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Vegan and cruelty-free skincare claims: the rules in the EU, UK and US

Vegan has no legal definition for cosmetics, and cruelty-free means different things in Brussels, London and California. Here is what the law says in each, and how brands back up the claim.

By the KoreanOEM team · · 7 min read

Formulators at work in the lab

Vegan and cruelty-free are marketing claims, not legal categories, in most markets. The EU and the UK ban animal testing for cosmetics and allow a "not tested on animals" claim only when no animal tests were done or commissioned for the product or its ingredients. The US has no federal definition, but twelve states ban the sale of cosmetics developed with new animal tests.

Here is what each market requires, where the traps are, and how brands document the claims. Rules as of September 2026.

Vegan and cruelty-free are different claims

Vegan is about ingredients: nothing of animal origin in the formula. Common animal-derived cosmetic ingredients include beeswax, honey, lanolin from sheep's wool, carmine from insects, and snail secretion filtrate, the snail mucin used in some Korean serums.

Cruelty-free is about testing: no animal tests on the finished product or its ingredients. A product can be one without the other. A snail mucin serum can be made without any animal testing and still not be vegan, and a fully plant-based formula is not cruelty-free if an ingredient was tested on animals for it.

Because the claims differ, the evidence differs too. Vegan needs ingredient and processing information; cruelty-free needs testing information from every supplier.

EU rules: a ban on testing and on selling tested products

The EU Cosmetics Regulation (EC) No 1223/2009 bans animal testing in two ways. The testing ban covers finished products since 11 September 2004 and ingredients since 11 March 2009. The marketing ban stops products and ingredients tested on animals from being sold in the EU; it has applied since 11 March 2009, and since 11 March 2013 also to the last three health effects that had been exempt: repeated-dose toxicity, reproductive toxicity and toxicokinetics.

Claims have their own rule. Under Article 20(3), a brand may say no animal tests were carried out only if the manufacturer and its suppliers have not carried out or commissioned any animal tests on the finished product, its prototype or any ingredient, and have not used ingredients tested on animals by others to develop new cosmetics.

Every cosmetic claim in the EU must also meet the six common criteria in Regulation (EU) No 655/2013: legal compliance, truthfulness, evidential support, honesty, fairness and informed decision-making. One point matters here: a claim may not present mere compliance with a legal requirement as a special benefit. Since every cosmetic sold in the EU is covered by the testing ban, write animal testing claims carefully.

The REACH gapThe cosmetics ban is not the only EU law that touches ingredients. In November 2023 the EU General Court upheld demands from the EU chemicals agency for animal tests on two UV filters used only in cosmetics, for worker safety under the chemicals law REACH.

The EU has no legal definition of vegan for cosmetics. A vegan claim is judged like any other claim: it must be true and backed by evidence.

UK rules after Brexit

Great Britain kept the EU rules in its own version of the Cosmetics Regulation. Article 18 bars placing a product on the market where the final formulation or its ingredients were tested on animals to meet the Regulation, and bans such testing in the UK. Historic animal testing data may still be used. The Article 20(3) claim condition is the same as in the EU.

In May 2023 the UK government also announced that no new licences would be granted for animal testing of chemicals intended only for use as cosmetic ingredients. For a UK launch you also need a UK Responsible Person and an SCPN notification; our guide to starting a skincare brand in the UK covers those steps.

US rules: no federal definition, state bans

FDA says there are no legal definitions for "cruelty-free" or "not tested on animals". It also notes that some companies apply those claims only to the finished product while relying on suppliers or contract labs for any animal testing of ingredients. Under MoCRA, brands must keep records that support product safety, and FDA states that animal testing is not a requirement for marketing a cosmetic.

The states have gone further. California's law, in force since January 1, 2020, makes it unlawful for a manufacturer to sell a cosmetic developed or manufactured using an animal test conducted or contracted by the manufacturer or any supplier on or after that date. "Manufacturer" means the company named on the label, which is usually the brand, and the law has exceptions, for example for some tests a regulator requires.

States with a sales banSource
California, Hawaii, Illinois, Louisiana, Maine, Maryland, Nevada, New Jersey, New York, Oregon, VirginiaConnecticut legislative research report, August 2023
Washington, from January 1, 2025Revised Code of Washington 69.05.020

Each law has its own start date, exceptions and penalties, so check the ones where you sell. If you sell nationwide, plan for the strictest state you ship to.

How brands back up the claims

Whichever market you sell in, the claim is only as good as the paperwork behind it. A workable file has four parts:

  1. The full INCI list of the finished product. At KoreanOEM you receive it for every product.
  2. A statement from each raw material supplier on animal origin and on animal testing, with dates.
  3. Your own policy: what you claim, which markets it covers, and a rule that new ingredients are checked before use.
  4. Non-animal safety evidence: the safety assessment, stability and challenge tests and human patch tests. Stability, challenge and patch tests are planned into every project with us.

Ask for supplier statements at the sample stage, not after the label is printed. Changing an ingredient after approval restarts part of the work. If a custom formula is part of your plan, see custom skincare formulation for how briefs and sample rounds work.

Certification: Leaping Bunny and the Vegan Trademark

A third-party logo is voluntary, but it replaces "trust us" with an audited standard.

  • Leaping Bunny asks companies to pledge to end animal testing at all stages of product development, to recommit to the program every year and to be open to third-party audits.
  • The Vegan Trademark from The Vegan Society requires that the product's manufacture and development involve no animal products, by-products or derivatives, and no animal testing of any kind, including tests required by law in any territory, by the company or on its behalf. Brands must also minimize cross-contamination from animal substances.

Note the last point of the Vegan Trademark: if a market you plan to sell in requires animal tests for your product, that conflicts with the standard. Your manufacturer and its raw material suppliers provide the ingredient and testing information these programs ask for.

A claims checklist before you print

  • Is every ingredient free of animal-derived material, including processing aids? (vegan)
  • Do you hold a dated statement from every raw material supplier? (both claims)
  • Did you, your manufacturer or any supplier carry out or commission animal tests for this product or its ingredients? (EU and UK Article 20(3))
  • Does the wording avoid presenting a legal requirement as a special benefit? (EU and UK)
  • Which US states will you sell in, and do their laws cover your whole supply chain?
  • If you use a certification logo, is the certification complete and current?

We can prepare the ingredient information and test plan for your market as part of your project. Tell us your claims when you ask for a quote, and read the export guide for the EU, UK and US paperwork.

Frequently asked questions

Is cruelty-free a legal term?
Not in the US, where FDA says "cruelty-free" and "not tested on animals" have no legal definition. In the EU and the UK, a "not tested on animals" claim is allowed only if neither the manufacturer nor its suppliers tested or commissioned tests on the product or its ingredients.
Can I sell animal-tested cosmetics in the EU?
No, not where the product or its ingredients were tested on animals to meet the EU cosmetics rules. The EU marketing ban has applied in full since 11 March 2013.
Which US states ban animal-tested cosmetics?
California, Hawaii, Illinois, Louisiana, Maine, Maryland, Nevada, New Jersey, New York, Oregon and Virginia, according to a 2023 Connecticut legislative research report, and Washington since January 1, 2025. Each law has its own exceptions.
Is snail mucin vegan?
No. Snail secretion filtrate comes from an animal, so a product that contains it cannot be called vegan, even if no animal testing was involved.

Sources

Making your own skincare?Tell us the product, quantity and market. You get a written quote within 1 business day and lab samples in about two weeks.
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