu
A European Citizens Initiative calling for the repeal of European Directive
2010/63/EU ("on the protection of animals used for scientific purposes") and the
proposal of a new Directive aimed at ending animal experiments and making the useof data relevant to humans in biomedical and toxicological research compulsory, inthe place of data obtained on animals.
The Citizens’ Initiative is a request to the European Commission to legislate on
matters in which the EU is the competent authority. An Initiative must be supported
by at least one million EU citizens, representing a minimum of 7 out of the 27
member states. In addition, there is a requirement for a minimum number ofsignatories for each of the 7 member states.
Its committee consists of scientists, activists and politicians, including: André
Ménache, veterinary surgeon and director of Antidote Europe; Gianni Tamino,
Professor of biology at the University of Padua, Italy; Sonia Alfano, Italian Member ofthe European Parliament.
June 2013: Arranged presentations in the European Parliament as part of thecampaign.

7.2 HSI (Humane Society International) – Brazil
Helder Constantino (Campaign Manager)
Telephone: +55 (21) 8342-4163
E-mail: hconstantino@hsi.org
Website: www.hsi.org/world/brazil
Brazilian national guidelines still recommend a series of tests on animals for thesafety evaluation of new cosmetics products and ingredients.
HSI has been working with scientists there to establish non-animal testing
methods:64 “HSI’s Science Team is working with Brazilian authorities and companies
in the cosmetics and other sectors to gain acceptance and use of proven non-animal
methods and testing strategies and to update regulatory testing requirements to
replace or reduce animal testing to the greatest possible extent.”
In November 2011, HSI co-sponsored a training course “to better familiarise
government authorities and industry scientists with internationally recognised nonanimal tests. The event was very successful as it gathered broad participation ofBrazilian regulators, industry and university scientists. The cosmetics sector was
64 HSI’s Work in Brazil to Promote Non-Animal Testing. HSI, 15.12.11.

Lush Lobbying Prize 2013 – Research Paper - August 201332

particularly well-represented, and expressed its willingness to further explore
regulatory aspects of cosmetics testing in Brazil.”
The launch of HSI’s ‘Be Cruelty Free’ campaign in Brazil has increased calls for an
end to animal testing. In March 2013, to mark the implementation of the EU
marketing ban, HSI and ProAnima held a protest outside the Ministry of Health. HSI
is also working with another NGO, ARCA Brazil, on the issue.

7.3 European Coalition to End Animal Experiments (ECEAE)
16a Crane Grove, London N7 8NN, UK
Telephone: +44 (0) 20 7700 4888
Email: info@eceae.org
Web: http://www.eceae.org/
The ECEAE is co-ordinated by the BUAV; therefore, some of the activities andachievements of both the ECEAE and BUAV overlap.
The coalition has 18 members in 11 countries and its website is available in 17
European languages.
As a member of ICAPO (the International Council on Animal Protection in OECD
Programmes), scientists at the ECEAE comment on testing guidelines that will be
used by chemical companies wanting to register their substances under REACH.
REACH campaign (ECEAE activities in 2013 and 2012)2013
With an estimated 700 testing proposals under REACH to be published between
June 2013 and June 2015, the ECEAE is contributing more funds to support its
scientific team to comment on the proposals (assisted by independent toxicologists
and TSGE LLP, an independent European regulatory consultancy company based in
the UK).
The experiments are likely to include tests for reproductive and repeated dose
toxicity which involve force feeding high doses of the substance to rats and rabbits
and long term toxicity tests in which fish are forced to swim in water polluted with thesubstance. The ECEAE estimate a further half a million animals could be involved in
tests like this if all proposed tests go ahead. 65
The ECHA (European Chemicals Agency) rarely rejects testing proposals.
Companies only receive third party comments with the draft decision asking for the
animal test to be conducted. The ECEAE is asking the ECHA to change this process
65 BUAV urges ECHA to revise process for testing proposals for second REACH deadline as the fate of half amillion animals will be decided. 4.6.13

Lush Lobbying Prize 2013 – Research Paper - August 201333

so that companies have longer to consider alternatives to testing on animals before
the decision becomes binding.66
The ECEAE has been granted a stakeholder seat at the ECHA’s new committee
called the Biocides Products Committee (BPC). The BPC was established in March2013 and will have an important role in the approval of biocidal products under the
new Biocidal Products Regulation, which will come into force on the 1 st of September
2013.
Biocides are substances that can destroy or control the effect of any harmfulorganism and are widely used in medicine, agriculture and industry. Animal tests areoften used to assess these risks and to establish the safety of biocidal products forhuman users.
The ECEAE will attend BPC meetings to verify that animal tests are used only as alast resort and that existing data (where products have already been tested) is
shared in order to avoid the need for new animal tests. 67
ECEAE assisted chemical company Honeywell’s appeal against an ECHA decision
for a 90-day inhalation experiment to be conducted on rabbits for a refrigerant for its
car air conditioner system.68
2012
The ECEAE has been granted a stakeholder seat at the European Commission’s
REACH committee called CARACAL. The Competent Authorities for REACH and
CLP (CARACAL) committee is an expert group that advises the European
Commission and the European Chemicals Agency. It meets three times a year and is
an important forum for political and regulatory issues related to the EU chemical
testing legislations REACH and CLP. The ECEAE seat will be shared with Eurogroupfor Animals.69
Following submissions by the ECEAE, animal tests for four substances have been
either rejected by the European Chemicals Agency (ECHA) or withdrawn by thecompany involved. ECEAE estimate this has saved up to 7,000 animals who would
otherwise have suffered and died in a total of five toxicity (poisoning) tests.
With two of the substances the ECHA rejected the test in line with suggestions madeby ECEAE experts. The substances were industrial chemicals used to make rubber
and adhesives. In both instances the company had proposed to do a test that was
not strictly required by the legislation. The ECHA rejected the testing proposal. The
comments submitted by the ECEAE were noted in its final decision.
The tests were primarily two generation reproductive toxicity tests that use up to
2,000 animals each. This is because the test involves force-feeding the substance to66 BUAV urges ECHA to revise process for testing proposals for second REACH deadline as the fate of half amillion animals will be decided. 4.6.13
67 BUAV attends first Biocides Products Committee meeting in Helsinki. 31.5.13
68 BUAV welcomes ruling in landmark rabbits testing case. 29.4.13
69 ECEAE gains seat at CARACAL, the EU REACH advisory group. 12.11.12

Lush Lobbying Prize 2013 – Research Paper - August 201334

female rats who are then made pregnant, with the substance fed to the resulting
offspring until they also have offspring.70
Although the ECEAE is led by the UK-based BUAV, other members have had a rolein moving forward the coalition’s campaign on REACH. For example, German NGO
Animal 2000 pays the salary for a toxicologist to work for the ECEAE and provide
evidence to reduce the number of animals that are used due to the REACH
Directive.71

7.4 Physicians Committee for Responsible Medicine
5100 Wisconsin Ave., N.W., Ste.400, Washington DC, 20016
Telephone: 202-686-2210
Email: pcrm@pcrm.org
Web: http://pcrm.org/
PCRM is the Secretariat of the International Council on Animal Protection in OECD
Programmes - www.icapo.org
PCRM lobbied for a Senate bill, the Chemical Safety Improvement Act of 2013,
introduced in May 2013, to make it a requirement for the use of non-animal test
methods where reasonably and practicably available. “Such a requirement is crucial
to the rapid development and uptake of new methods and the continued
improvements in toxicity testing policy that offer superior protection for public healthand the environment”.72
The CSIA contains many provisions that are consistent with this goal and therecommendations made by the National Academies’ report Toxicity Testing in the
21st Century: A Vision and a Strategy. Importantly, it requires the EPA to fundresearch and validation studies to replace, reduce, and refine the use of animals.
However, PCRM says “faster progress could be made by requiring, rather than
encouraging, new methods to be used in place of animals wherever possible". 73
Many of the suggestions PCRM scientists provided to Congress in past hearing
testimony and meetings are included in the CSIA. Principles to replace and reduceanimal-based test methods and to increase the use of information from humanbased and mechanistic tools are integrated into the heart of the legislation.
The Physicians Committee urges Congress to harmonise the bill with the European
Union law, which requires that new animal tests only be conducted as a last resort,when all other methods of obtaining data have been exhausted. A “last resort” clauseis crucial to the rapid development and uptake of new methods as it allows flexibility
70 BUAV helps save animals from chemical testing under REACH. 13.8.12
71 REACH - Toxicologist saves lives. Focus, Winter 2011/2012.
72 Physicians Committee for Responsible Medicine
73 Physicians Committee Statement on the Chemical Safety and Improvement Act of 2013.

Lush Lobbying Prize 2013 – Research Paper - August 201335

to incorporate continued improvements in toxicity testing that offer superior
protection for public health and the environment.

7.5 Center for Alternatives to Animal Testing
Bloomberg School of Public Health, Department of Environmental Health Sciences,
615 N. Wolfe St., W7032, Baltimore, MD 21205
Telephone: 410-614-4990
Email: caat@jhsph.edu
Web: http://caat.jhsph.edu
The Johns Hopkins University Center for Alternatives to Animal Testing promotes
humane science by supporting the creation, development, validation, and use ofalternatives to animals in research, product safety testing, and education. CAATEurope is a joint venture with the University of Konstanz in Germany.
CAAT has been actively lobbying for a legal implementation of Tox-21c in the US andthe EU, educating legislators and politicians about the NAS report: Toxicity Testingand Assessment in the Twenty-first Century: A Vision and a Strategy (Tox-21c), theurgent need for regulatory change, and the availability of new methods.
A reach-out to lay audiences, journalists and policy makers is provided by a series ofworkshops, information days and white papers commissioned through CAAT’stransatlantic think tank for toxicology (t4). Our dissemination channels Altweb and
ALTEX as well as social networks form a knowledge base helping to create a path
for a successful paradigm shift away from animal toxicity testing. The activities arefocused on developing a roadmap to implement the Tox-21c vision.
CAAT believes that only an integrated approach is the answer to advancing Tox-21c.
The integration of humane science into legislation and policy is essential, and theintegration of legislation and policy approaches on both sides of the Atlantic, andindeed globally, is mandatory. CAAT is ideally suited to promote this approach, as it
combines high-level research into alternatives in its own laboratories with forming its
teams of professionals in communications and policy in Europe and the US. Throughthis unique integrated policy approach, CAAT is striving to move us toward a world inwhich animal testing is replaced by humane science.
•

CAAT’s EU policy program has involved: Attendance and involvement with
Committees on Environment, Public Health and Food Safety (ENVI), Industry,
Research and Energy (ITRE), Internal Market and Consumer Protection(IMCO) and European Parliament’s Intergroup on the Welfare andConservation of Animals. Close following of and contribution to various MEPs’
work at the Committee level and at Plenary Sessions at the EP in Brussels
and Strasbourg.

Lush Lobbying Prize 2013 – Research Paper - August 201336

CAAT-EU has made policy input on several key legislative files. CAAT has madeclear the need for support within Horizon 2020 for EU research on alternative test
methods rather than the traditional and antiquated animal models. CAAT is
supporting the use of human-based models for better predictive outcomes throughthe Protection of Public Health on Endocrine Disrupters. Regulation on Medical
Devices normally involves animal testing, and CAAT is pushing for this to move tohuman-based models.
In March 2013, CAAT-EU applied to STOA of the EP for two specific lots: ‘Life
Sciences for Human Well-Being’ and ‘Safety and Security Technologies’. If
successful, CAAT will be then listed as an official expert contact point for a period of
4 years for the EP. The results are expected at the end of 2013.

7.6 PETA India
PO Box 28260 Juhu, Mumbai - 400 049
Telephone: +91 22-4072 7382
E-mail: Info@petaindia.org
Web: www.petaindia.com
PETA India played a major part in the successful campaign to ban the testing ofcosmetics on animals in the country.
In June 2013, the Drug Controller General of India announced that the testing ofcosmetics and their ingredients on animals will no longer be permitted. The
announcement was made during the Bureau of Indian Standards PCD 19 Cosmetics
Sectional Committee meeting, on which PETA India has an official seat.
In 2012, PETA India prompted discussion in the Cosmetic Sectional Committee overreplacing the existing tests on animals; the panel agreed to replace the Skin
Sensitisation test on guinea pigs with the Human Repeat Insult Patch Test.
PETA brought in companies, research groups, high-level government officials,
Members of Parliament and individuals to support this ethical ban. It submitted
supporting letters from multinational companies The Body Shop and LUSH as well
as Indian companies such as Omved Lifestyle, Shahnaz Husain and others who had
also written to the Ministry of Health & Family Welfare in full support of a ban after
hearing from PETA. They also submitted letters from officials from the Indian Councilof Medical Research, the Mahatma Gandhi–Doerenkamp Center for Alternatives to
Use of Animals in Life Science Education and the Animal Welfare Board of India.
Through its official membership of the Soaps and other Surface Active agents
committee, PETA India is working for a complete ban on testing of householdproducts and their ingredients on animals. It has submitted data on several
alternatives tests that can be carried out and the working group is presently
reviewing the comments.

Lush Lobbying Prize 2013 – Research Paper - August 201337

After hearing from PETA, the Galaxy Surfactants and Association for Consumer
Action on Safety and Health (ACASH), which also has seats on the committee,
supports the ban on testing household products on animals. Prominent current andformer ministers also sent strong appeals to the Ministry of Health & Family Welfare
and the Ministry of Consumer Affairs in favour of a total ban on the testing ofhousehold products and their ingredients on animals.

7.7 International Council on Animal Protection in OECD Programmes (ICAPO)ICAPO Secretariat, Physicians Committee for Responsible Medicine, 5100
Wisconsin Ave, NW, Suite 400, Washington, DC 20016
Telephone: +1 202-686-2210
Email: icapo@pcrm.org
Web: www.icapo.org
ICAPO is a coalition of 11 NGOs from North America, Europe and Japan and has
held official status as 'invited experts' at certain OECD programmes since 2002.
It works to incorporate non-animal testing methods into the activities of theOrganisation for Economic Co-operation and Development (OECD), an economic
alliance of the world's industrialised countries. The OECD co-ordinates thedevelopment of standardised chemical testing guidelines which are then adopted by
the member countries. It also co-ordinates the development of chemical testing
programmes, such as its current programme on endocrine disruptors.
ICAPO has financially supported the attendance of IIVS (the Institute for In Vitro
Sciences) and other experts to numerous OECD expert meetings, including those
focused on the adoption of in vitro methods for skin irritation, eye irritation,
carcinogenicity, genetic toxicity, and for (Q)SAR methods. Their internal experts also
attend other expert meetings related to endocrine disruption, inhalation toxicity, andnanomaterials, for example.
ICAPO contributes to a majority of test guidelines and guidance documents,
ensuring that those that involve animals use the minimum number of animals andare written to ameliorate some of the most cruel laboratory procedures.
OECD work is often long-term, collaborative, and confidential, making it difficult tooutline specific successes for 2012. Even so, over the past few years an
unprecedented number of in vitro tests have been adopted by the OECD, including
Reconstructed Human Epidermis methods for skin irritation and in vitro methods forgenotoxicity, eye irritation, and endocrine disruption. Another recent move was the
adoption of the Extended One-Generation Reproductive Toxicity Study, which cuts
significantly the number of animals used in each test.

Lush Lobbying Prize 2013 – Research Paper - August 201338

7.8 Forska Utan Djurförsök / The Swedish Fund for Research Without Animal
Experiments

Virkesvägen 10, SE-120 30 Stockholm
Telephone: +46 8749 03 40
E-mail: info@forskautandjurforsok.se
Web: www.forskautandjurforsok.se
The Swedish Fund for Research Without Animal Experiments promotes thedevelopment and validation of replacement alternatives to animal experiments.
Grants are awarded annually to research projects. In 2013 grants were awarded to
11 research projects, 9 of which were in the field of toxicology.
The NGO has been lobbying for Sweden to establish a centre for alternatives toanimal testing. This proposal received important support from a government inquiry
report submitted to the Government in June 2012, with several important proposals
based on the Fund’s action plan. Proposals in the report argue strongly for aknowledge centre for 3R alternatives to animal use.
After several meetings with relevant government bodies, 21st century testing
methods have found their way into several government reports during the last 18
months, including the very important "Strategy for Sweden's work for a non-toxic
environment", from the Environmental Advisory Council. This forms the base for
Sweden’s position in the negotiations to amend REACH in the coming years.
During 2013, the Fund were also involved in the process of drafting a proposal to set
up a Swedish Institute of Toxicology, with an aim to ensure that, if such an institute is
being established, it will focus on toxicology from a 3R perspective. This is also
included in the final proposal to set up Swetox, www.swetox.se. Although Swetox will
use animals, it will have a strong 3Rs commitment. Developing and validating new,non-animal tests will be a major part of Swetox’s mission.
From January 2013 the Fund has been represented on the Board of Agriculture's
National Committee for the protection of animals used in experiments and was
appointed by the government as member of the newly formed Central Animal
Research Ethical Review Board. The Central board serves as the appeal board inrespect to the local ethics committees that approves or rejects applications to use
animals in research. It will also be responsible for retrospective assessments ofanimal experiments, as required in the EU Directive (2010/63/EU) on the protectionof animals used for scientific purposes.

Lush Lobbying Prize 2013 – Research Paper - August 201339