the european coalition to end animal experiments€¦ · european coalition to end animal...

The Humane Cosmetics Standard

The European Coalition to End Animal Experiments

ECEAE

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HCS Final Version 1.0 July 2008

Contents

Section 1 ……. Introduction and background to the Standard……………………… 3 Section 2 ……. Summary of approval process and procedures……………………. 5 Section 3 ……. Independent assessment approach…………………………………... 6 Section 4 ……. Humane Cosmetics Standard criteria - (‘The Standard’)………….. 8 Section 5 ……. Definitions…………………………………………………………………. 9 Section 6 ……. Cruelty free flow chart…………………………………………………... 13 Section 7 ……. The ‘Rabbit and Stars’ (Leaping Bunny) Logo……………………… 14 Section 8 ……. Guidance notes…………………………………………………………… 15 Section 9 ……. The Forms ………………… HCS Application Form ………………… Declaration of product compliance ………………… Declaration of raw material compliance ………………... Auditor checklist Appendix 1….. Cruelty free flow chart

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Section 1 Introduction and background to the Standard

Companies sign up to the standard by providing information on their suppliers, products and ingredients. The HCS has been in use since 1996. It is the most comprehensive standard a company can adhere to in terms of removing animal testing from its supply chain, as it operates at an ingredient level. The standard requires a company to:

No longer conduct or commission animal testing

Apply a company fixed cut-off date (a date after which none of your products or ingredients have been animal tested)

Be open to an independent audit throughout your supply chain

Adhere to your animal testing policy

The Standard was developed by an international coalition of animal protection groups from across the European Union and North America, including

European Coalition to End Animal Experiments (ECEAE)

Coalition for Consumer Information on Cosmetics (CCIC).

In the UK the Standard is managed by the British Union for the Abolition of Vivisection (BUAV). The BUAV also acts as secretariat for the ECEAE.

1. What is the Humane Cosmetics Standard (HCS)?

The HCS is the only internationally recognised scheme that enables consumers to easily identify and purchase cosmetic and toiletry products that have not been tested on animals.

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Section 1 Introduction and background to the Standard

2. This document

This document is for: 1. New companies who wish to apply

for approval or existing partner companies requiring any further information about the Standard.

2. Independent assessors - for

review of auditing requirements and a copy of the checklist to be used during a company audit.

3. ECEAE group members for

distribution to companies in their own countries who wish to join the Standard.

It includes the following forms:

1. Application Form – to be completed and returned for approval

2. Product Declaration Form*- to detail each product within a com-pany’s own label range

3. Raw Material Declaration Form* –

to be copied and completed by each supplier to the company applying for approval – this

document requests the date that the ingredient was last tested on animals, so that the company may assess this date in accordance with their own Fixed Cut-Off Date and ensure the ingredient is compliant with the HCS.

4. Auditor Checklist – for use by the auditor and for reference by a company applying for approval, to see how the audit is performed.

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Section 2 Summary of application and approval process

1. Collection of Information The company applying for approval collects all raw ingredient and product information from their suppliers using the forms provided. Application forms should only be submitted for approval after all information has been obtained.

2 Processing Applications

Applications are reviewed on receipt for all appropriate information. Where necessary, additional information may be sought from the company.

3 Company Approval Companies that are approved will be issued with notification of approval and a contract to sign. We also provide advice and discuss marketing and promotional opportunities, working with each company individually to provide a complete service to help launch the HCS.

4 Logo Formal approval under the Standard will be issued by the ECEAE. A copy of the logo will be made available to the approved company. Further guidance on logo use can be found in Section 7 of this document.

5 Independent Assessment - The Audit

Within six months of being granted approval, the company’s Supplier Monitoring System must be open to independent assessment by a suitably qualified auditor. An audit will take place within 12 months of approval. The auditor conducts the assessment and sends the report to the company. The company considers the results of the assessment and implements new procedures as necessary. If such procedural changes are fundamental, the company will be required to undergo re-assessment. A copy of the auditor’s report should then be sent to the ECEAE member group. See Section 3 for further information.

6 Renewal

Approval may be renewed on an annual basis on the condition that the company continues to meet the Standard’s criteria for animal testing and its terms and conditions.

A company may also wish to consider gathering this information via their purchase order system. In this case, we request that any statements or text to be used on Purchase Orders should be sent to us for review and approval.

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The audit visit typically lasts up to 1 day at the company premises (i.e. possibly just a morning or afternoon depending on company size). The inspection will include:

interviews with staff

review of the supplier monitoring system

review of declarations and forms

if applicable, a review of any on site manufacturing or laboratory premises.

Again, depending on the company, we are always prepared to arrange the audit but some may wish to appoint an auditor themselves and we can arrange to incorporate the audit into a company’s current auditing system. Full guidance, information and an agenda explaining the details of the audit are always sent to the company well in advance of the audit date (which is also mutually agreed in advance with the company). The company will have the opportunity to consider the results of the audit and

implement new procedures if necessary, before the report is sent to the ECEAE member group. It should be emphasised that the audit, whilst of course ensuring that a company remains compliant with the standard, is designed to help companies with any supplier monitoring issues and answer any questions they may have on managing the Standard. Any findings or recommenda-tions will be positively highlighted with full guidance and assistance for future best practice implementation. The Auditor’s Checklist should be used to perform the assessment (see page 19).

Section 3 Independent assessment approach - the audit

A suitably qualified auditor will conduct the independent assessment in strictest confidence.

The audit is designed to help companies with any supplier monitoring issues and answer any

questions they may have on managing the Standard.

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i) A company’s Supplier Monitoring System must be open to an independent audit within six months of the company gaining approval under the Standard. The audit will be carried out within 12 months of gaining approval and then at least once every three years thereafter.

ii) The audit evaluates compliance with

the Standard and ensures that a company has effective policies and procedures in place to monitor its manufacturers and suppliers. This will involve inspection of documentation relating to the animal testing of products and/or ingredients, and how the company uses the monitoring system to ensure that animal tested ingredients are not used. This may be a simple or a more complicated system, depending on the size and structure of the company.

iii) The assessment will be conducted

with professional confidentiality using the Standard’s Independent Assessment Approach and Auditor Checklist.. Results will be the property of the company but the assessor must forward a report to the ECEAE to

confirm that the company continues to meet the Standard’s criteria. Where a breach of the criteria is found, the company and auditor must notify the ECEAE, by providing full details and all relevant data and information concerning the breach. The ECEAE will then work with the company to remedy the breach and provide guidance on solutions available, to ensure the company’s continued approval under the Standard.

iv) A company that currently operates a

Supplier Monitoring System or other quality assurance procedures should contact us to discuss how the Standard’s auditing requirements can be incorporated into its current approach.

Section 3 Independent assessment approach - the audit

The audit involves inspection of documentation

relating to the animal testing of products

and/or ingredients, and how the company uses the monitoring

system to ensure that animal tested

ingredients are not used.

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Section 4 Humane Cosmetics Standard Criteria - (“the Standard”)

Criteria for non-animal tested cosmetic and toiletry products

(Please refer to Section 5 – Definitions)

1. A company2 must not (now, or in the future) conduct, commission3, or be a party to animal testing5 of any cosmetic product including, without limitation, formulations and ingredients7 of such products. No animal testing of the finished product or any individual ingredient is permitted, regardless of whether the testing was conducted by the company seeking approval, the ingredient supplier, third party manufacturer or any other third party commissioned so to do.

2. A company must not purchase any

formulation, ingredient or product from any third party manufacturer8 or supplier9, 10 that has conducted, commissioned or been party to animal testing for cosmetic purposes6 on them after the company’s fixed cut-off date11.

3. A company must implement a supplier monitoring system12 to ensure that ingredients and products meet the Standard’s criteria, and the supplier monitoring system must be open to an independent audit.

4. A company must obtain declarations of

product and raw material compliance13 (or equivalent documents), from each of its third party manufacturers and suppliers. This information will be kept as part of the company’s supplier monitoring system.

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Section 5 Definitions

Ref no Terminology Definition under the Standard

1 Cosmetic A ‘cosmetic product’ shall mean any substance or preparation intended to be placed in contact with the various external parts of the human body (epidermis, hair system, nails, lips and external genital organs) or with teeth and the mucous membranes of the oral cavity with a view to exclusively or mainly to cleaning them, perfuming them, changing their appearance and/or correcting body odours and/or protecting them or keeping them in good condition.

2 Company Legal entity (Limited liability company/Sole Trader/Partnership/Other entity recognised by the law) involved in selling Cosmetic/Toiletry products under its own name.

3 Commission Where a Company requests a Third Party Manufacturer and /or Ingredient Supplier, other company in the group or contract testing laboratory to conduct Animal Testing.

4 Animal An animal is defined as it is under the Great Britain Animal (Scientific Procedures) Act 1986:1) Subject to the provisions of this section, "a protected animal" for the purposes of this Act means any living vertebrate other than man and any invertebrate of the species Octopus vulgaris from the stage of its development when it becomes capable of independent feeding. (2) Any such vertebrate in its foetal, larval or em-bryonic form is a protected animal only from the stage of its development when - (a) in the case of a mammal, bird or reptile, half the gestation or incubation period for the relevant species has elapsed; and (b) in any other case, it becomes capable of independent feeding. *Also included under this definition are cyclostomes (hagfish), cephalopods (octupi and squid) and decapod crustaceans (lobsters, crabs and prawns) as well as their foetal and larval forms, as recommended by AHAW (Panel on Animal Health and Welfare) on behalf of the EFSA (European Food Standards Agency) in their opinion on the animals that should also be included in the revision of the European Directive relating to laboratory animals (86/609/EEC). (The EFSA Journal (2005) 292, 1-46 - Opinion on the “Aspects of the biology and welfare of ani-mals used for experimental and other scientific purposes”). *Please note - it is acknowledged that the additional species listed here do not relate to testing under the requirements of the HCS. However, they are included to be consistent with the general BUAV definition of an animal.

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5 Animal Testing

An experiment (defined in European Directive 86/609) “any use of an animal for experimental or other scientific purposes which may cause pain, suffering, distress or lasting harm….”

6 Animal Testing for Cosmetics Pur-poses

Animal Testing within your supply chain of an Ingredient for use in a Cosmetic Product (irrespective of whether the Cosmetic Product is the Company’s or a third party’s) or where the ingredient was, in prac-tice, first used in cosmetics. Animal Testing within your supply chain of an Ingredient where the testing was not specifically carried out for use in a Cosmetic Product but where the Ingredient is in practice used more in Cosmetic Prod-ucts than otherwise (50% or more used).

7 Ingredient Also referred to as a compound/raw material/additive*. Can be a single substance or mixture of substances, intended for use in Cosmetic/Toiletry products, as listed on the product label. Fragrance products and ingredients should also be included in this definition. *An additive is any substance which has been added to a raw material or mixture of materials which does not contribute to the function of the compound/ingredient in the product. These include preservatives, stabilisers and diluents.

8 Manufacturer A manufacturer that supplies directly, through an agent or third party any finished cosmetic products to or on behalf of the Company seeking approval under the Standard.

9 Direct Supplier

Any supplier that supplies directly finished Cosmetic/Toiletry products that may or may not manufacture those products.

10 Ingredient Sup-plier

Any ingredient manufacturer that supplies directly, through an agent or third party, any ingredient or ingredient mixture, used in the formulation of cosmetic products. This includes the original manufacturer of the ingredient, the supplier who sells directly to the company and all intermediaries.

11 Fixed Cut-off Date

A date after which a Company, its Third Party Manufacturers and/or Suppliers must not have conducted or commissioned Animal Testing for the Company’s own-label Cosmetics Products and/or Ingredients supplied for use in the Company’s products. The Company must also not purchase any Ingredient on which any of its suppliers have commissioned or conducted animal tests for Cosmetic Product pur-poses after the Company’s Fixed Cut-off Date. The Company may choose its own Fixed Cut-off Date, which must be before the date of the Company’s application to join the Standard and it must be fixed and consistently applied throughout its entire Cosmetic Product range, now and in the future.


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12 Supplier Monitoring System (SMS)

A system by which a Company monitors its Third Party Manufacturers and Suppliers at least once a year (unless otherwise agreed) to ensure that they have not conducted or commissioned Animal Testing (tracing back to the original Manufacturer of the Product and/or Ingredient). The system need not be complicated, but it must be effective and open to an independent audit. Suppliers to be monitored must include the original manufacturer of the Ingredient. A company may also wish to include its FCOD on its purchase order system to ensure the information is automatically gathered from suppliers when purchasing new ingredients. A Company must not use in its products any Ingredients that have been animal tested for cosmetic product purposes by their suppliers or third party manufacturers since the companies fixed cut-off date, even if the testing was not commissioned by the company seeking approval. Agents or Distributors may not sign the Declaration of Product/Raw Material Compliance. Exemption from implementing a Supplier Monitoring System Only a company that manufactures products for which they grow all of their own ingredients, or who purchase all ingredients from growers of natural agricultural ingredients would be exempt. For example, the manufacturers may grow herbs and flowers, and may purchase bananas from a greengrocer. However, if the company uses ingredients such as essential oils, stabilisers, preservatives or other additives that are supplied by an ingredient manufacturer, they must indicate on the application form that they do use suppliers. Companies who do not use suppliers for any ingredients should confirm in writing that this is the case.

13 Declaration of Product/Raw Material Compliance

Written confirmation obtained by a Company once a year from all its Third Party Manufacturers and Suppliers that they have not performed Animal Testing for the Company’s products and ingredients after the Company Fixed Cut Off Date. These documents form part of the Company’s Supplier Monitoring System. Equivalent documents may be used on the condition that they provide at least the information requested on the Declarations.


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14 Vegetarian For any company wishing to have their products declared as Vegetarian, we ask that the Vegetarian Society definition is used: A vegetarian product must not contain any of the following: • Animal flesh (meat, fowl, fish or shellfish) • Meat, fish or bone • Animal carcass fats • Gelatine, aspic, gelatine based block or jelly crystals • Battery or intensively produced eggs. • Royal Jelly (Please note: vegetarian ingredients are not compulsory under the HCS but companies are very welcome to declare them- see Section 8 for further information)

15 Vegan For any company wishing to have their products declared as Vegan, we ask that the Vegan Society definition is used. The manufacture and/or development of the product, and where applicable its ingredients, must not involve, or have involved, the use of any animal product, by-product or derivative. Vegan products are, as far as is possible and practical, free from all animal ingredients, such as meat, animal milks, eggs, honey, leather, wool and silk . (Please note: vegan ingredients are not compulsory under the HCS but companies are very welcome to declare them- see Section 8 for further information)


16 Independent Audit

An assessment of a Company’s Supplier Monitoring System.

17 Gross Annual Sales

Gross annual sales apply to a Company’s own-label range of Cosmetics and Toiletries.

18 Purchase Order

A document used by a company to purchase products or ingredients. A company may wish to include their FCOD and policy prohibiting the purchase/use of animal tested ingredients on this document to alert suppliers. In this case, we request that any statements or text to be used on Purchase Orders should be sent to us for review and approval.


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Section 6 Cruelty Free Flow Chart

Please refer to Appendix 2 at the end of this document. This flow chart has been developed to help companies through the process of assessing ingredients suitable for use under the HCS. It should be repeated for each existing ingredient a company uses when applying for approval AND for each new ingredient they wish to add thereafter. If you have any questions or need advice, please contact the ECEAE. Please also refer to the definitions section above for further clarification.

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Section 7 The ‘Rabbit and Stars’ (Leaping Bunny) Logo

The Standard logo (‘the Logo’) is set out in Annex 3 and is registered as a trademark in the European Union and the United States and Canada. i) The Company may, on a non-

exclusive basis, apply the Logo to corporate communications materials (including those used in advertising and point of sales) (‘the materials’) and product packaging in the territory provided that the materials and packaging relate solely to the products meeting the Standard.

ii) The Logo is to be used in a combination of its official colours (Pantone 2728 and black) wherever possible. It is also acceptable to reproduce it in one of these colours alone or reproduce the logo in a single colour reversed out. There should be sufficient contrast between the background and the Logo to ensure its legibility.

iii) No alteration or addition is to be made to the Logo.

iv) No drawing, symbol or words other than “BUAV approved”; “ECEAE ap-proved”;” Approved by [ECEAE member organisation]”, e.g. “Approved by BUAV”, “Approved by EDEV”; or “Approved under the Humane Cos-metics Standard”) is to be placed on or adjacent to the Logo so as to suggest that such drawing, symbol or words are part of or associated with the Logo, unless the written consent of the Coalition is first obtained.

v) In this clause, ‘territory’ means

European Union, the United States of America and Canada. The Coalition may, on written application by the Company, extend the territory on such terms as it thinks fit.

vi) On termination of the agreement the

Company may no longer use the Logo except to the extent necessary to enable it to sell or otherwise dispose of all stocks of the products then in its possession (subject to a maximum period of 90 days).

Rabbit and Stars (Leaping Bunny) logo for use only by companies approved under the Humane Cosmetics Standard.

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Section 8 Guidance Notes

Vegetarian/Vegan Products & Ingredients (Please refer to Section 5) We welcome vegetarian and vegan products under the Standard; however this is not mandatory for approval under the Standard. These questions are included on the declaration forms as an optional extra if companies wish to provide this information and be indicated on the Go Cruelty Free website and Little Book of Cruelty Free as a vegan or vegetarian company. This can also prove a useful marketing advantage for companies wishing to promote their products to shoppers who particularly seek vegetarian or vegan items. (Please note: an entire range must be declared vegan or vegetarian in order to be indicated as such on the GCF website, to avoid confusion to consumers.) Product range approval A Company must apply for approval to join the Standard for its entire own label range of Cosmetic Products. Individual products or lines within a range cannot be approved as this causes confusion for consumers and

conveys misleading information about the standard. The Standard works on the basis that a company applies for approval in their own country but are then approved worldwide. Any companies who wish to apply for approval in countries that do not currently operate the HCS would be reviewed and approved by the BUAV. Also, approval is given on the basis of global accreditation (For example, a company based in Holland would go through the approval process there but would be approved worldwide if its products were available in other countries.) Go Cruelty Free website and The Little Book of Cruelty Free Upon approval, a company has full rights to use of the Rabbit and Stars (Leaping Bunny Logo ) and will be added to the Go Cruelty Free Website and Little Book of Cruelty Free. The Little Book of Cruelty Free is produced for the UK - similar marketing materials may apply in the country of the company application and approval. Similarly, websites profiling approved companies may also operate in each country.

Appendix 1Cruelty Free Flow Chart ECEAE

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Appendix 1 – Cruelty Free Flow Chart Page 1 of 1 HCS Final Version 1.0 July 2008

N

Has the ingredient ever been tested on animals ?Please contact your supplier(s)

for this information.

Do you know the date that this ingredient was last tested on animals?

Is this date AFTER your company FCOD?

Y

Y

YN

Please contact

your supplier(s)

for this information.

N

The ingredient cannot

be included in your products. Are you

willing/able to withdraw this ingredient or

reformulate/withdraw the product?

Is the ingredient used 50% or more in the

cosmetics industry? Please contact your supplier(s) for this

information

Was the ingredient FIRST USED in a

cosmetics product after it was animal

tested? Please contact your supplier(s) for this

information.

Your company CAN be approved under the HCS

IS this the final ingredient you need to check? If NO,

please return to START and repeat for each

ingredient

The ingredient CAN be used-please continue

below.

Your company cannot be approved under the HCS

Y

Y

N

N

Y

Y Y

N

Was the ingredient tested on animals after your FCOD for cosmetics purposes?

Please contact your supplier(s) for this information.

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For more information on the Humane Cosmetics Standard, please contact your local group operating the Standard, or alternatively: Cruelty Free Officer ECEAE 16a Crane Grove London N7 8NN United Kingdom Telephone: +44 (0) 20 7700 4888 Facsimile: +44 (0) 20 7700 0252 Email: [email protected] Website: www.gocrueltyfree.org

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