On 25 July 2023, the EU Commission published its response to the European Citizens’ Initiative’s petition on “Save Cruelty-free Cosmetics – Commit to a Europe without Animal Testing”.   The petition received 1.2 million signatures from EU citizens and the EU Commission must respond to petitions gathering 1 million signatures or more.

The EU Commission has confirmed the following in response to the requests of the petition:

Protect and strengthen the cosmetics animal testing ban

  • The EU Cosmetic Products Regulation already prohibits the placing on the market of cosmetic products tested on animals and action will be taken to continue to apply and enforce this ban.
  • The ban currently does not apply to safety tests required to assess risks from chemicals to the environment and workers under the EU Registration, Evaluation, Authorisation, and Restriction of Chemicals Regulation (REACH). The Commission has confirmed that it will consider the need for legislative changes to further clarify the interface between the cosmetics and REACH regimes depending on the outcome of ongoing judicial review proceeding considering this point.

Transform EU chemicals legislation

  • Work will commence on a roadmap with the aim of ultimately phasing out animal testing for chemical safety assessment.  The roadmap will consist of legislative and non-legislative actions aimed at reducing animal testing in the short-term before eventually moving the EU towards an entirely animal-free regulatory regime under relevant chemicals legislation (e.g. REACH, Biocidal Products Regulation, Plant Protection Products Regulation and human and veterinary medicines).

Modernise science in the EU

  • The Commission has proposed a set of action points to accelerate the reduction of animal testing in research, education and training, including activities that will increase cooperation with Member States.
  • The Commission notes that it has already spent approximately €1 billion in the past 20 years on creating alternatives to animal testing and has confirmed that it will continue to support research on alternatives to animal testing with substantial funding. 

For further information please contact Rachel MacLeod, Elina Angeloudi, Jaspreet Takhar or Julia Gillert.


Rachel MacLeod is a senior associate in Baker McKenzie's London office.


Elina Angeloudi is an associate at Baker McKenzie's London office and specialises in regulatory advice to pharmaceutical and medical devices companies.


Jaspreet Takhar is a senior associate in Baker McKenzie' London office and advises market-leading tech and healthcare companies on issues at the cutting-edge of digital health.


Julia Gillert is Of Counsel at Baker McKenzie's London office, and has shaped her practice to focus exclusively on regulatory matters affecting the Healthcare & Life Sciences industry.