IAVS condemns EU’s ‘Tick-Box Torture’ of animals

IAVS condemns EU’s ‘Tick-Box Torture’ of animals

IAVS lobbies Irish MEPs over EU breaching own ‘ban’ on poisoning animals to test cosmetics

On 11th March 2021 - the 8th anniversary of the EU law that was supposed to ban animal testing for the sake of cosmetics - the Irish Anti-Vivisection Society (IAVS) joined forces with animal protection groups and cosmetic companies across Europe to complain to the European Commission about massive loopholes in the Cosmetics Regulation which mean that animals were still being poisoned and killed for vanity products. In particular, regulations around chemicals – REACH – are being enforced by the European Chemicals Agency (ECHA) [1] in a way that means ingredients exclusively used in cosmetics continue to be tested on animals.

For example, last August the ECHA demanded three separate animal toxicity tests for homosalate [2], an ingredient in sunscreens such as those under the L’Oreal brand. [3] One of the tests ordered required at least 60 rats to be force-fed homosalate every day for 90 days before being killed. [4] Another test involve force-feeding of the substance to scores of pregnant animals until the birth date, at which point both the mothers and baby animals are slaughtered and dismembered for analysis. [5]  The third test would sacrifice even more animals, with fathers, mothers and offspring being force-fed the chemical from before conception until the pups reach adulthood, when they are put to death. [6]

What’s more, these animal tests are notoriously unreliable: the developmental and reproductive tests aren’t even consistently ‘reproducible’ – a basic measure of scientific validity – because the identical test can be performed in different laboratories, but yield different results. The ECHA’s implementation of REACH is a callous tick-box approach with no real regard for the wellbeing of innocent sentient animals.

The IAVS followed up on 19th March 2021 with a direct appeal for support to the six Irish MEPs who are members or substitute members of Committees that have oversight over this policy area:


Billy Kelleher MEP, Fianna Fáil, South Constituency
Seán Kelly MEP, Fine Gael, South Constituency
Mick Wallace MEP, Independents for Change, South Constituency
Ciaran Cuffe MEP, Green Party, Dublin Constituency
Deirdre Clune MEP, Fine Gael, South Constituency
Grace O’Sullivan MEP, Green Party, South Constituency


As of 3rd June 2021, we have received a response from just one of the MEPs, Grace O’Sullivan, who sits on the Environment, Public Health and Food Safety (ENVI) Committee of the European Parliament. Ms O’Sullivan kindly assured us of her support for our call for an immediate end to cosmetics testing on animals under REACH, and said she will be on alert for how the new EU Chemicals Strategy for Sustainability might impact on animal testing for cosmetics.

The IAVS is disappointed at the lack of response so far from the other MEPs and will continue to agitate against this scandalous situation.

IAVS chairperson Yvonne Smalley comments:

“The IAVS is appalled at the callous indifference and incompetence of EU institutions on this matter. With one face, Brussels passes a law which appears to heed public opinion and basic morality by banning such gratuitous suffering, and the public is led to believe that this evil has been consigned to history. But with the other face, the EU enacts other legislation which quietly drives a coach and horses through the testing ban, allowing other EU bodies to commission animal cruelty. And it is no wonder these terrible things happen if the indifference of many Irish MEPs is representative of the attitudes within EU institutions.”


[1] Ireland’s Competent Authority for REACH enforcement is the Health and Safety Authority, which also has strong links with the ECHA.

[2] https://echa.europa.eu/documents/10162/61c5d2f4-fca4-6bef-9df7-de10802ee3bf

[3] https://inside-our-products.loreal.com/ingredients/homosalate

[4] https://www.oecd-ilibrary.org/environment/test-no-408-repeated-dose-90-day-oral-toxicity-study-in-rodents_9789264070707-en

[5] https://www.oecd-ilibrary.org/environment/test-no-414-prenatal-development-toxicity-study_9789264070820-en

[6] https://www.oecd-ilibrary.org/environment/test-no-443-extended-one-generation-reproductive-toxicity-study_9789264185371-en