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Oppose the Safe Cosmetics and
Personal Care Products Act

The Safe Cosmetics and Personal Care Products Act (SCPCPA), H.R. 1385, requires the registration and toxicity testing of all cosmetic ingredients, old and new. A recent article, Safety Evaluations under the Proposed US Safe Cosmetics and Personal Care Products Act of 2013: Animal Use and Cost Estimates, in the peer-reviewed journal ALTEX, studies the language of this federal legislation to project the amount of animal testing that the law would require.

    Summary of Findings (click here to read the full text of the article)

  • Animal testing would surge. One million to 11.5 million animals would be subject to testing in the first 10 years under the SCPCPA.1 By comparison, the article estimates that currently, 27,000 animals are used in cosmetic ingredient testing worldwide annually, or 270,000 animals over the same 10-year period.2

  • Costs to businesses would be tremendous. Under the SCPCPA, cosmetic manufacturers and ingredient suppliers would likely pay $1.7 - $9 billion in 10 years to perform animal tests on cosmetic ingredients.3 Current estimates suggest that cosmetic ingredient testing costs $54 million annually or $540 million worldwide over 10 years.4

  • Regulators would be overwhelmed with implementation. The SCPCPA requires new regulatory functions for the Food and Drug Administration (FDA) to create priority lists for ingredient testing as well as oversee pre-market evaluation of new ingredients. By year 10, that would involve an estimated 18,800 cosmetic ingredients in use in the United States.5 However, the legislation would only mandate that 1,200 ingredients undergo evaluations over 10 years in additional to any premarket testing for new ingredients. Even under optimal conditions, the number of ingredients to receive evaluations would be 10,000, a little over half of ingredients likely in use in 10 years.

  • For consumer safety, the priority should be the development and use of alternatives. Animal based toxicity tests are expensive and time-consuming. As the National Research Council concluded in its 2007 report, Toxicity Testing in the 21st Century, a Vision and a Strategy, the future of safety testing depends on the creation of high-throughput screening tests that enable the rapid evaluation of many ingredients. If more resources are consumed using animal tests, less are available for the development of the alternatives that will ultimately save time, money, and animal lives.

    Additional Considerations

  • Using animals to test cosmetics is unjustified cruelty. The public made the decision decades ago that using animals to test products like shampoo and eye shadow is not acceptable. Consumers demanded change, and industry and regulators focused resources on the development of non-animal alternative test methods instead. By requiring a massive new testing scheme for cosmetic ingredients without the availability of alternatives for all the newly required tests, we are taking a major step backward.

  • United States companies will be at a disadvantage. In 2004, the European Union banned animal testing for cosmetic products and now bans the sale of cosmetic products with ingredients tested on animals. Israel and India followed suit in 2007 and 2013 respectively. Even China has recently announced plans to phase out mandatory animal testing for cosmetic products.

  • Non-animal alternative test methods are better for companies, consumers, and animals. Not only are animal tests expensive and time-consuming, but the results of animal studies offer questionable information about human safety. Alternatives provide data relevant to humans. Concerns about the safety of cosmetic ingredients should be addressed by looking at the best way to obtain safety data in a timely, cost-effective manner while also preventing the unnecessary suffering of millions of animals.

1. Due to uncertainty about the exact tests that will be required by the Food and Drug Administration, the authors detail four different testing scenarios that would affect the number of animals and money needed to complete the tests.
2. These figures are based on the introduction of 500-700 new chemicals, the number of new cosmetic ingredients developed worldwide each year. Because the SCPCPA requirements would affect ingredient companies worldwide, the authors used this number as a basis for comparison.
3. See Note 1.
4. See Note 2.
5. The number of ingredients in use in 10 years was formulated by taking the total number of cosmetic ingredients available in 2013 (20,800) and adding 500-700 each year. The authors then estimated conservatively that 70% of those ingredients would be in use during the 10-year period.

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