What do we mean when we talk about animal testing and REACH
If you are a company manufacturing or importing chemicals into Europe, under the REACH legislation you have new responsibilities.
You must register each of your ingredients with the REACH authority, which is called the European Chemicals Agency, who have their headquarters in Helsinki.
Whether it’s an old fashioned ingredient used for generations, or a brand new ingredient you’re currently inventing
all must be registered and a series of safety data about that material supplied.
So let’s take a completely imaginary example to show how it works.
So for example you are a manufacturer of Vanillin, which is the artificial vanilla that we are all used to tasting in lots of our foods and smelling in perfumes every day.
You have to register with the Agency and say you are a vanillin manufacturer.
The Agency then sees how many companies have registered that ingredient and organises them into a group called a SIEF.
This stands for Substance Information Exchange Forum.
On your Vanillin SIEF there might be huge companies, some of them might be smaller,
one might even be even be a completely animal testing free company who already sell to Lush.
This group is then responsible for supplying a dossier of all the safety data that the REACH legislation requires for that ingredient.
You are expected to pool all the data that you all have and make sure you have everything needed for the dossier.
If you find there are gaps in the data, together you are expected to fill these gaps.
So let’s say for Vanillin no one on your SIEF has data for maybe
Температура плавления
Melting Temperature
Flashpoint or Flammability
Eye Irritation
So together now you have to decide how to find that data elsewhere,
if you couldn’t find it elsewhere how are you going to test for those things.
If you are going to test who is going to pay for it and who is going to do the testing for the group.
It could be that all of you pay a little bit towards it, it could be that one of the companies agrees to do the testing and bear the costs
but each SIEF will discuss that and debate it and come up with their own arrangements.
So you can get the Melting Temperature tests done in a laboratory in test tubes. Same with Flash Point and Flammability.
But Eye Irritation data, that’s a little more tricky.
That could very likely lead to having to test on animals, because there is currently no complete alternative available.
So your SIEF would have to apply to the European Chemical Agency, telling them that you need to conduct animal tests to complete the dossier.
That’s is why Lush is worried about REACH.
Our suppliers might end up on a SIEF that has to animal test.
Because of our strict animal testing policy, all of Lush’s suppliers over the years have been completely free of animal testing.
Our policy says we wont buy from any supplier, who tests any ingredient for any reason on animals.
REACH means that our suppliers who were previously committed to no animal testing
could suddenly find themselves required by law to be party to testing via their SIEF in order to complete their dossier.
And that makes us weep.
To be honest, after 17 years of running a cruelty free business, It makes us angry.
Laws should exist to guide people to do the right thing, not force them to do something so very, very wrong.
Lush will never be comfortable with the REACH legislation
until all animal testing is removed from it.