Cruelty-free and vegan are two different claims about two different things, and a product can hold one without the other. Cruelty-free addresses testing: no animal testing at any stage. Vegan addresses composition: no animal-derived ingredients in the formula.
A base makeup formulated with carmine and never tested on animals is cruelty-free and not vegan. A formula with no animal ingredients, sold into a market that required animal testing for registration, is the reverse. Shoppers treat the two words as synonyms. Certification bodies do not, and neither do the buyers writing your RFQ.
What PETA US actually certifies
The Beauty Without Bunnies programme run by PETA US works from company-level commitments rather than product-level claims. A brand and its suppliers state that no animal testing occurs at any stage of development, and the listing rests on the verifiability of that statement across the supply chain.
That verifiability constraint explains something brands often read as arbitrary. PETA US concentrates on markets where direct supply chain verification can be managed with confidence — the US, Canada, Germany and India among them. A brand manufacturing through a chain that runs into markets where ingredient-level testing history is not traceable has a harder case to make, and no amount of internal policy substitutes for a supplier who can document what happened upstream.
The programme has also widened beyond the testing question alone, taking in sustainable production and supply chain verification. The direction is consistent: the claim is being anchored to evidence about the chain rather than to an assertion about the finished product.
The REACH tension
Here is the contradiction that has occupied the industry for years. The EU bans animal testing for cosmetic purposes. The EU’s REACH framework governs chemical safety, and can require animal data for substances used in cosmetics when it assesses them as industrial chemicals for worker or environmental safety.
The result is an ingredient that has been animal-tested lawfully under one European regime while another European regime prohibits animal testing for the product it goes into. A brand can be fully compliant and still find a certification body treating that ingredient as disqualifying.
This is not a loophole a brand can close by choosing better suppliers. It is a structural conflict between two frameworks with different purposes, and the practical consequence is that certification decisions turn on where a substance’s test data came from and why — a question most brands have never had to ask their raw material suppliers.
Alternatives to animal testing, and their limits
The methods replacing animal tests are further along than they were, and they are not uniform in maturity.
- Reconstructed human skin models, used for skin irritation and corrosion, are the most established and the most widely accepted by regulators.
- Computational toxicity prediction reads across from structurally similar substances with known profiles. Useful for screening, weaker as a standalone submission.
- Ocular and sensitisation endpoints remain the harder cases, which is why they show up most often in disputes about whether a substance’s file is complete.
For a brand developing a vegan foundation, the relevant point is that these methods cost money and take time, and the bill lands somewhere. If a supplier is quoting an unusually low price for a certified-compliant raw material, the reasonable question is which testing route produced its safety file.
Composition is the easier half
Replacing animal-derived ingredients in base makeup is largely a solved formulation problem. Carmine has pigment alternatives, lanolin has plant-derived emollient replacements, and beeswax substitutes are well established in stick and cream formats.
Plant-derived components including avocado oil, aloe vera and green tea extract have become common in this category, partly for their own properties and partly because they carry a story that photographs well on an ingredient list. They also tend to suit sensitive skin, which is a genuine performance argument rather than a positioning one.
What remains difficult is matching the wear and coverage of formulations that used animal-derived waxes and film formers without adding synthetic content the brand’s clean beauty positioning has ruled out. That squeeze — vegan, clean, and long-wearing at once — is where most reformulation projects in this category actually stall.
A naming fight worth watching
The EU has been debating whether plant-based food products may use traditional meat names — whether a plant product can be called bacon or chicken. The European Court of Justice has already indicated that clearly labelled plant-based products fall outside the concern the restriction is meant to address.
Cosmetics are not food, and nothing in that debate applies directly. It is worth watching anyway, because it is the same underlying argument: whether a descriptive term is inherently misleading, or whether adequate labelling resolves it. Whichever way that reasoning settles will inform how regulators treat other category-defining words, and vegan is one of them.
Where this leaves a sourcing decision
Vegan has stopped functioning as a differentiator in several categories. It appears in RFQs as a baseline requirement, often before the formula direction is settled, which means a brand claiming it is meeting an expectation rather than making an argument.
The differentiator now is the documentation. Which certification, verified how far up the chain, with what evidence about each raw material’s testing history. Brands that can answer those three questions specifically are in a different conversation from brands that can only point at a logo. The same shift is visible in adjacent categories, from vegan mascara and eye products to markets tightening their safety data and claim rules more generally.
Two things are worth settling before development starts. Decide which certification you are targeting, since the criteria differ and retrofitting a formula to a scheme it was not built for is expensive. And ask your manufacturer for supplier declarations covering animal-derived content and testing history at the raw material level, in writing, at the sampling stage. Requesting that document after the campaign brief is written is when a vegan foundation project usually goes wrong.
“We’re seeing ‘vegan’ shift from a marketing add-on to a baseline expectation in RFQs — buyers ask about cruelty-free and animal-derived-ingredient documentation earlier in sourcing conversations than they did even a couple of years ago, often before they’ve settled on a formula. What’s interesting from a positioning standpoint is that brands are starting to differentiate less on the vegan claim itself, since it’s now table stakes for many categories, and more on how transparently they can show their sourcing and testing story. That’s the conversation we’re having more often with clients building out foundation and base makeup lines.” — Hyejin Cho, Digital Marketing Specialist, Marketing and Communication Team at SPSCOS