Bunnies and bunnies and bunnies – oh my! Apparently, being “cruelty-free” isn’t all that straightforward, so I set out to answer: “what does it ~really~ mean to be cruelty-free?” and “what the heck is up with all these different bunny logos”… and I might have thrown a 50 Shades reference in there too.

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This post was partially inspired by a podcast I started listening to recently called Natch Beaut where they were talking about cruelty-free makeup, as well as an assignment that I did last year as part of a Corporate Social Responsibility class.  The assignment was basically to pick a brand and discuss its current CSR initiatives, as well as to propose any initiatives that they could adopt in the future.  Naturally, my makeup-obsessed self chose Sephora and to more specifically analyze their private label brand, Sephora Collection.  I decided to email the company and ask if they were cruelty-free, to which I received a response saying that they were; however, upon further research, I found that Sephora Collection was actually listed on some cruelty-free makeup websites as being one brand to avoid, including a more recent list by Ethical Elephant.  So… what was the truth?

It was at that point that I realized that although I had considered myself pretty “makeup savvy,” I guess I didn’t really 100% know what it meant to be “cruelty-free” – how could a company claim to be cruelty-free and still be considered a brand to avoid?  What exactly does it mean to be “cruelty-free?”

Let’s start with the basics: the pretty much always controversial animal rights advocacy group, People for Ethical Treatment of Animals (PETA), defines “cruelty-free” as not having been tested on animals.  According to a Nielsen survey of 1,000 adults, “not tested on animals” was the most important packaging claim among beauty product consumers with 43% of respondents indicating that they are willing to pay more for products that are not tested on animals.  Additionally, a report from the Physicians Committee for Responsible Medicine showed that 72% of Americans oppose animal testing on cosmetics and consider it “unethical.”  With the pretty simple definition and obvious consumer trend towards cruelty-free products, why is there still so much confusion?

50 SHADES OF (CRUELTY-)FREED

According to the FDA, “the unrestricted use of these phrases by cosmetic companies is possible because there are no legal definitions for these terms.”  The whole “gray area” (sorry I couldn’t resist making a 50 Shades reference above) regarding cruelty-free practices comes from the fact that although some companies may not test on animals in the United States, they still do test on animals somewhere in their supply chain due to the regulations of the other countries they choose to sell in.  

In the past, a company that sold cosmetics products in mainland China that were not domestically produced were required to test on animals; the implications here are that a company selling in another country, such as the United States, may have never tested products on animals in the United States because it is not required; however, if it sold product on the mainland Chinese market, it was still required to test on some part of its supply chain.  

In 2014, China changed its policies on animal testing, stating that animal testing is no longer an “absolute requirement” on domestically produced “ordinary” cosmetics, which include makeup, fragrances, skincare, hair, and nail care products, but is still required on “special use” cosmetics, which include hair dyes, perms and hair growth products, deodorants, sunscreens, skin-whitening creams, and other products that make a “functional claim” on the label.

With these regulations in mind, let’s go back to Sephora Collection.  Since it’s manufactured in countries worldwide (including China) and contains both ordinary and special use cosmetics, this means that despite Sephora’s claims, Sephora Collection is not completely cruelty-free worldwide and isn’t certified “cruelty-free” by PETA.  If they wanted to be truly cruelty-free in the global sense, Sephora needs to stop selling its special use products in stores in mainland China.  This doesn’t mean Sephora needs to stop selling those products completely to the Chinese market because China has never required testing on “any cosmetic bought in China via a foreign e-commerce website,” indicating that as long as ordinary products sold in China are manufactured in China and its special products sold online to customers in China are manufactured in a country that does not require animal testing, it can be cruelty-free compliant worldwide.

DIFFERENT SYMBOLS

If you’ve looked for the little symbols on your makeup products, you may have noticed there are a few different variations of a “bunny” that indicates your product is cruelty-free.  PETA has one logo, while another popular one is the “leaping bunny.”  I don’t mean to sound like your high school English teacher, but pay attention to these symbols because they’re not all necessarily the same!

According to Cruelty Free Kitty, there are “only 3 bunny logos a cruelty-free shopper should trust,” which include the PETA bunny (which you’ve probably seen on your makeup before if you’re in the US), the CCIC “leaping bunny,” and the Choose Cruelty Free rabbit.

As you can see above, to use each logo, you’d need to be certified by the organization. and in all cases, there’s also some kind of licensing fee that needs to be paid in order to be able to use it.  They also have some different ways of certifying/accrediting companies, which are as follows:

PETA // Beauty Without Bunnies

A company that is interested in having its name added to our cruelty-free list(s) must complete a short questionnaire and sign a statement of assurance. Upon receipt of these completed documents, your company will be added to our pocket-sized Cruelty-Free Shopping Guide and our searchable online database of cruelty-free companies

CCIC // Leaping Bunny

Companies may license the use of the logo after becoming certified by CCIC, thereby making a pledge that, as of the fixed cut-off date, they do not conduct or commission animal tests, and do not use any ingredient or formulation that is tested on animals. A one-time licensing fee, based on the company’s gross annual sales, is required for use of the Logo.

CCF // Choose Cruelty Free

To be eligible to apply for CCF accreditation your company must:

1. Produce cosmetics, toiletries and/or household cleaning products;
2. be fully established for one year;
3. have an ABN (or equivalent for offshore companies);
4. have a business e-mail address and an operational website; and
5. be selling to Australian consumers online and/or retail.

To become an accredited cruelty-free company with CCF, you must fill in the Questionnaire & Application for Accreditation (Q&A), including a legally binding contract.

If you use a contract manufacturer to make some or all of your products, they too are required to complete a Q&A in support of your application. Your manufacturer need only complete the forms as they relate to the products they make for you.

…

Companies on the CCF List are regularly asked to undergo re-accreditation to ensure that they still comply with CCF’s criteria for accreditation. There is no fee for re-accreditation.

If this is a lot to take in, Cruelty Free Kitty wrote a post comparing the Leaping Bunny and PETA, which is definitely worth reading.  She basically points out that Leaping Bunny’s list is smaller than PETA’s because it’s way more selective, while PETA only requires a written agreement from companies and Leaping Bunny requires an agreement to independent audits.

DOES CRUELTY-FREE = VEGAN?

The short answer: no.  According to Logical Harmony, a product that is vegan “does not contain any animal ingredients or animal-derived ingredients,” which can include honey, beeswax, lanolin, collagen, albumen, carmine, cholesterol, gelatin, and many others.  A brand or product can be cruelty-free and not be vegan because although they don’t test on animals, they can still contain one or more of the listed ingredients.  I think a classic example of this is Burt’s Bees, who is cruelty-free (although this status was disputed and clarified by My Beauty Bunny), but since most of their products contain beeswax, the brand isn’t vegan.

TL;DR

In short, a cruelty-free product means it hasn’t been tested on animals, and while a brand that produces and sells a product in the United States may call themselves “cruelty-free,” if they sell in another country where they’re “required by law” to test, they’re technically not cruelty-free worldwide.  One classic example of this is Mainland China, where a lot of popular brands choose to sell, but there are two “loopholes” that would allow a brand to sell in China while remaining cruelty-free:

• Produce “ordinary” products “domestically” (in China)
  • Ordinary = makeup, fragrances, skincare, hair, and nail care
• Sell “special use” products online only
  • Special Use =  hair dyes, perms and hair growth products, deodorants, sunscreens, skin-whitening creams, and other products that make a “functional claim” on the label

Furthermore, there are different cruelty-free logos that are issued by different organizations and mean different things and you should note that just because a product might be cruelty-free worldwide, it doesn’t guarantee that they’re actually vegan as they might contain animal ingredients or animal-derived ingredients.

At the end of the day, I think it all comes down to personal morals.  I’m not vegan and don’t really tend to pay attention to whether or not a product is vegan-certified, and while I try to look for products that haven’t been tested on animals, if we’re being honest, I don’t tend to look into their global supply chain.  I know there are people who are really passionate about only using products that are 100% cruelty-free in the global sense, and I think that’s something I want to work towards also getting into.

If this is something you’re passionate about, here’s a list of lists (redundant, I know) put together by people much more knowledgeable about this topic than I am:

• Cruelty Free Kitty // List of Officially Cruelty-Free Brands // Ultimate Guide to Cruelty-Free + Vegan Makeup Brands
• Logical Harmony // Cruelty-Free Brand List
• PETA // Product-Testing Database
• Leaping Bunny // Leaping Bunny Approved Brands
• Choose Cruelty Free // Choose Cruelty Free Lists

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BLOGS MENTIONED

• Ethical Elephant // Which Brands at Sephora are Cruelty-Free or Tested on Animals?
• Cruelty Free Kitty // How to Spot a Fake Cruelty-Free Logo // Leaping Bunny vs. PETA: Who to Trust?
• Logical Harmony //  What’s the Difference Between Cruelty-Free and Vegan Cosmetics?
• My Beauty Bunny // Is Burt’s Bees Cruelty Free?

ORGANIZATIONS MENTIONED

• PETA // What Does ‘Cruelty-Free’ Really Mean? // What is Beauty Without Bunnies? // Beauty Without Bunnies Program
• CCIC // The Leaping Bunny Logo
• CCF // Home // CCF Accreditation

OTHER SOURCES

• Nielsen // PACKAGE THIS: BEAUTY CONSUMERS FAVOR ‘CRUELTY FREE’ AND ‘NATURAL’ PRODUCT CLAIMS
• Physicians Committee for Responsible Medicine // More Than a Makeup Trend: New Survey Shows 72 percent of Americans Oppose Testing Cosmetics Products on Animals
• FDA // “Cruelty Free”/”Not Tested on Animals”
• Humane Society International // China Implements Rule Change in First Step Towards Ending Animal Testing of Cosmetics

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*Disclaimer: I am in no way affiliated with or compensated by any of the organizations or brands mentioned.  As always, all thoughts & opinions are my own (unless stated otherwise)!