Leaping Bunny

Leaping Bunny Program

Leaping Bunny China Qualification Program

Indicates required field

Checklist

The Coalition for Consumer Information on Cosmetics’ Leaping Bunny Program understands that the process for a personal care or cosmetics company wishing to register and file to sell in Mainland China without animal testing is very complex. As a service to our certified companies, we have launched the Leaping Bunny China Qualification Program.

The first step for companies is to complete the checklist below, which can be used to see if your brands may be a good fit for entry into China while remaining Leaping Bunny certified. The checklist includes some of the major challenges that companies will face during the registration process and some of our requirements to ensure that animal testing does not occur.

Indicates required field

The following has been prepared in consultation with experts but is not to be considered legal advice.

Proof of valid trademark registration is a requirement for product registration, import, export, and distribution in many channels in China and at least the (English) trademark certificate must be done before the registration and filing process begins. Is your trademark already registered in China or would you be prepared to register your trademark in China?
Registration of special use cosmetics including but not limited to sunscreen and whitening agents as well as products for babies, children, and expectant and/or breastfeeding mothers still require animal testing in China. Are you planning on registering any of these products?
Certain efficacy claims such as anti-blue light, anti-pollution, or anti-perspirant require animal testing during registration to be substantiated. Will you have efficacy claims associated with your products?
Ingredients not on China’s list of accepted ingredients will be required to undergo animal testing during registration. Do your products contain any ingredients not currently on China’s list of accepted ingredients?
Suppliers need to declare all ingredients/raw materials in the NMPA database in China prior to a company submitting its registration dossier. Have your ingredient suppliers completed this step and received a code?
A local legal entity is required for registration in China. Would you be willing to establish a such an entity in China or authorize a local third-party entity that can act as a ‘responsible person’ on your behalf?
In order to be exempt from animal testing for general cosmetics, the manufacturer is required to obtain a Certificate of Good Manufacturing Practice (GMP certificate) issued by the local government authorities. Has your manufacturer(s) obtained a GMP certificate from the local authorities?
An alternative route into China that may avoid animal testing is by domestic manufacturing and/or filling of General Use products inside China. Would you have the capacity to manufacture and/or bulk fill your products in China?
Companies that have already registered their products to sell in the EU where the reporting burden, while still extensive, is significantly less than in China will be better prepared to meet China’s stringent requirements. Is your company currently registered to sell products in the European Union?
No matter the path into China, in order to continue to qualify for Leaping Bunny certification, a company that registers products must undergo both pre-market and post-market audits at the company’s expense for a pre-determined number of years to ensure that animal testing has not been conducted. Would your company be prepared to submit to and pay for a one-time pre-market audit for each product registration and a yearly post-market audit for a fixed period of time?
If it is determined that one or more of your products is causing adverse effects, Chinese authorities may require you to engage in post-market animal testing to determine the cause. If this happens, we would require companies to issue a product recall instead of submitting the product(s) in question to animal testing. Would you be willing to recall any problematic products if this situation arises instead of animal testing?

Based on your answers above, it does not appear that your company would currently be able to avoid the animal testing requirement in China. Please fill out the form below so that we may keep you updated on any changes to Chinese regulations which may affect you. Thank you for your interest! 

 

Based on your answers above, your company may be able to avoid the animal testing requirement in China. Please fill out the form below so that we may keep you updated on the Leaping Bunny China Qualification Program when it launches. Thank you for your interest!

 

Please input url that starts with https:// or http://