Ferguson 1

Emmi Ferguson

Professor Cynthia Richardson

English 1201

23 March 2019

Animal Testing for Cosmetics

Doing my makeup is something I have been doing since I was a young girl. I remember

begging my mom to let me wear makeup for the first time. She took me to the mall and let me

pick out a mascara and an eyeshadow palette. From there on my love for makeup only grew.

Cosmetics has become second nature to me, part of my daily routine for so long, and I even

consider it as one of my favorite hobbies. I never even thought about the deeper secrets of the

brands I use almost every day until very recently. It didn’t occur to me that my favorite

foundation could be destroying a rabbit’s ear or a mouse’s face, only to kill them after the

experiment was done. Testing cosmetics on unsuspecting animals is still a dilemma in the

cosmetic industry that has been mostly frowned upon by the general public, yet it still happens.

It’s estimated that around 100,000 to 200,000 animals die from animal testing around the world

from cosmetics alone. There needs to be laws that are put in place so that number can change.

Animal testing for cosmetics should be banned in the U.S. because it is inhumane, unreliable,

and expensive.

Almost 40 countries have already banned testing cosmetics on animals. Europe, India,

Norway, and Israel are just a few examples. One country where animal testing in cosmetics is

still legal is the United States. One of the many things the FDA (Food and Drug Administration)

does as a federal agency is ensure the safety of the health and human services in the U.S.
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Ensuring the safety of cosmetics also falls under this category. On the FDA’s official website

they state that “The FD&C Act does not specifically require the use of animals in testing

cosmetics for safety...However, the agency has consistently advised cosmetic manufacturers to

employ whatever testing is appropriate and effective for substantiating the safety of their

products” The FDA does not require companies to test on animals, nor do they ban animal

testing. Their policy is that it is the manufacturer’s job to make sure the products are safe before

they go on sale and only advises that they use whatever testing is needed to ensure this. The

FDA’s policy on cosmetic testing is rather vague and has no enforcement to limit the amount of

animal testing. It is the choice of makeup companies to decide whether animal testing is needed

or not. As stated in the quote above, the FDA encourages appropriate and effective testing. What

people consider appropriate and effective could vary depending on who you ask which leaves

many holes in this policy. While the FDA does support the use of non-animal testing in place of

animal testing, the policy doesn’t require alternatives to be used when they are available. When

animal testing is used, the FDA encourages using as little animals as possible, while still being

able to get accurate information, while also using the most humane methods possible. The FDA

encourages this but it’s not enforced as a law.

The main reason why animal testing should be banned in cosmetics is that it is cruel.

Many animals are killed in laboratories each year due to the harsh experiments that take place

against their will. In cosmetics, there are many tests that are done to ensure safety. ​Eye irritancy

tests can determine eye irritation from certain chemicals. Animals are restrained in this process

so they cannot react to the irritation as they normally would. The chemicals are placed in one

eye, the other eye serves as a control. They are then monitored every so often for reactions in
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their eye. Rabbits are often used for these tests and their cornea, iris, and conjunctiva is observed.

Another test that is conducted is acute toxicity, which consists of exposing rats or mice to

chemicals by their skin, mouth, and even making them inhale it. This way you can observe the

dangers of the chemicals but in return poison the animals. Repeated dose toxicity is similar to

acute toxicity but is repeated to see chronic toxicity and its effects. Skin corrosivity and irritation

tests are done to determine if a chemical can do damage to your skin. It is usually performed on

rabbits. A chemical is placed on a shaved patch of their skin and observed for inflammation,

swelling, and itching. In skin sensitizations tests, chemicals are placed on the ears of mice to see

if an allergic reaction occurs. Multiple doses can be used and the animals are killed after the

tests. Toxicokinetic tests measure the rate of absorption, excretion, metabolism, and the

distribution of toxic chemicals. Animals are feed, injected or forced to inhale the chemicals.

Their blood is taken and the amount of the chemicals in their organs is observed. In dermal

penetration tests, the movement of chemicals through an animal’s skin and blood is observed.

Mutagenicity experiments include exposing animals to large doses of chemicals and then

observing their bone marrow for mutations. Carcinogenicity tests use rats and mice and involve

exposing the animals to a chemical for a two year period. After this, the animals are killed and

their organs are observed for the presence of cancer. Reproductive and developmental tests are

used to determine the effects of a chemical on the reproduction of an animal and the effects on

their offspring as well. One test includes giving pregnant animals chemicals orally and just

before she is about to give birth she is killed and the fetuses are examined to see if the chemical

has toxic effects on the offspring. The other test involves exposing the male and female, before

mating, to the chemical to see if they are able to reproduce. This test is usually done in two
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generations to see the true effect on reproduction. Lastly, neurotoxicity tests determine the effect

of a chemical on the nervous system. Weight and behavior changes are monitored and then the

animal is killed to examine for neurotoxicity. There are many tests that can be done to measure

the damage of a chemical on an animal and as described, all of them are cruel and cause a great

deal of pain to the animals. Below is a picture of what an eye irritancy test looks like.

During these tests, the animals will have many reactions to the chemicals they are

exposed to. As the AAVS stated on their website about acute and repeated toxicity tests,

“However, during these tests, animals will often endure excruciating pain, convulsions, loss of

motor function, and/or uncontrollable seizures. The animals are killed at the end of the test so

that a necropsy can be performed to determine internal damage.” For the eye irritancy tests

ulcers, redness, and bleeding in the eye is common, blindness can also occur. For the skin tests,

skin irritation and allergic/immune reactions occur, as well as itching, swelling, and
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inflammation. Animals such as rats and mice, fish, amphibians, and reptiles make up of over 99

percent of the animals used in these experiments. These animals are not included in the

protection from the Animal Welfare Act of 1966, which means these species do not have to be

given pain relief, veterinary care, search for alternative methods, or be regulated by the USDA.

It’s interesting that the animals used the most in testing also happens to be the ones excluded

from this act. This leads to minimal protection and regulation for the animals used in these

experiments.

After these experiments are performed, the animals do not get to experience life again.

They do not get to become someone’s pet afterward but instead are euthanized. Sometimes their

injuries from the tests are so bad that being put down is the only humane option. If not, they

would have to live out the rest of their life in pain. Other times the experiments call for the

animal to be killed at the end so the internal organs can be examined to check for damage inside.

These animals live a life of pain due to these tests and the only way out of it is death.

Animal testing can be very unreliable and the data produced from these tests is

sometimes inconclusive. Referring back to the paragraphs above, eye irritancy tests usually

involve rabbits. Comparing rabbits to humans is like comparing apples to oranges. Rabbits

produce fewer tears than humans which causes chemicals placed into the eyes to stay there

longer, which would allow for more irritation. The structures of our eyes are different which

makes it harder to predict irritation as well. Acute and repeated dose toxicity is unreliable

because animals react to chemicals in different ways than humans do. Human and the animal

skin used for these tests is different making skin irritation tests unreliable. For skin sensitization

tests our liver enzymes are different which would make data unhelpful. Another thing to note is
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that rats are more prone to cancer than humans, which makes it difficult to believe data from

carcinogenicity tests is reputable. Human and other animals have very different reproductive and

life cycles, which makes reproductive and developmental tests less reliable as well. Also, often

times animals are exposed to an unnatural amount of the chemical which would be a different

amount than a human using the product would be exposed to it. Since different species’ skin,

eyes, and the way we react to chemicals is different, experiments that are conducted are

unhelpful and simply a waste of an animal’s life.

In an article by PETA, they stated that “Diseases that are artificially induced in animals in

a laboratory, whether they be mice or monkeys, are never identical to those that occur naturally

in human beings. And because animal species differ from one another biologically in many

significant ways, it becomes even more unlikely that animal experiments will yield results that

will be correctly interpreted and applied to the human condition in a meaningful way” By doing

animal testing manufacturers think that they are helping humans by proving the safety on other

animal species, however because of our differences the experiments end up providing useless

data and killing innocent animals. Even though humans are thought to be very similar to

monkeys, we still have some very significant differences even in our closest relative. This

method isn’t very effective, because humans and the other species we test on are not the same.

An interesting example from PETA’s article was the one about Dr. Richard Klausner

from the National Cancer Institute. He says that they have already been able to cure cancer in

mice, but for humans, they could not. Chemicals tested on animals may cause cancer in the

animals, but not for humans and vice versa. Another example was about the HIV/AIDS vaccines

for monkeys. At least 85 vaccines have worked to protect monkeys from HIV/AIDS but they
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failed on humans. These specific examples of studies done help prove the point that humans and

other animals are not the same, so testing chemicals on animals that will be used on humans is

pointless. We might think the results will be helpful but in reality, they are most likely not.

Consumers usually don’t want to support and give their money to brands that cause pain

to animals. “60 percent of people are more likely to buy products that have not been tested on

animals”. An even higher percentage of people think animal testing is wrong. Alternative

non-animal testing methods are more effective and decrease the number of animals used in

testing. Nakamura writes “Increasing ethical concerns regarding animal experimentation have

led to the development of various alternative methods based on the 3Rs (Refinement, Reduction,

and Replacement)... specific alternatives to the animal models are discussed, including

biochemical approaches, 2-dimensional and 3-dimensional cell cultures and volunteer studies, as

well as future directions, including genome-based research and the development of in silico

computer simulations of skin models.” The advancement of science today allows us to be able to

do tests we couldn’t do in the past. Many years ago banning animal testing would be impossible,

but today with modern science animal tests can be recreated with more effective non-animal tests

for a lower cost.

Specific tests that can be recreated are the skin and eye irritation tests, phototoxicity tests,

and skin erosion. Recreated alternatives for animal testing can be more precise, effective,

cheaper, and quicker. Recreating human tissue to test chemicals on is more reliable than testing

on animals that are different from humans. A scholarly article written by Thomason showed an

inexpensive and quick way to assess a mascara’s irritability. Since mascara goes near your eyes,

it’s important that through tests be conducted to ensure the safety of the product and make sure it
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doesn’t irritate eyes. He stated that the experiment allowed them to “establish the groundwork

for such studies to be applied at a more commercial level. We do this by developing a bioassay

for mascara toxicity and indicate the low cost and the ease of performing such tests, as a

consideration for their future commercial application.” This is just one example of a non-animal

test, not to mention one that is inexpensive (compared to animal testing) and quick to do. This is

important because it shows that non-animal testing is not out of reach and can be done with

modern day science. It also encourages this testing to be done at a commercial level.

There are many alternatives methods that are just as effective or even more effective than

animal testing. As science continues to develop, the effectiveness will go up and the cost will

continue to go down, making the ban on animal testing in cosmetics even easier and makeup

companies will have more incentives to go cruelty-free than ever before. That being said makeup

companies still have no excuses to go cruelty-free now. Countries have already shown that it is

possible to ban animal testing and still make safe products. Some makeup companies in the U.S.

don’t test on animals, and even more, are making the switch. If these companies can make

products without testing on animals, all brands can do the same.

One way that brands in Europe are able to stay cruelty-free is because they have a “safe

list” of all the chemicals that have ever been tested on animals in the past and have been verified

safe. While this does mean that the chemicals were tested on animals at some point, it also means

that the same chemicals can be used without testing them again. Also since the testing on

animals isn’t banned in pharmaceuticals, ingredients that are tested in that field can be taken into

the cosmetic field. Some people see this as going around the system or finding loopholes, but it’s

a smart thing to do and still decreases the number of animal lives lost. If the chemical has already
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been tested, you can’t change the past, so you might as well use the data from that experiment to

benefit the safety of the cosmetics. Both of these ways would overall help decrease the number

of animals killed each year in testing and they make banning animal testing in cosmetics

possible.

An economic reason why animal testing should be banned is that it is expensive. It is

much more expensive to conduct animal tests versus in vitro tests which do not use animals. The

Humane Society International states that animals testing has “ a cost of hundreds of thousands -

and sometimes millions - of dollars per substance examined.” One reason animal testing costs so

much is because many animals have to be used to test just one substance and each substance has

to be examined separately. To get the data as accurate as possible more animals have to be used

which means more money. When you are testing multiple substances the costs add up. When

comparing animal testing with non-animal testing, non-animal testing is significantly less

money. For eye irritation, the animal test cost is around $1,800 and the in vitro test costs $1,400.

For skin corrosion tests, the animal tests cost is around $1,800 and the in vitro tests cost $850

and $500. For skin sensitization tests, the animal test cost is $6,000 and the in vitro test costs

$3,000. Lastly, the phototoxicity animal test costs $11,500 and the in vitro costs $1,300. For each

test listed the in vitro test is cheaper and sometimes the cost is cut in half or more. By switching

to in vitro testing, companies can save money when testing their products.

While many people are beginning to see the horrors of animal testing and are starting to

oppose it, there are people who still support it because they think it is absolutely necessary in

order for cosmetics to be safe. Wischhover writes that most makeup brands do want to eventually

move away from animal testing, as it has many negatives. Brands have received a lot of backlash
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and negativity for testing on animals from people who don’t support it. This is good because it

encourages brands to become cruelty-free. She states that “The U.S. has many resources

committed to researching alternatives to animal testing. The Center for Alternatives to Animal

Testing (CAAT) at John Hopkins is at the forefront of science, and it receives funding from

private cosmetic companies, philanthropy, and grants from governmental agencies like the NIH.

Thanks to the CAAT’s research, there are a number of tests that can substitute for animal testing

now… there are no laboratory tests yet that can replicate the results of what happens when a

chemical is inhaled or to predict whether a substance will cause cancer, for example.” While

there might not be any non-animal tests available yet for these two situations, there is still a “safe

list” of chemicals they could pick from to use in their products. Many popular brands, for

example, Anastasia Beverly Hills, Colourpop, Covergirl, Elf, Hourglass, Urban Decay, Too

Faced, and many more do not test on animals. These are a mix of high-end and low-end makeup

brands. If over 500 makeup companies can make safe products without testing on animals,

brands have no excuses to still do so.

Banning animal testing for cosmetics in the U.S. would decrease the number of animals

being used for, and killed in experiments, save companies money, and provide alternatives to

animal testing. It would encourage other countries in the world to ban animal testing and the

brands would gain more support from the public. Makeup is not for animals and therefore should

not be tested on animals.

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Works Cited*

Adler, Sarah, et al. “Alternative (Non-Animal) Methods for Cosmetics Testing: Current

Status and Future Prospects-2010.” ​SpringerLink​, Springer, 1 May 2011,

link.springer.com/article/10.1007/s00204-011-0693-2.

Admin. “Testing.” ​American Anti-Vivisection Society,​ Aavs,

aavs.org/animals-science/how-animals-are-used/testing/.
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Baldrick, Paul. “Juvenile Animal Testing: Assessing Need and Use in the Drug Product

Label.”​Therapeutic Innovation & Regulatory Science,​ NCBI, Sept. 2018,

eds.a.ebscohost.com/eds/detail/detail?vid=1&sid=6d4d2bdf-2600-4625-933d-40b4559737

17@sessionmgr4006&bdata=JnNpdGU9ZWRzLWxpdmU=#AN=131758709&db=lih.

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“Cosmetics.” ​Understanding Animal Research,​

www.understandinganimalresearch.org.uk/policy/cosmetics/

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www.hsi.org/issues/chemical_product_testing/facts/time_and_cost.html.

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by Cruelty Free International.” ​Business Wire, Inc.,​ 5 Nov. 2018,

eds.a.ebscohost.com/eds/detail/detail?vid=8&sid=92a977a6-c2dd-4478-bcb1-61d5801e3b

2f@sessionmgr4006&bdata=JnNpdGU9ZWRzLWxpdmU=#AN=edsgcl.561122209&db=

edsggo.

“Experiments on Animals: Overview.” ​PETA,​ PETA, 9 Nov. 2018,

www.peta.org/issues/animals-used-for-experimentation/animals-used-experimentation-fact

sheets/animal-experiments-overview/.
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Davies, Jamie A. ​Replacing Animal Models: a Practical Guide to Creating and Using

Biometric Tissue Alternatives.​ Wiley-Blackwell, 2012.

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REGULATIONS IN COLOMBIA.” ​Escritos​, Universidad Pontificia Bolivariana, Dec.

2016,

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Taylor & Francis Ltd,

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Siegel, Elizabeth. “The Real Reason So Many Beauty Brands Still Test on Animals.” ​Allure,​

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mal-testing/​.

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