China’s animal testing laws can be a bit confusing, so I broke it down to help you better understand their requirements.  Animal testing is required by law in China for all foreign cosmetics companies. This means that all the big-name American and European cosmetics brands that are currently sold in China, are required to undergo animal testing. If a cosmetic company sells their products in China, they are not truly 100% cruelty-free. To be cruelty-free these are the stipulations brands must follow:

•  No animal testing conducted by their company on any finished product or ingredient.
•  No animal testing conducted by their suppliers.
•  No animal testing conducted by third parties on behalf of the company.
•  No animal testing where required by law.

If this gets too wordy for you, you can jump down to my infographic at the end of this post!

Photo by Gustavo Zambelli on Unsplash

Most “green” cosmetics companies do not test on animals. This includes selling to China where it’s a legal requirement. When you think of a “green” beauty brand you expect either organic, natural, or wild crafted ingredients in conjunction with being paraben-free, petrochemical-free, fragrance-free AND free from animal testing. Whenever I reach out to cosmetics brands to make sure they fit my values, I always ask – “do you sell in China, and if so, have you found a way to bypass China’s animal-testing laws.”

There are loopholes

EXAMPLE, 100% Pure

100% Pure started selling in China, however they found a loop hole. Rather than basing their shipping facilities in China (like other cosmetic brands) they are sending their product direct to their China customer’s home via a third party logistics partner based in Portland. This innovative work-around allows them to sell to their Chinese fans without abiding by China’s mandatory law to test on animals. All cosmetics that are sold off shelves in retail stores in China are required to test on animals. Furthermore, all retail products are subject to random “post market inspections” via animal testing, with or without the consent of the company. There is absolutely no way around this law when selling products on Chinese soil. Therefore 100% is not opening a physical store in China and will only be selling through their third party global distribution website:


China is the world’s largest consumer market. Last year, China’s cosmetic market was worth over 26 billion dollars (according to Euromonitor).  Thus, it has become a lucrative market for many American & European cosmetics brands.

Popular Brands That Sell in China
(NOT that I wouldn’t recommend these anyway because they contain harmful ingredients 🙅)
Dior  •  MAC  •  Maybelline  •  Neutrogena  •  Clinique  •  Chanel  •  Estee Lauder  •  Covergirl  •  Mary Kay  •  Garnier  •  Avon  •  L’Oriel  •  Origins  •  Benefit  •  OPI  •  Stila  •  Victoria’s Secret  •  Nars  •  Almay  •  Bobbi Brown  •  Tom Ford  •  Yves Saint Laurent  •  Sephora Collection  •  Giorgrio Armani  •  Burberry  •  Makeup Forever  •  Revlon  •  Rimmel London

Companies are sneaky and can state that they do not engage in animal testing, but insert language that indicates exceptions. For instance, Estee Lauder states on their website it “does not test on animals and we never ask others to do so on our behalf,” but “if a regulatory body demands it for its safety or regulatory assessment, an exception can be made.”


On June 30th 2014, China lifted the animal testing requirement for cosmetics manufactured within the country. Cosmetics manufactured outside of China are still subject to compulsory animal testing in government labs before regulators can approve products for sale in the country.

•  Foreign imported ‘ordinary cosmetics’ require animal testing.
•  Domestically produced ‘ordinary cosmetics’ are no longer required to be tested on animals.
•  Both foreign imported and domestically produced ‘special use’ cosmetics require animal testing.
•  Domestically produced ‘ordinary cosmetics’ for foreign export only do NOT require animal testing.
•  Cosmetics bought in China via a foreign e-commerce website do NOT require animal testing.

Ordinary Cosmetics – makeup, fragrances, skin, hair, and nail care products. The tests include eye irritation, acute skin irritation, and repeat skin irritation.
Special Use Cosmetics – hair dyes, perms & hair growth products, deodorants, sunscreens, skin-whitening creams, slimming creams, and other products that make a functional claim on the label.
Both foreign imported and domestically produced ‘special-use’ cosmetics are subject to testing for all finished products.


Pre- and post-market testing requirements do not apply to cosmetics ordered by customers via an e- commerce website if the website and fulfilment is outside of mainland China, and products posted direct to the customer in China.

Selling in Chinese Airports

Cosmetics sold as duty-free in China’s airports still risk being subject to random post-market animal testing by the Chinese government.  This means that cruelty-free companies cannot sell in Chinese airports and guarantee that their products will never be animal tested, with or without their knowledge.

There is some change happening…

Last year, the government moved to accept safety data collected through a non-animal test method called the 3T3 phototoxicity assay. This measures the safety of a chemical after exposure to light. The government hasn’t said if this test is yet in use. Also, in some provinces, companies domestically manufacturing ordinary products, like lotion and soap, can now apply to waive the animal testing requirements. But experts say China’s murky regulatory environment is difficult to navigate and getting those approvals can be spotty.


  • Imported products can continue to be direct mailed by foreign companies to consumers in the Chinese mainland for personal use with no animal testing requirement.
  • Imported products can be sent to Hong Kong by foreign companies, then an agent there can direct mail to consumers in the Chinese mainland for personal use, with no animal testing requirement.
  • Hong Kong still has no mandatory animal testing regulations for e-commerce or retail.
    The animal testing law does not apply to cosmetics sold in Hong Kong only in mainland China.


There are alternatives to animal testing! Companies can choose from thousands of established ingredients or use proven non-animal tests. For instance, artificial tissue testing has proved better in predicting skin irritation in people than testing on animals. Another one, the test tube method can distinguish toxic from non-toxic cosmetic ingredients. Modern Science can replace animal testing and use tools that are kinder, better, and faster!


Sources: Choose Cruelty Free, Humane Society International, PETA