Personal Care Magazine recently published this article in which we examined some of the current challenges in animal-free ecotoxicity testing.

Recent clarification of the EU REACH legislation highlighted that some environmental assessments are exempt from the obligation to use non-animal testing methods. Which got us thinking about how we can reduce the number of animals used in ecotoxicity testing and asking whether the ethical considerations for this type of testing are even the same? For instance, is it reasonable to use fish to assess the environmental impact of a sun screen when the person wearing it is in the sea? Can the cosmetics industry take a lead in this discipline, when progress has traditionally been made by the agrochemical and biocide sectors?


Should environmental testing on earthworms pose a dilemma for the cosmetic industry? Image courtesy of KJ Muddiman

In the article, we consider the lack of legal definition of animal products which can be used in scientific testing, and how animals tend to be defined within the categories of vertebrates or ‘higher sentient’ organisms. We argue that this matters both for vegan products, and also for invertebrates, whose importance in the wider ecosystem is now far better understood.

What animal-free technologies are available?

So if we agree that animal-free alternatives are desirable for ecotoxicity testing, what are the latest technologies available to companies wanting to adopt these strategies? Building on the foundations of cellular assessment for human safety, a fish acute toxicity model using a trout gill cell line has been developed. We debate what organisations could gain or lose using a cell line test vs the existing Fish Embryo Test (FET).

It was interesting to learn that in December 2019, ECHA announced that they were starting work on guidance for assessing risk to bees and other pollinators such as ladybirds. Can we see a future where cosmetic consumers learn how their favourite products might impact on these much loved insects and demand their protection, whilst also expecting that products and ingredients are not tested on them? What an opportunity for the cosmetic and personal care industry to get ahead of the curve.

If we’ve got you thinking about this fascinating topic, feel free to download and share the article with your colleagues and as ever, drop us a line at if you’d like to ask us a question.

Ecotoxicology-article-in-Personal-Care-Jan-2021.pdf (307 downloads )