Pukka Herbs on Testing on animals

Does (your business) participate, directly or indirectly, in animal testing?

No

Pukka Herbs produces, markets and sells a range of functional fruit, herbal and green teas & wellbeing supplements. We are strongly against animal testing and has been Cruelty Free International certified since 2013. This means that no animal testing has been conducted or commissioned for any finished cosmetic or raw material ingredients in any phase of product development by Pukka Herbs, its laboratories or its suppliers after our fixed cut-off date of 5 June 2005.

We have always believed it to be abhorrent to continue using animals to test the safety of cosmetic products, especially since there are other methods of evaluating safety. It has been understood for a long time now that the results of product tests on animal skin do not necessarily give an accurate indication of a possible outcome on human skin. There is no justifiable reason to continue animal testing in the name of beauty.

No product, or ingredient of any product, has ever been tested on animals by Pukka Herbs since its foundation - nor will there ever a case to do so. Furthermore, we do not use the services of any other research establishment who conduct animal testing on our behalf, either on a product or any product ingredient.

Pukka Herbs has operated a strict policy to never purchase products or ingredients from suppliers or intermediary agents who have conducted, commissioned or been party to animal testing for cosmetics on them, since the company began.

Therefore, we require annual written assurances from each of our suppliers to ensure that the ingredients they sell to us comply with the Humane Cosmetics Standards, which stipulate that no animal testing is conducted or commissioned for finished cosmetic products or ingredients by the company, its laboratories or its suppliers after a fixed cut-off date.

Our commitment to the standard is such that if any of the ingredients we use were found not to be compliant with the standard, we would seek an alternative supplier for the relevant ingredients, or if necessary remove them from our product range.

This policy is made available to all Pukka People, covered in our inductions and is published here on the Responsible 100 website.

Testing on animals occurs for a wide range of reasons including scientific, medical, veterinary and curiosity driven research. In industry testing on animals often occurs in order to evaluate the safety and environmental impact of the chemicals that are the basis of a huge variety of products in everyday use. This includes, for example, paints, dyes, plastics, pesticides, household cleaners and food additives. As a result, animal testing is an issue that potentially is of concern to every business. Testing on animals, however, is a highly charged topic and there is vigorous debate about whether experiments on animals are necessary, useful or justified. There are increasing non-animal alternatives available.

While, in many countries, including the UK there is legislation and regulation of what should be tested, and which tests on animals should be carried out, the level of control will vary between jurisdictions. Within a global economy, it can be difficult to identify what is tested, where and how, especially since animal experiments are often shrouded in secrecy. Since 2013, there has been a complete EU ban on testing cosmetics, and ingredients for cosmetics, on animals but other jurisdictions allow it or, in the case of China, can mandate it (though categories of soap and shampoo will not require testing before sale in China from 2014 provided it is locally manufactured/bottled). Replacing the use of animals with humane alternatives is now the stated goal of many regulatory regimes, using the ‘3 Rs’ approach. These three principles are:

  • Replace a procedure that uses animals with a procedure that doesn't use animals
  • Reduce the number of animals used in a procedure
  • Refine a procedure to alleviate or minimize potential animal pain

In many cases, businesses can use existing ingredients that have a history of safe use or those for which there are no regulatory demands, such as certain natural products. Most businesses are not obliged to use ingredients, materials or products which require new animal testing. There remain, however, specific requirements for testing in limited sectors such as drugs development. It is important to note that some animal testing may be carried out not because regulation demands it, but because manufacturers incorrectly assume or perceive that it is required to demonstrate the safety of their products. Any company, however, is in a position to actively support a 3Rs approach.

The only internationally recognised scheme that enables consumers to easily identify and purchase cosmetics, personal care and household products that have not been tested on animals is the ‘Leaping Bunny’ certification programme. The Cruelty Free International website gives details and lists all companies approved worldwide. These use a 'Fixed Cut Off Date' (see Glossary below) as a way of continuously reducing the amount of animal testing whilst also recognising that it has happened in the past. The certification programme is recognised globally by the 'Leaping Bunny' logo, which compliant companies can choose to display on their packaging, website and publicity materials.

Other companies either do not apply a ‘Fixed Cut Off Date’, or apply a ‘Rolling Rule’ policy and both approaches mean that the company does not end its involvement with animal testing (and they cannot achieve ‘Leaping Bunny’ certification for any of their eligible products).

Testing on animals that causes pain, suffering or lasting harm is regulated under UK law. It requires three Home Office licences - for the institution, the scientist and the project. The project must outline the potential benefits weighed against the harm to the animals and a license should not be granted unless there is no alternative to animal use. Any new drug must be tested on at least two different species of live mammal, one of which must be a large non-rodent. Such research is covered by EU Directive 2010/63/EU or the UK Animals (Scientific Procedures) Act 1986.

Direct participation

'Direct participation' refers to a company that carries out, pays for or otherwise commissions any animal testing.

Indirect participation

'Indirect participation', often hidden yet pervasive, can be more challenging to identify. For the purposes of this question, a company 'indirectly participates' in animal testing when it:

  • sources ingredients or materials for their own products and services that have been tested on animals by others
  • invests in a company that directly participates in animal testing, or
  • provides products or services to a company that directly participates in animal testing.
Fixed cut-off date

With a 'fixed cut-off date' (FCOD), a company commits to not using any ingredients, materials, formulations or products that have been animal tested after a fixed date (e.g. 2005). The company products and their ingredients may change but the fixed date may not. This rule draws a clear line under animal testing and sends a strong message that a company is not prepared to continue with it. The long-term effect is a reduction in the overall amount of animal testing as more and more companies make a commitment.

Rolling rule

With a 'rolling rule', a company delays using ingredients, materials, formulations or products that have been animal tested within a specific period, e.g. the last five years. An animal-tested ingredient may be temporarily avoided, or embargoed, (because it falls within the 'last five years' bracket) but used subsequently thereafter (when it falls outside this bracket) even though it is still the same animal-tested ingredient. There are strong criticisms to be made against a rolling rule. A company may claim 'not to test on animals' while it is still using ingredients that have been animal tested elsewhere by others. Using this rule, there is no strong incentive to reduce the amount of animal testing done. It does not encourage the development of alternative methods of non-animal testing. However, supporters of the rolling rule say it allows for innovation and improvements in performance of products.

Answering YES

All Businesses MUST

State their business sector

Describe how they directly and/or indirectly participate in animal testing and for what purposes

All Businesses MAY

State any philosophy or key values which govern or influence their approach to testing on animals

Indicate where they publish their practices and policies, targets, data and other relevant information

Companies which participate in animal testing directly MUST

Indicate what animal testing legislation and regulation is applicable e.g. EU Directive 2010/63/EU or the UK Animals (Scientific Procedures) Act 1986 which require the use of animal testing);

Explain if actions are being taken to replace animal tests with alternative methods (as in the 3Rs approach), and if not, why not

State how their practices are monitored and evaluated

Describe any future intentions in regards their direct participation

Companies which participate in animal testing indirectly MUST

Set out any policies or practices which govern their indirect involvement in animal testing

Describe how their policies or practices are monitored and evaluated

Describe any future intentions in regards their indirect participation

Answering NO

All Businesses MUST

State their business sector

Describe any policies they have regarding animal testing

Demonstrate what practices and policies they have in place globally to actively monitor their supply chain

All Businesses MAY

State any philosophy or values which influence their stance on animal testing

Indicate where they publish their policies and other relevant information (including hyperlinks)

Answering DON'T KNOW

All Businesses MUST

State their business sector

Demonstrate that they are making an effort to investigate whether they are indirectly participating in animal testing, as defined above

All Businesses MAY

Provide any relevant information they have

Explain why they have been unable to gather further information

Describe their future intentions regarding this issue

NOT APPLICABLE is not a permissible answer to this question

Version 1

This question has multiple scorecards.

Businesses answering no to animal testing question

To receive a score of 'Excellent'

Being ‘test-free’ and maximising pressure for legal reforms is a strategic issue

Examples of policy and practice which may support the EXCELLENT statement:

  1. All products certified cruelty free
  2. Campaigning company supporting efforts to end animal testing
  3. Bold statement of philosophy or values
  4. Strong track record in promoting practical alternatives to testing on animals
  5. Staff and other stakeholders are engaged
  6. Strategic alliances with third parties
  7. Uses a fixed cut-off date greater than five years where alternatives for essential ingredients and/or components do not exist
To receive a score of 'Good'

Being ‘test-free’ is important to the business

Examples of policy and practice which may support the GOOD statement:

  1. Many products certified cruelty free
  2. Statement of philosophy or values
  3. Staff and other stakeholders are engaged
  4. Occasional promoter of practical alternatives to animal testing
  5. Possibility of certifying cruelty free and/or for taking a public stance on the issue being fully investigated
  6. Uses a fixed cut-off date
  7. Uses a fixed cut-off date of five years or less where alternatives for essential ingredients and/or components do not exist
To receive a score of 'Okay'

Statement on animal testing irrelevant to business given its size and/or sector

Examples of policy and practice which may support the OKAY statement:

  1. No scope for certifying cruelty free
To receive a score of 'Poor'

No statement on animal testing despite relevance to the business given its size and/or sector

Examples of policy and practice which may support the POOR statement:

  1. Some scope for certifying cruelty free but no efforts made to do so
  2. No statement of future intent
  3. No efforts made to explain policies
  4. Does not engage with third parties on issue

Businesses answering yes to animal testing question which participate directly

To receive a score of 'Excellent'

Testing on animals is unavoidable by law, company mitigates ill effects and maximises transparency as part of comprehensive best practice strategy

Examples of policy and practice which may support the EXCELLENT statement:

  1. Statement of philosophy or values
  2. Publish their practices, policies, codes of practice
  3. Statement of how company practices are monitored and evaluated
  4. Publish targets, data and other relevant information
  5. State any targets in place to reduce the number of animals used
  6. Describes various actions taken to introduce alternative methods of testing
  7. Working with third party organisations to address this issue
  8. Has discontinued animal testing in many of its procedures
To receive a score of 'Good'

Testing on animals is unavoidable by law, company mitigates ill effects and demonstrates transparency on issue

Examples of policy and practice which may support the GOOD statement:

  1. Statement of philosophy or values
  2. Publish their practices and policies
  3. State how company practices are monitored and evaluated
  4. Ensures testing does not exceed the mandated requirements
  5. Indicates actions taken to replace testing on animals with alternative methods
To receive a score of 'Okay'

Testing on animals is unavoidable by law, company demonstrates some transparency on issue

Examples of policy and practice which may support the OKAY statement:

  1. Company engages in limited dialogue about its policies and practices
  2. Statement of future intent to improve
To receive a score of 'Poor'

Testing on animals is unavoidable by law yet company refuses to engage in any meaningful dialogue about its policies and practices OR testing occurs despite not being mandated by law

Examples of policy and practice which may support the POOR statement:

  1. No statement of future intent to improve
  2. Testing beyond any mandated requirements
  3. No efforts made to explain policies
  4. Does not engage with third parties on issue

Businesses answering yes to animal testing question which participate indirectly

To receive a score of 'Excellent'

Sourcing ingredients or materials for products and services that have been tested on animals by others, investing in any companies which directly participate in animal testing; and/or providing products or services to companies which directly participate in animal testing is UNAVOIDABLE, company mitigates ill effects and maximises transparency as part of best practice strategy

Examples of policy and practice which may support the EXCELLENT statement:

  1. Statement of philosophy or values
  2. Publish their practices, policies, codes of practice
  3. Statement of how company practices are monitored and evaluated
  4. Publish targets, data and other relevant information
  5. State any targets in place to reduce the number of animals used
  6. Indicates actions taken to promote alternative methods of testing
  7. Working with other organisations to address this issue
  8. Investors which actively promote the above in their portfolios
To receive a score of 'Good'

Sourcing ingredients or materials for products and services that have been tested on animals by others, investing in any companies which directly participate in animal testing; and/or providing products or services to companies which directly participate in animal testing is UNAVOIDABLE, company mitigates ill effects and demonstrates degree of engagement and transparency

Examples of policy and practice which may support the GOOD statement:

  1. Statement of philosophy or values
  2. Publish their practices and policies
  3. State how company practices are monitored and evaluated
  4. Ensures testing does not exceed the mandated requirements
  5. Indicates actions taken to replace testing on animals with alternative methods
  6. Investors which always raise the issue with their portfolio companies and/or publish a coherent policy statement
To receive a score of 'Okay'

Sourcing ingredients or materials for products and services that have been tested on animals by others, investing in any companies which directly participate in animal testing; and/or providing products or services to companies which directly participate in animal testing is UNAVOIDABLE, company demonstrates some engagement and transparency OR is AVOIDABLE, and company is actively taking steps to change policies and practices

Examples of policy and practice which may support the OKAY statement:

  1. Where participation is unavoidable, company engages in some dialogue about its policies and practices
  2. Where participation is avoidable, company sets out credible and ambitions plans for overhauling its policies and practices
To receive a score of 'Poor'

Sourcing ingredients or materials for products and services that have been tested on animals by others, investing in any companies which directly participate in animal testing; and/or providing products or services to companies which directly participate in animal testing is AVOIDABLE, yet company makes no attempt to change policies and practices

Examples of policy and practice which may support the POOR statement:

  1. No statement of future intent to improve
  2. No efforts made to explain policies
  3. Does not engage with third parties on issue

Businesses answering don't know to animal testing question

To receive a score of 'Excellent'

Being ‘test-free’ and maximising pressure for legal reforms is a strategic issue, but criteria for answering NO to question not met for unavoidable reasons

Examples of policy and practice which may support the EXCELLENT statement:

  1. All products certified cruelty free
  2. Campaigning company supporting efforts to end animal testing
  3. Bold statement of philosophy or values
  4. Strong track record in promoting practical alternatives to testing on animals
  5. Staff and other stakeholders are engaged
  6. Strategic alliances with third parties
  7. Uses a fixed cut-off date greater than five years where alternatives for essential ingredients and/or components do not exist
To receive a score of 'Good'

Being ‘test-free’ is important to the business, but criteria for answering NO to question not met for unavoidable reasons

Examples of policy and practice which may support the GOOD statement:

  1. Many products certified cruelty free
  2. Statement of philosophy or values
  3. Staff and other stakeholders are engaged
  4. Occasional promoter of practical alternatives to animal testing
  5. Possibility of certifying cruelty free and/or for taking a public stance on the issue being fully investigated
  6. Uses a fixed cut-off date
  7. Uses a fixed cut-off date of five years or less where alternatives for essential ingredients and/or components do not exist
To receive a score of 'Okay'

Statement on animal testing irrelevant to business given its size and/or sector, but criteria for answering NO to question not met for unavoidable reasons

Examples of policy and practice which may support the OKAY statement:

  1. No scope for certifying cruelty free
To receive a score of 'Poor'

No statement on animal testing despite relevance to the business given its size and/or sector, but criteria for answering NO to question not met for unavoidable reasons

Examples of policy and practice which may support the POOR statement:

  1. Some scope for certifying cruelty free but no efforts made to do so
  2. No statement of future intent
  3. No efforts made to explain policies
  4. Does not engage with third parties on issue

Join the conversation

Log in or join to leave a comment.