What Does “Cruelty-Free” Really Mean? - Public Goods

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What Does “Cruelty-Free” Really Mean?

More so now than ever, consumers want to know what’s inside of their products and how they’re made.

lab testing rabbit

The rise in sustainable shopping practices and eco-friendly consciousness has forced us to reflect on how animals and animal byproducts are incorporated into our everyday products.

Even if you don’t identify as vegan, there’s an ethical argument to be made in favor of buying “cruelty-free” products. But you might be surprised to discover that this animal-friendly marketing phrase doesn’t really mean what you think.

The “cruelty-free” label is on more bathroom, personal care, cosmetics and household products than ever, but does it have an actual definition?

What Does Cruelty-Free Really Mean?

According to the U.S. Food and Drug Administration (FDA), there’s no standard legal definition for the term, so brands are free to use the language however they want. Usually the goal is to attract conscientious consumers who are willing to spend more than people who don’t consider ethical issues. Cruelty-free products should not be confused with vegan products.

Companies employ the label to imply they do not play a role in testing products on animals or harming them in any way. As opposed to more specific language such as “not tested on animals,” “cruelty-free” doesn’t make a claim. Like “natural,” it’s one of those terms where government regulations have not caught up to marketing trends.

One common misunderstanding in the U.S. is that ingredients in cosmetics and beauty products must be tested on animals. According to the Federal Food, Drug and Cosmetic Act, the FDA “does not specifically require the use of animals in testing cosmetics for safety.”

In mainland China, however, all cosmetics must be tested on animals. Some brands that claim to be cruelty-free change their position to enter the Chinese market.

Because “cruelty-free” doesn’t have a single legal or official specification, there are several meanings various brands and organizations use interchangeably:

  1. The ingredients have been tested on animals, but the final product has not.
  2. The brand hired another company to conduct tests.
  3. The brand or manufacturer relied on test results from an outside organization.
  4. The testing occurred in a different country than the one the brand is based in (usually China because it requires animal testing).
  5. The brand only uses animal testing when it is required by law as part of expanding into foreign markets (usually China).
  6. At least one animal was harmed or killed and used for ingredients (what “animal products” means), but there was no testing.
  7. The brand, or companies involved in its supply chain, have relied on the results of past animal tests from other organizations, but they have not conducted any tests themselves, harmed any animals or sourced any animal-derived products or byproducts.
  8. Neither the ingredients nor the products have ever been tested on animals, and the companies involved have not harmed or slaughtered any animals.
  9. The brand has a cruelty-free certification (not a legal regulation, but still provides a higher level of accountability).

Those last three definitions are the most ethical forms of cruelty-free production.

Cruelty-Free Certification Programs

If you want to find brands that meet the highest standards of being cruelty-free, try searching on the Leaping Bunny database or Beauty Without Bunnies, PETA’s certification program and database of approved companies. Below we break down the differences between these certifications. Both are legitimate, but you might feel like one carries more weight than the other.

There are also organizations that might be relevant if you live in Australia. Let us know if this list is missing anything!


To earn a cruelty-free certification from PETA, companies “must complete a short questionnaire and sign a statement of assurance verifying that they do not conduct, commission, or pay for any tests on animals for ingredients, formulations, or finished products and that they pledge not to do so in the future.” If these brands want to show off PETA’s cruelty-free bunny logo, they have to pay a one-time licensing fee of $100.

PETA has a ton of media power. If a company violates their statement of assurance and gets called out, they’d better get ready for a PR nightmare.

Leaping Bunny

Leaping Bunny is not nearly as well-known as PETA, but their certification program seems more extensive. In addition to what PETA stipulates in the statement of assurance they ask companies to sign, Leaping Bunny’s contract requires companies to implement a “Supplier Monitoring System” and allow independent audits of their business. For those who want to double check brands while they’re out shopping, Leaping Bunny has a cruelty-free app you can download for free.

Choose Cruelty-Free

An Australian organization, Choose Cruelty-Free [CCF] monitors both Australian and international brands. Companies can apply for CCF accreditation and license the CCF registered trademark (“Not Tested On Animals” text with bunny illustration) if their supply chain meets the following criteria:

  • The never tested rule: None of its products and none of its product ingredients have ever been tested on animals by it, by anyone on its behalf, by its suppliers or anyone on their behalf. ​
  • The five year (or +) rolling rule: None of its products and none of its product ingredients have been tested on animals by it, by anyone on its behalf, by its suppliers or anyone on their behalf at any time within a period of five years immediately preceding the date of application for accreditation.”

The CCF list divides companies into several categories:

  • Licensed Cruelty-Free Companies: brands that are paying an annual fee to use the “Not Tested On Animals Rabbit Logo”
  • CCF Vegan List: brands that are paying an annual fee to use the “Not Tested On Animals Rabbit Logo,” and CCF considers them vegan (although this vegan label doesn’t seem to have a certification process like the cruelty-free aspect)
  • Removed From CCF List: companies that once earned CCF accreditation but lost it by violating criteria or failing to renew contracts

If you live in Australia, download the CCF app to check products while you’re out shopping.

A Brief History of the Cruelty-Free Trend

Originally the idea of cruelty-free had little to do with testing products on animals. It was more about product alternatives that did not require the slaughter of animals. The issue appealed more to vegetarians and vegans than people who did not want animals to suffer the pain and trauma of tests.

The concerns may sound similar, but they focus on different groups of people. Think about how there are consumers who eat meat but shop cruelty-free, as well as those who are vegetarian and vegan but do not care about the cruelty-free movement.

In 1959 animal rights activist Muriel Dowding founded Beauty Without Cruelty, a charity that eventually became a manufacturer of vegan cosmetics. Dowding encouraged apparel companies to manufacture fake fur instead of butchering animals and using their hides. About a decade later, Marcia Pearson founded Fashion With Compassion, a similar organization.

During the 80s and 90s the “cruelty-free” language became more prevalent, according to green business consultant Shel Horowitz. The term started to refer to animal testing and personal care products, not only fake fur and similar goods. In 1987 PETA launched their cruelty-free certification program and developed a long-term initiative to dissuade companies from testing personal care products on animals. During the 90s Cruelty Free International investigated and exposed the trade of monkeys used in product research and testing. They also created the Leaping Bunny Program.

Another significant factor in the movement was consumer lawsuits against big cosmetic brands that lied about testing their products on animals. In 2012 five women filed a class action suit that accused Mary Kay, Estee Lauder and Avon of false claims regarding their “cruelty-free” products. The companies had compromised their values to access the Chinese market, where animal testing is required.

Between 2012 and 2017, interest in the cruelty-free movement spiked, according to Google Trends data. After decades of sustained efforts from organizations such as PETA and Cruelty Free International, many countries banned animal testing. The European Union and Israel were some of the first, followed by India.

In 2015 U.S. Congressman Martha McSally introduced the Humane Cosmetics Act, which has still not been passed into law. Australia and New Zealand are considering similar legislation that would ban animal testing.

Beauty product consumers value “not tested on animals” and other cruelty-free language as the most important claim on the packaging of their products, according to a 2015 Nielsen survey. “Contains no animal products” was also one of the top interests.

The Future of Cruelty-Free

The cruelty-free market is expected to grow at least 6% through 2023, according to a report from Market Research Future. Daniel Levine of trends consulting firm Avant-Guide believes millennials will continue to drive the movement by holding brands to high standards of integrity and ethics.

“We’re in an age where people’s BS meters are super sensitive,” Levine said.

Today consumers and advocacy organizations are continuing to sculpt a landscape where there is only one definition of cruelty-free: the one that actually doesn’t involve any animal testing or harm.

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