For Cruelty-free Cosmetic Brands: How to Bypass China’s Mandatory Animal Testing?

Updated: Jan 8, 2020

China’s rapidly growing beauty & personal care market is worth more than $51.8billion in 2019 with an expected growth of 6.7% in 2020 (see Exhibition 1), according to, hugely appealing for ambitious beauty brands across the world.

Exhibition 1: Revenue in the Beauty & Personal Care Market in China from 2012-2023

However, because of China’s animal testing requirements, many of them are forced to choose between profiting from exporting to China or staying true to their cruelty-free principles and loyal customers by resisting temptation.

What is going to happen if a brand caves to China’s animal testing laws? NARS, a French cosmetics and skincare company, was criticized and boycotted by its global fans after it announced in June 2017 that it would engage in animal testing to sell products in China. Meanwhile, according to the Sixth Tone, “makeup users in China were largely unconcerned — they were more interested in what NARS’ product names would be in Mandarin”.

Why does Animal Testing Still Exist in China?

The UK banned cosmetic testing on animals in 1998, followed by the EU-wide ban in 2013. As of now, 37 countries have either ended or limited cosmetic products testing on animals. They use artificial skin or human cells in tests, which are seen as equal to or even better than animal testing because the tests can be more precise.

However, there are still 80% of countries in the world that still require animal testing and China is one of them. According to the international animal rights advocacy group People for the Ethical Treatment of Animals (PETA), over 300,000 rabbits, mice, and other animals are used each year in China for testing cosmetic products, a significant chunk of the estimated 500,000 animals used in cosmetics testing worldwide each year.

There are three main reasons why animal testing is still required in China:

1. Consumers lack animal cruelty awareness.

“Without animal testing, the cosmetic product is like unauthenticated merchandise, and I dare not use it”, wrote one commenter on China’s social media Weibo. Many Chinese consumers believe that animal testing is still safer than other methods.

2. The government does not see eliminating animal testing as a priority.

Peter Li, a China policy specialist at global animal protection organization Humane Society International, said “The Chinese authorities do not feel as much pressure from Chinese consumers as European and other governments have over the years.”

3. The progress of the development and adoption of alternative testing methods is slow.

There are many reasons behinds it, such as the lack of relevant policy initiatives from government, R&D investment (testing labs is a highly fragmented and low-margin industry in China, hard to attract investment) and scientists with the appropriate knowledge.

What Progresses in Cruelty-Free Have been Made in China?

During the past 30 years, the introduction of mandatory animal testing has made it possible for China to take a giant leap forward in a cruelty-free dream by working with international organizations such as PETA and IIVS.

In 1990, China introduced mandatory animal testing for skin and eye irritation of ‘special use products’ (such as sunblock and whiteners), and this was extended to all ordinary cosmetics in 2012.

In 2012, PETA was the first to bring cruelty-free to light.

In 2014, China made some changes to its laws. As noted on Humane Society’s website, here is a short version of the state of cosmetic animal testing laws after the changes had been made:

1. Foreign imported ordinary cosmetics – still require animal testing

2. Domestically produced ordinary* cosmetics – animal testing no longer an absolute requirement

3. Both foreign imported and domestically produced special use** cosmetics – still require animal testing

4. Domestically produced ordinary cosmetics for foreign export only – have never required animal testing

5. Any cosmetic bought in China via a foreign e-commerce website – has never required animal testing.

*Ordinary cosmetics include makeup, fragrances, skin, hair and nail care products.

**Special use cosmetics include hair dyes, perms and hair growth products, deodorants, sunscreens, skin-whitening creams, and other products that make a functional claim on the label.

In January 2018, according to China’s e-commerce law, none of the beauty & personal care products sold direct-to-consumer via cross-border e-commerce platforms are required to test on animals.

In March 2019, China announced that post-market testing for finished imported and domestically produced cosmetics in China would not include animal tests.

In April 2019, China approved two new non-animal test methods for the regulation of cosmetic ingredients (it will go into effect on Jan 1, 2020). This brings the total to nine animal-free tests in which China has approved so far. The newly approved test methods only apply for cosmetic ingredients but they are not validated for final formulations.

From May 2019 till now, despite incremental progress made to date, foreign imported cosmetics and domestically produced special use cosmetics still require animal testing in China. The international IIVS and PETA are working hard with the Chinese government to continuously make progress to achieve the cruelty-free goal.

How do International Cruelty-Free Brands Bypass China’s Mandatory Animal Testing?

So far, there is only one proven way to bypass China’s animal testing: Selling via Cross-Border E-commerce Platforms.

Although cruelty-free brands like The Body Shop, Lush, Smashbox, singer Rihanna’s Fenty Beauty and Kim Kardashian’s Fragrance can’t be found on shelves in mainland China’s physical stores, with fans’ increasing appetite, they have all successfully sought an alternative way to break into the Chinese Market--selling on cross-border e-commerce platforms and shipping from overseas warehouse, or HK warehouse or China’s bonded warehouse.

Take one of Fenty Beauty products, for example, Dimond Bomb Highlighter had been sold more than 25,000 boxes monthly in its flagship store on Tmall Global.

Cross-border e-commerce sellers have a strong competitive advantage. Since China's new e-commerce law(2019) cracked down on grey-market Daigou sellers and the recent Hong Kong protests have put a damper on Chinese tourist arrivals, cross-border e-commerce has emerged as a popular channel to buy cruelty-free beauty and personal care brands.

Here are what foreign cruelty brands should pay attention to if sell in China under cross-border e-commerce route:

1. Choose the right cross-border e-commerce platforms customized for your brands as selling on the right channels help get you to the right audiences from the first place. The main platforms in China are Tmall Global, JD Worldwide, Netease Kaola, Little Red Book, VIP International, Ymatou, and etc. Brands like Charlotte Tilbury and The Ordinary have both opened their stores on Tmall Global, Netease koala and Little Red Book.

If the Chinese market is on your list, getting to know the six major marketplace platforms including sales models, customer data ownership, how to open a store, fees, requirement, popular categories, advantages, disadvantages and platform comparisons is absolutely essential. If you want to add other sales channels, you might want to click here to discover more about the WeChat mini-program and mobile app.

2. Select the most suitable logistics choice based on the stages of your China plan. Brands can ship directly from overseas warehouse, HK warehouses or bonded warehouses in China’s free-trade zones. Skincare Brands like Aesop(Australia), Derma E(America), and Cocoon Apothecary(Canada), mainly adopt the bonded warehouse model, which is efficient and convenient.

If you want to further engage with the Chinese customers offline, you may open physical stores in HK, Macau or Taiwan (These 3 territories are not part of mainland China and do not operate under the same laws) with no animal testing whatsoever at any point, and at the same time, sell via cross-border e-commerce platforms to mainland China;

Or, you may throw a physical pop-up store in a shopping mall or other places where customers can experience your products and services altogether, and then order your product by scanning a QR code of the product listed in your WeChat store. After you receive the order, you may arrange the delivery from any of the above three warehouses, overseas, HK or China’s bonded warehouse.

3. Work with a third-party e-commerce enabler to operate your online store locally, maintain strong relationships with customers, and perform digital marketing campaigns, etc. It’s always a wise choice to let local people run local business since they know better than you do about what the Chinese customers like and how to attract their attention, saving you a lot of money and time on local employee hiring and training.

We highly recommend foreign cruelty-free beauty brands try this route since cross-border e-commerce is not only highly encouraged by the Chinese government which recently lowered the import taxes but also is a perfect way to avoid animal testing and stay true to your brand identity and loyal customers.

Want to know more about how to avoid animal testing in China? EC LINKER is here to help you. Please visit our Consultancy &Service page or contact us by booking a free consultation here.

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