Animal Testing

History of the Lush Non-Animal Testing Policy

Before Lush came to be in 1995, our no animal testing philosophy was already a core value for our founders. It was a driving force in the company that came before Lush, Cosmetics To Go, and was then carried over into Lush as one of its leading policies. It spans across our global business, being cared for by our passionate and dedicated Non Animal Testing Coordinators in the UK, North America, Croatia and Japan.

We oppose animal testing not only because it is a cruel and unfair practice, but also because we believe that animal testing is bad science. Humans are not 70g rats and the testing done on animals cannot be transferred with confidence to a human model. We launched our ground-breaking Non Animal Testing policy in June 1991 and it is now an absolute non-negotiable for our suppliers of both raw materials and packaging. This ensures we only work with businesses that share our own company values. 

This rigorous policy goes above and beyond the call of the European Union (EU) cosmetics animal testing ban because of its supplier specific nature. Not only do we ensure that the ingredients we source from our suppliers are as free of animal testing as possible, but we also make sure that the suppliers themselves are not involved in animal testing for any other sectors or industries. Cosmetic ingredient manufacturers and suppliers often also sell into other industries — for example, pharmaceuticals and animal feed — and we want to make sure we aren’t supporting animal testing in these areas either. 

Our definition of the term ‘animal’ includes all vertebrates and invertebrates, which encompasses animals such as Daphnia, Worms and Fish, often used in safety testing but not usually considered as animals. 

Our definition of ‘testing’ is also extremely broad, comprising any area that we deem to be cruel, such as animal feed trials and testing required for other regulations such as food, pharmaceutical and pesticide testing. This protects our money, and our customers’ money, from being used to fund animal testing by any tier-1 supplier.

The only exception to our policy is testing that is required by EU and UK REACH legislation. REACH (Registration, Evaluation, Authorisation and restriction of Chemicals) started as a European Union legislation that has been put in place for companies to ensure the chemicals they use are safe for the environment and for humans. This came into effect on the 1st June 2007 in the EU and when Britain left the EU on the 31st of January 2020, they created their own — albeit extremely similar — REACH legislation which is still being implemented. Unfortunately these regulations cause some animal testing to become unavoidable if a company wants to trade in the EU and the UK. Although we recognise the unavoidable exception of testing for UK and EU REACH legislation, we are actively campaigning to get animal use out of REACH where alternative, non animal tests can be done to confirm ingredients are safe for use. We continue to encourage suppliers to test for safety using non-animal testing methods and to fund the development of non-animal test methods.

As much as we would love compliance to be simple, and as much as this is a future we are trying to work towards, it’s not. Companies go through acquisitions, legislations change and sometimes, an exciting new product or ingredient can take preference. Because of this, we want to make sure we always stay up to date with our suppliers and so, what better way to track our compliance rates than by conducting an annual review! Every year, we request all our suppliers, globally, to complete our Non Animal Testing (NAT) declaration form to ensure they are still compliant. Our NAT declaration covers a business as a whole, and is not just specific to an ingredient, as we want to make certain that we are not working with a business that conducts animal testing, no matter what department or area it might be in.

We partner with a third party, Ethical Consumer Research Association, to audit our suppliers at random. We first came into contact with Ethical Consumer in July 2013, when we approached them to conduct audits of our supply chain in the UK for compliance with our Non-Animal Testing Policy. Ethical Consumer has since conducted these audits every year. The 2024 annual audit was the 10th report conducted by Ethical Consumer on our NAT Policy. As they are such a vital part of this process, they have complete and open access to our supplier list and purchase history. They also verify our written records from our suppliers to ensure the information we have been given is valid.  

During the annual review, Ethical Consumer will do a one-on-one audit of a number of suppliers at random. In 2024,12 suppliers were chosen between the UK, North America, Croatia, Australia and Japan. In 2025, this will increase to 18. The Commitment to Transparency and External Audits Principle goes more in depth about how the audit is conducted.

So what happens if a supplier changes from compliant to non compliant? We will try our hardest in supporting those suppliers in looking at alternative testing methods, and try to find ways in which they, as a company, can positively change their methods. We want to understand why the testing occurred, if there were approved alternative tests available and if they are willing and able to eliminate the use of animal tests in the future. We have always believed that working with our suppliers, and other third parties, to improve their practices will be a more effective strategy than to cut our losses and turn our backs when we find an issue. We want more companies to learn about the animal cruelty and ineffective science that accompany animal testing and help us take a stand until it is no longer the norm. 

The NAT team works alongside our buyers with a ‘resourcing list’ where the team proactively looks at resourcing materials from a supplier that is compliant with our policies. Resourcing is a vital part in our annual review process. Once a resourcing need is identified, we will add the supplier to our ‘resourcing sheet’ that keeps track of all the suppliers and materials that need to be changed. The buyer attached to that material will then be informed to start looking at the most realistic timeframe in which the change can take place. Some ingredients are harder to resource than others due to their novel status but we always aim to have them resourced as soon as possible. 

Since 2013, when we first started working with Ethical Consumer Research Association to conduct and support our annual review audits, our processes, criteria and quality control surrounding our Non-Animal Testing Policy has become more robust and in depth, resulting in a greater scope for non-compliance. For example, in 2013 we started looking at a company’s corporate group, and what they are involved in as a whole, instead of focusing solely on the company we directly deal with — a process of which we formalised in 2021. Ethical Consumer have witnessed this growth.

The Lush Prize

Alternative testing methods are always on our radar, and we are actively promoting these methods to replace animal tests. Our dissatisfaction with the difficulty of ending animal testing led to another conversation with Ethical Consumer, asking for advice on running a prize fund which might help speed up the pace of change. After much research and consultation with scientists, academics and campaigners, the first Lush Prize awards were handed out in 2012 in a tent made of recycled paper in Shoreditch, London. We’ve provided more information about the money raised through the Lush Prize, and the groups it supports, in the Campaigning Principle.

The Prize has built up a big community of high-level supporters and we are beginning to see real change in the ambition of politicians and scientists, particularly in the USA and Europe. The Lush Prize Conference, and other events we hold, explore key issues with its winners and other experts. These provide an opportunity for scientists, campaigners and other experts from around the world to exchange ideas and information about the movement to end animal testing. Recent events have attracted more than 300 participants and high profile speakers. We believe this prize fund has accelerated the introduction of alternative non-animal testing, operating on the cutting edge of change. Our partnership with Ethical Consumer continues to support and advocate for the implementation of alternative testing in legislation, paying specific attention to toxicity testing for consumer products and ingredients. Focusing on Adverse Outcome Pathways and 21st Century Toxicology, the fund is aimed to support the most progressive work in this field and ensure its continuation and expanding impact.

In 2013, XCellR8 won the Lush Prize for Training and since then we have been working closely to gather non-animal based information on our raw materials. XCellR8 is an animal free in-vitro testing laboratory dedicated to providing scientifically advanced testing services to the cosmetics and chemical industries, without the use of animals or animal products. Our close relationship enables us to build a foundation of knowledge and experience in human biology based testing that needs to exist in order to get more companies and authorities to drop animal tests altogether. Our alternative method specialising toxicology team also works closely with the lab to build a database of safety information on the ingredients we use in our products. These human-based results help guide and inform our safety assessments and work towards our non-animal testing goals. 

Utilising cell culture testing means that our products and ingredients which are intended for humans, are actually tested on humans. Since 2015, we have tested 406 finished products with XCellR8.