Monday, December 4, 2023

By Sara Amundson and Kitty Block

The U.S. Food and Drug Administration is considering requiring companies to conduct new animal tests for several sunscreen ingredients that have been in use for decades. If this happens, companies would be forced either to test on animals or be limited to just two ingredients to produce sunscreen and products containing SPF (sun protection factor).

Because these ingredients have been used for so long, there is an immense amount of real-world human health data, data from past animal tests and data from non-animal test methods already available. If the FDA does decide that new safety information is needed, methods that use sophisticated technologies instead of relying on outdated animal tests would be much more effective.

Tell the FDA to reconsider requiring new animal tests for sunscreen ingredients >>

Testing ingredients on animals is a notoriously unreliable predictor of how humans will react to the same ingredients. As the FDA knows, embracing “human-relevant” methods (tests that use human cells or human data-driven technology instead of experimenting on animals) is critical for maintaining public trust and ensuring that products are safe. New animal tests are both unnecessary and unreliable, and requiring them would result in needless animal suffering. It also flies in the face of repeated commitments from the FDA to reduce and replace animal tests with non-animal methods, as well as congressional directives requiring the FDA to embrace human-relevant approaches.

In addition to the thousands of animals who would be subjected to animal tests and killed, millions of U.S. residents who avoid using products tested on animals would also be negatively affected. Cruelty-free companies may refuse to conduct the animal tests. As a result, consumers could see many of their favorite sunscreens removed from shelves. Or sunscreen ingredients may be removed for basic cosmetics, like foundation, which has provided additional safety from the sun. Sunscreens produced with the only remaining approved ingredients (zinc oxide and titanium dioxide) can leave a white cast on skin, particularly for people with darker complexions, making these products less desirable to some. Faced with these limited options, people may risk their health by forgoing the use of sunscreens altogether.

In most other nations, sunscreens are classified as cosmetics. In more than 40 countries, including Mexico and every European Union country, testing cosmetics on animals is prohibited. But because sunscreens are classified as drugs in the U.S., they are not covered by the laws in 11 states that ban the sale of animal-tested cosmetics, including California, New York, Louisiana, Virginia and Illinois.

Join us in calling on the FDA commissioner, Robert Califf, to reconsider the need for companies to conduct new animal tests for sunscreen ingredients. The FDA should take the time needed to comprehensively evaluate real-world information from decades of human use, previously conducted animal tests and non-animal approaches and exclusively commit to calling for new data from human-relevant test methods. 

Kitty Block is CEO of the Humane Society of the United States.