We only buy raw materials, to make our fresh handmade products, from companies that test none of their raw materials or anything else on animals now and have no plans to do so in the future.
This way none of our money goes to companies that test on animals. We do not just look at the one material we are buying from a company – we look at the entire companies testing behaviour. Which means, if a company offers a material that has not been tested but the company commissions or conducts animal tests for any other reasons we do not buy from this company.
It doesn’t matter what animal tests the company commissions or conducts themselves, whether it is for food, pharmaceuticals or cosmetics if they test for any reason they cannot become one of our suppliers.
We also look at the company’s corporate structure to see if a company is financially linked to any company that does conduct or commission tests on animals.
This policy means that we can be certain that the profit that our raw materials suppliers make from us does not go back into animal testing. It means that we do not do business with companies who’s ethical stance is at odds with ours.
We have built Lush from day one using this policy – and we believe this shows that it is possible to invent, manufacture and bring to the market an entire range of products without any involvement in animal testing. Our founders launched this policy in June 1993, whilst still running their previous company, Cosmetics To Go. So when they started Lush in 1995, it began life using this policy and has stuck to it ever since.
What did the introduction of the REACH (Registration, Evaluation, Authorisation & restriction of Chemicals) legislation mean for the LUSH policy?
REACH is a new European Community Regulation on chemicals and their safe use (EC 1907/2006). Its title stands for the Registration, Evaluation, Authorisation and Restriction of Chemical substances. The aim of REACH is to improve the protection of human health and the environment through the better and earlier identification of the risky nature of chemical substances.
Unlike previous regulations, REACH removes all tasks and responsibilities from the competent authorities and transfers them to the industry. It introduced uniform procedures and testing requirements for all substances.
Registration - According to the REACH Regulation, all substances manufactured or imported into the European Union in quantities of 1 tonne per year or more shall be registered. Registration, requires 8000 data per substance, supported by studies and review summaries. Manufacturers of the same substance may form a consortium and share dossier costs.
Evaluation - There are two types of evaluation:
Dossier evaluation is carried out by the European Chemicals Agency (ECHA). The registrars check the completeness of the dossier, formally evaluate the data and make further testing proposals.
Substance evaluation can be initiated and carried out by the competent authorities of any member state, if they can justify the suspicion that manufacturing and use of a substance endangers human health or the environment. REACH seeks to assess the safety of chemicals for human health and the environment, so it describes which tests need to be carried out to see what impact they have. The experiments used to assess the safety of chemicals are called toxicity tests, which traditionally involve the poisoning of guinea pigs, rabbits, birds, fish, rats and mice, although some non-animal alternatives now exist.
Authorisation - Substances subject to authorisation can only be used if the particular use has been authorised and the user meets the requirements stated in the permission, or if the use is exempted from licensing obligation (e.g. intermediate uses).
The new REACH Chemical Legislation hits us harder than other cruelty free policies – and means that whilst it was possible to be truly cruelty free and still meet all the stringent legal safety requirements, this new layer of legislation puts our suppliers at risk of being involved in third party testing. The new REACH chemical legislation affects our policy. As mentioned above our suppliers must not be involved in or commission animal testing for any reason, and any materials they supply to LUSH must only buy from other suppliers/manufacturers who are NOT involved in the use of, or commission of, animal testing, for any reason. However due to the introduction of REACH we had to make an unavoidable exception to our policy: If a supplier gets involved in animal testing due to the unavoidable requirements of meeting the requirements of REACH legislation, we have to ‘accept’ this. Whilst we recognise the now unavoidable exception of REACH legislation, LUSH continue to encourage suppliers, who have to test for safety, to use alternative testing methods and to fund the development of non-animal test methods. We also seek to re-source or reformulate a product formula to eliminate any ingredient suddenly tested on animals.
Lush intends to highlight this and work towards a day when all animals are safe from testing and properly protected by worldwide laws.
Difficulties / other testing policies
No other company follows this policy. Which means we are also often left off ‘cruelty free’ lists simply because the organisations that compile the lists either:
- Do not fully understand our policy
- Do not have a convenient pigeon hole for us so would have to give us our own heading section as our policy exceeds their standards
- Only lists companies licenced under their own scheme
- Or perhaps they simply do not agree with our route to the solution?
However lots of animal protection organisations do see the strength of Lush’s policy and are happy to include us in their cruelty free lists, even though we do not fit in the same category as the other standards.
Our policy is a hard policy to stick to and means that we have a smaller pool of suppliers to choose from than most companies.
How does LUSH implement the non-animal testing policy?
As outlined above Lush will not buy from any company that tests on animals or commissions tests on animals for any reason (with the unavoidable exception of the REACH legislation). To ensure that each supplier meets our standard we conduct an annual non-animal testing review of all suppliers.
An email containing the non-animal testing declaration is sent to the suppliers each year.
The supplier is given one month to complete and return the declaration.
If the declaration does not come back completed (even after additional time given to the supplier to answer any queries) and signed or is lacking information the supplier becomes 'unapproved' and it is necessary to resource the ingredient from a supplier who does comply.
In the event that a supplier/material becomes unapproved they are added to the ‘Non-Compliant materials log’ sheet which records the following information:
- Non-compliant material
- Date when found non-compliant
- Current Supplier
- Buyer Responsible
- Date when replacement found
- New supplier name
- N.A.T checked?
- Date submitted to labs
- Product being tested in
- Response from lab
- Date of approval
- When we can start using in production?
- If failed, why?
- Next step
At the end of the review a report is compiled and a report is sent to appropriate persons within the company.
At the end of the review the internal ‘black list’ is updated and shared with the appropriate persons.
All Lush manufacturing countries that buy their own materials for production must complete an annual non-animal testing review
Lush’s manufacturing sites in Australia, Canada, Croatia and Japan send their summary report to the UK where it is distributed to the appropriate persons.
An independent third party auditor conducts an audit of UK records each year.
Materials that have been tested for REACH are also tracked and eventually resourced where possible
LUSH do not test on animals, do not use materials that contain animal derivatives that are unsuitable for vegetarians and only buy raw materials from manufacturers who are not involved in the use of, or commission the use of, animals for testing.
We also operate a fixed cut-off date for individual ingredients, requiring that they have not been tested by the manufacturer or on your behalf as a supplier since 1st June 2007 at the latest.
Before a supplier becomes approved by us they must first complete and sign the Lush non-animal testing declaration. As this is an ongoing commitment, we also require the declaration to be renewed annually. In addition the declaration is a written condition of each order sent to suppliers.
If our supplier is part of a group of companies then they must be financially independent from any group, which carries out or commissions animal testing. Our objective is to stop our money being used in connection with animal testing, as we believe it to be both cruel and inefficient in determining safety.
Our distributors need to confirm that they do not conduct or commission tests on animal for any reason
The distributors raw materials suppliers need to confirm that they do not conduct or commission tests on animal for any reason
If we are buying directly from source/the manufacturer they also need to confirm that they do not conduct or commission tests on animal for any reason.
We ask for confirmation whether testing has ever taken place, when the company made a commitment not to test again in the future and if testing has taken place for REACH why, when, what for.
We do not only rely on suppliers to complete and sign our declaration, we research each company. Look at what materials they sell, who they are owned by, which other companies they are linked to etc. Whether they register/sell your products into any other markets that require animal testing by law etc.
Materials purchased by LUSH do not contain animal derivatives that are unsuitable for vegetarians.
Our suppliers must not be involved in or commission animal testing for any reason, and any materials they supply to LUSH are only from other suppliers/manufacturers who are NOT involved in the use of, or commission of, animal testing, for any reason (with the unavoidable exception of meeting the requirements of REACH legislation).
By signing our suppliers confirm that should any of the information provided on this declaration change I’ll let the LUSH Buying team know immediately
See more of our Lush policies and positions