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The "cruelty-free" lie: why this claim is meaningless in the EU

If you're an EU consumer, you've seen it countless times. A skincare brand proudly stamps "cruelty-free" or "not tested on animals" on their packaging and/or website. It feels good, doesn't it? Like you're making an ethical choice.

The uncomfortable truth is though that this claim is legally meaningless in the European Union. And brands know it.

What the law actually says

In 2013, the EU implemented a complete ban on animal testing for cosmetic products and their ingredients. Under Regulation (EC) No 1223/2009, it is illegal to sell any cosmetic product in the EU that has been tested on animals, or contains ingredients that have been tested on animals for cosmetic purposes.

This means that every single product on the EU market is, by law, cruelty-free. There are no exceptions for finished products or ingredients to meet the requirements of the EU Cosmetics Regulation.

So when a brand slaps a "cruelty-free" label on their product, they are telling you something that is already a legal baseline. It's like a car manufacturer bragging that their vehicles come with seatbelts. It's not a virtue; it's the law.

Why the "cruelty-free" claim is actually misleading

According to Commission Regulation (EU) No 655/2013, which lays down common criteria for cosmetic claims, any claim that conveys the idea that a product has a specific benefit when that benefit is mere compliance with minimum legal requirements shall not be allowed.

Simply put: you cannot claim a benefit that is just the law. A "cruelty-free" claim is not compliant with the EU common criteria claims, because it conveys the idea that a product has a specific benefit when this benefit is mere compliance with minimum legal requirements.

Yet brands continue to use it as a marketing tool to appear more ethical than their competitors. And consumers, unaware of the law, fall for it.

The grey areas

There are nuances. The REACH regulation, which governs chemicals in the EU, can require animal testing for certain substances to assess risks to workers or the environment during manufacturing. These risks are not covered by the Cosmetics Regulation. This means ingredients used in cosmetics can theoretically be tested on animals for non-cosmetic purposes.

However, the EU has been working to phase this out. Extensive funding has been provided to develop alternatives. The Commission is actively preparing a roadmap to replace animal testing in chemical safety assessments.

What brands don't want you to know

The "cruelty-free" claim is cheap marketing that preys on your good intentions. It doesn't communicate anything special about the product. It doesn't tell you about the formulation, the efficacy, the ingredient sourcing, or the sustainability.

It simply tells you the brand is complying with a law that applies to everyone.

And they're betting you don't know that.

Our position

We don't use the "cruelty-free" label. Not because we support animal testing, we absolutely do not. But because we believe in transparency over marketing fluff.

Every product we sell is legally compliant with the EU's animal testing ban. That's the baseline. What we want to talk about is what happens above that baseline: the quality of our ingredients, the ethics of our sourcing, the science behind our formulations.

We refuse to greenwash you with claims that mean nothing.

Sources