The New Guinea Pig -You

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The European Union (EU) has a new law forbidding the sale of any cosmetic product that contains an ingredient tested on animals. What does it mean for you?

Cosmetic Products

Cosmetic products are defined in this context as “substances or mixtures of substances intended to be placed in contact with the external parts of the human body (epidermis, hair system, nails, etc.) or with the teeth and the mucous membranes of the oral cavity with a view exclusively or mainly to cleaning them, perfuming them, changing their appearance, protecting them, keeping them in good condition or correcting body odours.”

Cosmetics guinea pig

In practice, these regulations apply to any toothpaste, sunscreen lotion, skin cream, hair shampoo, and anything else which may be used on your body’s surface or parts thereof. It does not matter whether any such substance or product had been shown to have no detrimental effect in any standard animal test. Nor would it matter if any such product may have proven beneficial effects.

Animal Testing

In the context of the new law, the term “animal” has not been defined. Perhaps a definition can be found elsewhere in the myriad of existing and new regulations. Nevertheless, the term animal here would certainly include rats and mice, rabbits and the proverbial guinea pigs.

Among the tests routinely undertaken for cosmetic products in the past were skin and eye irritation tests. They are performed on small patches of shaved skin of live rats or mice and the appearance or lack of rashes or inflammations are determined. Similarly, the rabbit eye irritation test (also termed Draize test) is checking for irritation of the mucous membranes of eyes.

All of these tests have been in use for many decades. For example the Draize test was invented by John Draize and Jacob Spines in 1944 while working for the US Food and Drug Administration. In many test cases, the animals do not suffer any lasting harm and little discomfort. No sane company would want to spend resources on detailed testing of a substance shown to cause any clear sign of irritation effects in short order.

Other Methods

The new EU regulations are aimed to replace actual animal tests with computer models. This field of science, generally known as quantitative structure-activity relationships (QSARs) has been rapidly evolving since the 1970s. I have been working in that field myself for several decades.

QSARs have great value in optimizing (desired) effects of new drugs and medicinal compounds, but they still lack the ability to conclusively estimate the effects of substances with novel (untested) chemical structures. The QSAR computer models which the EU is going to use to determine product safety are not exactly earth-shattering with precision. Therefore, it appears to be rather premature to rely solely on such computational methods for the safety of products which may become used by many millions of people world-wide.


With the EU ban of the sale of any of the “cosmetic” products listed above containing any substance tested with animals, many manufacturers of such “cosmetics” will have to scramble to comply with the new law which is slated to become effective this July. Worse though, for any new products the consumers outside the EU will effectively become the substitute guinea pigs for their counterparts in the EU.

So, next time you brush your teeth or apply sunscreen lotion, you may have reason to wonder if the image you see in the mirror is that of the new “de facto EU guinea pig” for the new toothpaste or lotion you are using.


The new regulation forbids the sale of any product for which either any ingredient or the whole substance has been tested on animals. At least for the time being, existing products are grandfathered in.


Abbreviated and full versions of the new law are available at here and here, respectively.

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    Charles Higley


    It has recently been established that the omnivorous and decayed-foods eating abilities of rats and mice go with very different immune systems and reactions. Thus, hundreds of studies on rodents are very misleading regarding the human response to the same challenges. Even the rabbit may be a false lead as they are herbivores and deal with a very different range of challenges.

    Perhaps the EU would like to volunteer their prison inmate population, letting them volunteer for studies in exchange for reduced sentences. The civil liberties bleeding hearts hate this idea as they claim it’s indirect coercion but isn’t every choice we make in life based on the gain, loss, or risk of a given choice or action?

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