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Product Testing: Toxic and Tragic

Every year, millions of animals are poisoned and killed in barbaric tests that were crudely developed as long ago as the 1920s to evaluate the toxicity of consumer products and their ingredients. Rats, mice, guinea pigs, rabbits, and other animals are forced to swallow or inhale massive quantities of a test substance or endure the pain of having a chemical eat away at their sensitive eyes and skin––even though the results of animal tests are often unreliable or not applicable to humans. 

Acute Toxicity Tests
To determine the toxic consequences of a single, short-term exposure to a product or chemical, the substance is administered to animals (usually rodents) in extremely high doses via force-feeding, forced inhalation, and/or absorption through the skin. Animals in the highest-dose groups may endure severe abdominal pain, diarrhea, convulsions, seizures, paralysis, and bleeding from the nose, mouth, and genitals before they ultimately die.1

Acute toxicity testing began during the World War I era with the now-infamous lethal dose 50 percent (LD50) test, which, even today, remains the most common form of animal-poisoning study. In this test, groups of animals are force-fed increasing amounts of a substance until 50 percent of them die.

Despite its decades of use, the LD50 test and its more contemporary adaptations have never been scientifically validated to confirm that their results are indeed predictive of chemical effects in humans. One international study that examined the results of rat and mouse LD50 tests for 50 chemicals found that these tests were able to predict toxicity in humans with only 65 percent accuracy––while a series of human cell-line tests was found to predict toxicity in humans with about 75 percent accuracy.2   

Eye- and Skin-Irritation/Corrosion Tests
The Draize eye- and skin-irritation/corrosion test dates back to the 1940s.3 During this test, rabbits are often immobilized in full-body restraints while a substance is dripped into their eyes or smeared onto their shaved skin. Laboratory technicians then record the damage, which can include inflamed skin, ulcers, bleeding, bloody scabs, swollen eyelids, irritated and cloudy eyes, or even blindness, at specific intervals for hours or days.

The scoring of eye and skin damage in the Draize test is highly subjective, and therefore, different laboratories—and even different tests within the same laboratory—often yield different results. In addition, rabbits’ eyes are anatomically and physiologically different from and tend to have stronger reactions to chemicals than humans’ eyes. In contrast, a clinical skin patch test conducted on human volunteers has been shown to produce skin-irritation data that are “inherently superior to that given by a surrogate model, such as the rabbit.”4  

Product Tests
No law requires that cosmetics and household products be tested on animals. The U.S. Food and Drug Administration (FDA) advises cosmetics manufacturers “to employ whatever testing is appropriate and effective for substantiating the safety of their products” and notes that the Federal Food, Drug, and Cosmetic Act “does not specifically require the use of animals in testing cosmetics for safety.”5 Likewise, household products regulated by the Consumer Product Safety Commission (CPSC) do not have to be tested on animals. The CPSC’s animal testing policy, as published in the Federal Register, states, “Neither the FHSA nor the Commission’s regulations requires animal testing. The FHSA and its implementing regulations only require that a product be labeled to reflect the hazards associated with that product.”6  

Tests That Are Required by Law
By contrast, lawn fertilizers, weedkillers, and household cleaners that make “germ-killing” or “antibacterial” claims on their labels are regulated as pesticides by the Environmental Protection Agency.7 By law, every pesticide must undergo dozens of separate animal tests before it can be marketed, which spells suffering and death for many animals.8 The FDA has similar testing requirements for drugs as well as chemicals that are used as additives or preservatives in processed foods.9,10 

Alternatives to Animal Tests
Today, hundreds of cosmetics and household-product companies have turned their backs on animal testing and begun taking advantage of the many sophisticated non-animal testing methods available today, which range from cell and tissue cultures to computerized “structure-activity relationship” models.

For example, human-skin equivalent tests such as EpiDerm™ and EpiSkin™ have been validated and accepted in Canada, the European Union, and virtually all other member countries of the Organization for Economic Co-operation and Development as total replacements for animal-based skin-corrosion studies. These methods consist of normal, human-derived skin cells that have been cultured to form a multilayered model of human skin.

The 3T3 Neutral Red Uptake Phototoxicity Test was developed and validated in Europe and has since been accepted at the international level as a total replacement for animal-based phototoxicity studies. In this test, cells from the 3T3 cell line are exposed to a test chemical in the presence and absence of light. Photocytotoxicity is evaluated by the relative reduction in viability of cells exposed to the chemical in the presence vs. absence of light, where cell viability is measured by the degree to which they are able to absorb neutral red dye.

PETA is urging U.S. regulatory agencies to accept these and other valid non-animal testing methods as part of its “Give the Animals 5” campaign. Where validated non-animal replacements are not yet available or fully validated, PETA lobbies companies and the government to provide the necessary funding for research and development and works closely with organizations that specialize in test-method validation, such as the European Union Reference Laboratory for Alternatives to Animal Testing and the Institute for In Vitro Sciences, to bring new non-animal testing methods into the mainstream.

The Way Forward
As of March 2013, the European Union has banned the sale of any cosmetics or cosmetics ingredients that have been tested on animals.11 This marketing ban means that companies all around the world will have to abandon animal testing for cosmetics that they want to sell in the EU. Both Israel and India have banned cosmetics testing on animals, and Israel has also followed the EU’s lead regarding imported goods.12,13 Meanwhile, China is considering an end to mandatory testing on animals for cosmetics.14

What You Can Do
Compassionate consumers who boycott products that have been tested on animals play a vital role in pushing companies and government agencies to adopt more relevant and humane non-animal testing methods. To help consumers identify products that are cruelty-free, PETA’s Beauty Without Bunnies program clarifies non-animal testing terminology and procedures, compiles information on the testing policies of companies, and publishes a list of companies that have signed our statement of assurance to confirm that they do not conduct or commission animal tests of their products, ingredients, or formulations. Shoppers can support this project by purchasing products that comply with PETA’s “cruelty-free company” standard, boycotting those that don’t, and asking local stores to carry cruelty-free items.

Consult PETA’s database of companies that don’t test on animals and request a free copy of PETA’s global Cruelty-Free Shopping Guide to find cruelty-free versions of all kinds of products.

1Organisation for Economic Co-Operation and Development, “Guidance Document on the Recognition, Assessment, and Use of Clinical Signs as Humane Endpoints for Experimental Animals Used in Safety Evaluation,” OECD Environmental Health and Safety Publications, Series on Testing and Assessment, Nov. 2000.
2B. Ekwall, “Overview of the Final MEIC Results: II. The In Vitro–In Vivo Evaluation, Including the Selection of a Practical Battery of Cell Tests for Prediction of Acute Lethal Blood Concentrations in Humans,” Toxicology in Vitro, 13 (1999): 665-73.
3M.K. Robinson et al., “Non-Animal Testing Strategies for Assessment of the Skin Corrosion and Skin Irritation Potential of Ingredients and Finished Products,” Food and Chemical Toxicology, 40 (2002): 573-92.
4M.K. Robinson et al., “Validity and Ethics of the Human 4-h Patch Test as an Alternative Method to Assess Acute Skin Irritation Potential,” Contact Dermatitis, 45 (2001): 1-12.
5U.S. Food and Drug Administration, “Animal Testing and Cosmetics,” Office of Cosmetics and Colors Factsheet, U.S. Department of Health and Human Services, 5 April 2006.
6“Codification of Animal Testing Policy,” Consumer Product Safety Commission, 10 Dec. 2012.
7U.S. Environmental Protection Agency, “About Pesticides,” 9 May 2012.
8U.S. Environmental Protection Agency, “Protecting the Public From Pesticide Residues in Food,” Pesticides: Topical & Chemical Fact Sheets, 9 May 2012.
9Graham Lawton, “The Quest for Valid Alternatives,” Chemistry & Industry, 19 May 1997.
10National Library of Medicine, “Toxicology Tutor I: Basic Principles,” National Institutes of Health, 21 April 2005.
11James Kanter, “E.U. Bans Cosmetics With Animal-Tested Ingredients,” The New York Times 11 Mar. 2013.
12Gabe Fisher, “Import Ban on Animal-Tested Products Goes Into Effect,” The Times of Israel 1 Jan. 2013.
13Aarti Dhar, “India Bans Testing of Cosmetics on Animals,” The Hindu 29 June 2013.
14Zhang Dayu, “China Considers End to Mandatory Animal Testing on Cosmetics,” CNN 15 Nov. 2013.

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