China To End Mandatory Pre-Market Animal Testing in 2021

China is still one of the biggest countries that does mandatory animal testing on Cosmetics sold in China. Lately, there has been a possible indication from China towards ending the mandatory animal testing for Imported “Ordinary” cosmetics.

On Jul 3rd, 2020, Humane Society International and other sources like wwd, plantbasednews, Crueltyfreekitty stated, China will finally remove mandatory Pre-market animal testing for imported “ordinary” cosmetics sold in China. This is HUGE for the Cruelty free Community!

“Effective Jan. 1, 2021, imported ordinary cosmetics such as shampoo, blusher, mascara and perfume will no longer have to be animal tested for eye and skin irritation in Chinese laboratories”.


To make it easier for you to understand, I broke this into multiple sections with definitions and clear explanation of what these laws really mean.

Types of Cosmetics:

All cosmetics and beauty products fall into two categories.

  1. Ordinary Cosmetics: Ordinary or Non-Special Use Cosmetics include products for everyday use like hair care, nail care, skin care, perfumes, makeup etc.
  2. “Special Use” Cosmetics: Special-Use Cosmetics include products that make functional claims like hair growth, hair dye, hair perm, hair removal, breast shaping, fitness, deodorizing, spot removal, whitening and sun block.

Pre-Market Vs. Post-Market Animal Testing:

Simply put, China tests on animals at two stages: pre-market and post-market. Let’s review what these terms really mean.

  • Pre-Market Animal Testing: Tests done on products  in order to be proven “safe” for consumers before they hit the market.
  • Post-Market Animal Testing: Tests done after products hit the market. Products can be chosen at random and removed from shelves for “confirmatory” animal testing to ensure that the product on sale to customers is same as formulation approved for sale.

Breakdown of China’s Animal Testing Laws:

Now let’s take a look at the China’s Current animal testing laws Vs. what will be changing effective Jan 1st, 2021.

  • Foreign imported ordinary cosmeticsstill require animal testing
    • (NEW) There will NOT be any mandatory Pre-market Animal Testing on Ordinary Cosmetics.
    • But keep in mind, these products can still be subjected to Post-market animal testing incase of customer complaints or product recalls.
  • Domestically produced Ordinary1 cosmetics – animal testing no longer an absolute requirement [NO CHANGE]
  • Both foreign imported and domestically produced ‘Special Use’2 cosmetics – still require animal testing [NO CHANGE]
    • This includes both mandatory Pre-market and Post-market (products taken off of shelves) testing.
  • Domestically produced ordinary cosmetics for foreign export only – have never required animal testing [NO CHANGE]
  • Any cosmetic bought in China via a foreign e-commerce website – has never required animal testing. [NO CHANGE]

Detailed View:

Below is a detailed view of China’s Animal Testing Laws [Current Vs. Effective Jan 1st 2021]

China’s Animal Testing Laws – Current

China’s Animal Testing Laws – 2021

What does this mean?

Now, lets try to understand what this new change in China’s animal testing law really means.

As mentioned above, animal testing can be performed at two stages: pre-market and post-market.

Currently, pre-market animal testing is mandatory for all imported cosmetics ie, if an international skincare brand like Aveeno, Neutrogena, MAC, Estee Lauder etc. decide to sell their products in stores in Mainland China, they MUST have their products tested on animals beforehand.

With this new change which will take effect starting Jan 1st, 2021, brands will be able to start selling in China without the need for mandatory “Pre-Market” animal testing as long as they sell Ordinary1 cosmetics. However, if these brands carry any Special Use2 cosmetics like sunscreen, hair growth products etc., then the brand will still fund and pay for animal testing before they enter the China Market.


Simple answer is NO. They won’t be truly 100% Cruelty free even with the new change. Read below to understand why.

Even though, brands carrying Ordinary1 cosmetics can by pass pre-market animal testing, there is still a high risk of products being subjected to post-market testing on animals.

Humane Society International article also mentions:

“The regulation also provides for routine post-market sampling inspections by provincial authorities, including for cosmetics with reported safety problems. It is unclear whether such inspections and investigations could involve animal testing. This uncertainty has long been a barrier to cruelty-free beauty brands entering the Chinese market.”

Currently, we know that most post-market testing on products involves testing on animals. However, based on the above statement from HSI.Org, this regulation provides for a routine post-market sampling inspections, this means the number of post markets tests in general will increase in number.

It is still unclear whether the new routine post-market sampling inspections mentioned involves animal testing. I really hope it doesn’t. But if it does, then this will not really reduce the number of animals being used in animal testing.


Even with this change, brands selling in China will still NOT be truly Cruelty-free. But, China is one of the few countries in the world that requires mandatory animal tests for cosmetics, so removing this requirement atleast for everyday cosmetics is definitely a step in the right direction. And a lot of animals will be saved from the inhumane animal testing practices.

**There are still tons of Cruelty free brands options including some high end beauty brands listed here. You can now pick from 500+ Cruelty free brands that are vettes and #EthicalPixieApproved.

Please let me know if you have any further questions in the comments below.

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6 thoughts on “China To End Mandatory Pre-Market Animal Testing in 2021

    1. That’s a great question. Most toothpaste would fall under the Ordinary category. I am not 100% sure about the whitening strips/toothpaste etc. as they technically make functional claims. Will look into it further.

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