May 18, 2023

expert reaction to government announcing that no new licences will be issued for animal testing of chemicals used exclusively as cosmetic ingredients

The Secretary of State for the Home Department, Suella Braverman, announced the licensing ban with immediate effect.

Dr Ernie Harpur, Associate Lecturer, Translational and Clinical Research, Newcastle University, and former president of the British Toxicology Society (2016-18) and EUROTOX (1998-2000), said:

“I support the Government’s position on this. If there is uncertainty about worker (or user) safety of a novel chemical intended for exclusive use in a cosmetic product, then it should not be used until such times as an agreed non-animal alternative method has been developed. There is no commercial or social imperative that would justify the testing on animals in this context.”

Professor Malcolm Macleod, Professor of Neurology and Translational Neuroscience and Academic Lead for Research Improvement and Research Integrity, said:

“From an ethical perspective, animal experiments can be justified, in my view, only if the potential benefits (in terms of knowledge gained, and its application) outweigh the potential harms.

“The position of research for commercial purposes relating to cosmetics or new foodstuffs is therefore in a different ethical position to research relating to potential new treatments for human disease.

“This is slightly more complex, because the issue here is the risk of occupational harms to workers in those industries – but any current research would relate to the safety of new chemicals to be involved in those processes, the safety of existing chemicals (one would hope) already having been established – and so the impact of the government decision will be that new chemicals are not introduced to these processes (because the occupational safety cannot be established), and so they have to rely on existing chemicals, and in my view that is a reasonable and proportionate decision.

“Some other considerations:

• In some regulatory settings (eg environmental toxicology) there are large numbers of compounds approved for use which have not been through a contemporary regulatory system, having been ‘grand-fathered’ in from previous regulatory frameworks. Humans are exposed to these chemicals, often on a daily basis, and evaluation of risk to humans – an evaluation which may include animal experimentation – is in my view justified on the basis of benefits and harms outlined above
• Over many years there have been discussions about the use of ‘NAM’s, variously non animal methods or novel alternative methods or new approach methods – in the evaluation of potential toxicity. In my view we are not yet at a stage where NAMs can substitute, completely, for animal research.
• One issue is how we validate the NAM – how do we know that it can predict human toxicity. This is a subject of a great deal of current research. One disappointing consequence of the UK Govts failure to accede to Horizon Europe is that UK scientists will be unable to lead consortia addressing this issue, for instance in response to calls such as HORIZON-HLTH-2024-TOOL-05-06-two-stage: ‘Innovative non-animal human-based tools and strategies for biomedical research’, where we could make a major contribution. This consequence of this is that our UK expertise, and research critical mass, in these areas is less than it might otherwise be, and in my view this will also have impacts on the UK regulatory regime and, thereby, on UK industries.”

Prof Vitaliy Khutoryanskiy, Professor of Formulation Science, University of Reading, said:

“I agree that the development of alternatives to animal experiments is needed, and these alternatives could be in the form of cell- and organ- culture technologies. Some of these alternative models are already used widely for testing of many chemicals and formulations; however, more alternative methods are needed. Cell cultures are commonly used in toxicology; however, these cannot always predict the complex reactions that human organism may experience when in contact with some chemicals. Therefore more complex toxicological models are needed, which should include organ cultures and possibly even lower animals like invertebrates such as worms, insects, molluscs, and crustaceans. Also when these alternatives are developed they require a validation using higher animals such as mammals. This validation is often unavoidable.” 

Professor Clare Stanford, Professor of Translational Neuropharmacology, University College London, said:

“This is excellent news, which will be a welcome relief for the bioscience and safety research community.  It is hard to understand how the use of animals for testing cosmetic ingredients can be justified for one purpose, but not others.  There is promising progress on the development of non-animal alternatives for some classes of chemicals but, at present, their use as substitutes for animal testing has to be assessed on a case-by-case basis.”

Dr Vicky Robinson, Chief Executive, NC3Rs (National Centre for the Replacement, Refinement and Reduction of Animals in Research), said:

“I was pleased to meet with the Home Secretary today along with colleagues from Unilever and the Cosmetic, Toiletry and Perfumery Association.  We were able to provide a united voice on the importance of applying robust scientific approaches, that avoid the use of animals, for protecting the safety of workers involved in the manufacture of cosmetics ingredients.  These cutting-edge approaches have been used over the last decade to protect the safety of consumers and it is a regulatory contradiction that they are not used for the purposes of worker safety not least because exposure is tightly controlled in UK factories.

“This is not a dilution of worker safety nor simply concerns for animal welfare, but a call to apply the latest scientific advances to improve safety assessments.  We know that this can be done for cosmetic ingredients for consumers and we need a joined-up and rapid approach across government and its agencies to change the testing requirements under the REACH regulation as it applies to worker safety.”

Chris Magee, Head of Policy, Understanding Animal Research, said:

“This is a welcome statement that makes it clear animal testing for cosmetics is still banned in the UK.  Governments can be placed in a tricky situation if cosmetics manufacturers want to use potentially dangerous industrial chemicals, and we need some sort of test to make sure they don’t cause things like cancer or infertility.  We would all prefer not to use an animal for this so it is a good time to make sure that our non-animal test methods are up to the job of protecting industrial workers, the environment and the general public.”

https://questions-statements.parliament.uk/written-statements/detail/2023-05-17/hcws779

Declared interests

The nature of this story means everyone quoted above could be perceived to have a stake in it. As such, our policy is not to ask for interests to be declared – instead, they are implicit in each person’s affiliation.

Prof Malcolm Macleod: “I served on the UK Animals in Science Committee from 2012 to 2019; am a Consultant to the US National Academies Review “Variability and Relevance of Current Laboratory Mammalian Toxicity Tests and Expectations for New Approach Methods (NAMs) for use in Human Health Risk Assessment” which will report shortly; and participate in a consortium which holds a tender from EFSA for the development of novel approaches to systematic review and meta-analysis of evidence relating to food safety.”