Is “Cruelty free claim” Allowed in the EU?!

What the regulation says


Article 20 of the EU regulation 1223, 2009 explains the important criteria to make an acceptable claim in the EU. This regulation is in place since 2013. In 2017, the working group on cosmetic products published a technical guideline documents, which was applicable from 1st July 2019. The technical guideline provides tools that clarify 6 important common criteria explained in the article 20:

  1. evidential support
  2. honesty
  3. fairness
  4. truthful
  5. legal compliance
  6. informed decision making


When did it all start?


Animal testing was banned in the EU for cosmetic products in 2004 and for cosmetic ingredients in 2009. This published guideline strictly banns claims such as Cruelty free /or not tested on animal. The reasoning behind this ban is based on the fact that the animal testing not permitted for any cosmetic product or ingredient placed on the market. Hence, based on the technical guideline it would be against the principle of truthful criteria.


Not tested on animal or Cruelty free claim can be considered as misleading to consumers, since none of the products being placed on the market are allowed to be tested on animals.


Some European authorities like Germany and Denmark are taking enforcement action on this claim with fines. On the other hand, in the EU, the authorities seem to have a more relaxed approach on this claim. Advertising Standard Agency (ASA) evaluate the technical in accordance with regulation in the EU.


Do you need guidance?


If you are against the animal testing principle and want to know what type of claims you can have, please get in touch with us. Our experts are happy to help you with copywriting and supports on legal and compliance of your claims.

If you wish to discuss this matter with PCR, please contact us.