By Fraser Hill, Founder and CEO of Skinega.

As the founder of a Leaping Bunny registered cruelty free skincare brand, there has always been something that has troubled my conscience. I am obsessed with transparency in skincare and seeking the truth for consumers. On my journey of skincare discovery, I found that truth and skincare are linked only in a very tenuous and somewhat fractured way. The purpose of this article is not to pass an opinion but rather to share some facts, and seek some input as to whether there is a right or wrong answer to a very troubling problem.

As the title suggests, ingredients in all cruelty-free skincare brands have at some point been tested on animals. If that’s news to you, I’m afraid you did read that correctly. That is not to say that brands actually test their finished products on animals, but rather, every ingredient that ever existed in skincare has at some point been tested on animals somewhere. How do you think we know tea tree oil is excellent for skin but toxic if ingested? It’s because, like with all other natural or synthetic ingredients, tea-tree oil has at some point gone through some toxicology tests, where they find out, amongst other things, how much of it is enough to kill at least half the population of rats or mice that it’s introduced to. That leads us to understand what the LD50 is (lethal dose required to kill 50% of a test population), which is a common reference point in toxicology.

Now if your reaction to this statement is, “well that’s different, they didn’t actually test the products on animals,” is the intermediary separation from the source of the testing sufficient to ease your conscience? I’m not convinced that it is, and if you think its black and white, perhaps your mind will change as you read on.

The issue with so much of today’s collectivist opinions on everything from politics to social media, is that so many people are just regurgitating other people’s views without so much as a second thought. Before you know it you have a movement of people, sometimes in their millions, holding views that are not entirely understood, and often seriously misunderstood. Because they’re mistaken by a whole movement of people, they grow to become accepted facts by anyone and everyone who thinks it sounds right or morally correct or fitting to their perspective on life.

In skincare, it is even more warped and messed up than these facts would lead you to believe. In another article I wrote (Skincare’s Four Most Abused Terms – Toxic, Natural, Organic and Clean), I discussed a 100% organic product that I came across online. It contained a brand new organic skincare extract apparently commissioned by that company. In the full scientific report for any ingredient discovery, the report will always list the methods used and so on. This is standard practice across any ingredient research. In this particular report, that you have to dig hard to find as its certainly not in the skincare company’s website, there are two interesting parts. One is the method of extraction using petrochemical solvents for this ingredient. The second is the graphic description of the killing of pregnant mice and how the brains of the embryos were mushed up and so on it goes. If you’re disgusted by this summary, you should read the detail. It’s like a horror movie. All of that for an extract of a plant, stripped of its organic identity by industrial solvents, and death to a bunch of mice along the way, so this ingredient can be marketed in a 100% organic brand where the product is “not tested on animals.” That one story alone, for me, best represents how far we have fallen as an industry, and how long a path we have ahead of us.

Herein lies the moral or ethical dilemma for anyone who cares about animals, animal cruelty, or animal testing. At what point in the supply chain of finished skincare products does animal testing on ingredients become a non-issue for those who refuse to use products that have been tested on animals? If you refuse to use any products that were tested at any point in the ingredient supply chain, then good luck in your hunt because it just isn’t possible to use a product that is free from any ingredients that have ever been tested on animals.

To add some context to this, I have listed some below some examples, going from one extreme to another, with each number getting further and further away from directly being tested on animals. If you are so sure that direct animal testing of specific products is wrong, at which point along this continuum has the testing accountability been sufficiently diluted for it to qualify as okay in your view?

  1. The actual product you purchased was tested on animals – the very item you purchased was first of all added to a patch of Bugsy’s skin.
  2. The product you purchased was from a small batch of one hundred products. One of the hundred was tested on a rat. We don’t know which one.
  3. The product you purchased was from a batch of fifty thousand. Ten of them were tested on animals. We know yours wasn’t, but it was in that batch.
  4. A product from a separate batch produced five years ago was tested on animals, but no testing has been done since.
  5. A product you bought called X has not been tested on animals, but its name just changed two weeks ago. A year ago, it was named product Y, from the same company, and it was tested on animals.
  6. A product that is a copycat of a different company’s product was not tested on animals, but that company, whose patent has expired, did test it on animals twenty-five years ago.
  7. A product contains a unique ingredient that was tested on animals specifically for this company product in the past year. The product itself was not tested on animals.
  8. A company bought an ingredient that was tested on animals in the past year and now has it in their product.
  9. A company bought an ingredient that hasn’t been tested on animals since it was first invented, and it was first produced specifically for the skincare industry.
  10. A company bought an ingredient that hasn’t been tested on animals since it was first invented, and it was initially produced for a separate industry.

Now, some of you may say you’re not okay with any of those, but your actions are likely to imply otherwise. You just can’t avoid using products that have never, at any point in their ingredient history, been tested on animals. Is it the case that they are a necessary evil, and as long as steps are being taken to eradicate animal testing, that you are okay? In medicine, the ‘necessary evil’ is probably a more valid argument, and incidentally, all drugs introduced into the US market must be tested on animals, in a similar way that China approaches cosmetic and skincare products.

It appears that may soon slowly be starting to change, but we’re a long way away from animal testing in drug development being a thing of the past. Incidentally, I wrote in another article (Why USA Government Skincare and Beauty Reforms Deserve A Nancy Pelosi Clap) about animal testing in drug development. In the article, I refer to the horribly inadequate Personal Care Safety Act of 2017, which was a set of proposed reforms to bring the 1938 FFDCA Act (basically the founding FDA Act) up to date as it relates to cosmetics and skincare. In this proposed act, they are proposing to, within three years from the bill being passed (which hasn’t happened), provide a review into alternative methods of testing.

In the article, I showed evidence that the FDA has, for over 21 years, already been researching alternative methods of testing, and so to propose to share some finding after another three years, was just not good enough. The point is, even when the government finally bows to pressure from groups of consumers to start a discussion on change, these proposed changes have, to date, just been paying lip service to the underlying issues laid out.

Incidentally, in researching that article, I stumbled upon some vegan blogs seeking to address this difficult issue of animal testing in medicine. One naïve comment read “I don’t use medicine and never will because they’re tested on animals.” That may be a statement you can make up until a certain age, but good luck getting into your twilight years with that strategy. That statement alone conveyed the naivety that exists with some people and why we need to be taking more time to think about the implications of what we claim to be standing for, rather than just throwing around virtuous statements that reinforce our chosen, but often not very well researched identity.

Not that it’s relevant to any of you, but my personal opinion is, we are where we are; what has been done has been done, and we can’t change the past. We can only change what the future looks like. The fact that an ingredient was tested on animals in 1978 isn’t going to stop me from wearing that moisturizer.

We cannot change the future by being mere spectators though. We have to be much more informed participants in the future we want to see. We have to use our voice to come together as consumers and demand more. That’s not done by lying in front of buildings covered in pretend blood. It starts with getting much more granular about our views and better defining our opinions, and not just being other people’s headline opinions. So where do you stand on this? Under what circumstances is animal testing okay? If your position is, “under no circumstances,” how do you deal with the disconnect of your beliefs and actions?


Fraser is the Founder and CEO of Skinega, Inc. He grew up and was educated in Scotland before going on to forge an 18-year career in executive consulting and research, living and working in London, Hong Kong, Poland, Canada, and in the US, working for companies including J.P. Morgan, as well as starting Consulting firms in Canada in 2008, and London in 2012. With his background in research and technology, Fraser embarked on a consumer-driven journey to seek out cleaner, vegan, more effective luxury skincare. He sought a “free from” list that went beyond just harmful ingredients to include ingredients that serve no purpose to skin’s wellbeing like synthetic thickeners, colors, fragrance, and other texture modifiers. His search was unsuccessful, so Skinega was developed over a two-year period, then formally established in 2017.


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