You turn a bottle over and see a little bunny. Or you read "not tested on animals" on the front. And you think: good, that’s sorted.
And it is. Mostly.
Animal testing for cosmetics is prohibited in Europe. The testing ban has been in effect since 2004, the sales ban since 2013. You cannot sell cosmetics here if the product or its ingredients have been tested on animals, even if that test took place outside of Europe. That is a good law, and it came about because people demanded it.
Because it is the law for everyone, the claim "we do not test on animals" on European packaging actually says very little. Every brand on that shelf is required to comply. It isn’t a choice; it is the minimum standard.
But the ban has a loophole. And that loophole has a name, a date, and a lawsuit.
The loophole
In 2018, the European Chemicals Agency asked a manufacturer to conduct animal tests on two UV filters used exclusively in cosmetics. Not to protect you as a user, but to assess the risk for the workers manufacturing the substance in the factory.
The manufacturer refused. Aren't animal tests for cosmetics forbidden? It went to appeal, and then to the European Court of Justice. The court ruled in favor of the agency.
The reasoning is legally sound but strange to the ordinary reader. Cosmetics legislation protects the end user. The factory worker does not fall under this; they fall under chemical legislation. Thus, the ban only covers the tests necessary to prove the product's safety for you. Everything else falls outside of it.
In plain language: an ingredient used only in face cream or sunscreen can still be tested on animals, and that is legal.
How often this happens
In 2021, researchers searched the entire European chemicals database. They found 413 substances used exclusively in cosmetics. Of these, 63 had still been tested on animals after the ban, in 104 tests.
And then the part that is hardest to believe: the names of those 63 substances were not published. The researchers deliberately omitted them to avoid identifying the companies.
So you cannot check it. Not because it is a secret, but because no one is telling you. That is the gap between what is on the packaging and what is still permitted behind the scenes.
The three we do know
Three substances are known by name because there have been lawsuits or official decisions regarding them. And all three are sun filters.
Homosalate and ethylhexyl salicylate are the two from the lawsuit mentioned above. According to animal welfare organizations, this involved about 5,500 animals in total. Both names are simply listed on the ingredient labels of sunscreens, as homosalate and ethylhexyl salicylate.
Bemotrizinol is the third. In this case, it was not Europe but the American regulator that demanded animal testing for approval on the US market, despite the substance having been used in Europe for twenty years. Same mechanism, different regulator, same result.
Three substances, three times sun protection. That is no coincidence. UV filters are the category for which the strictest safety questions are asked, and thus the category for which a regulator is most likely to request an animal test.
Where we stand
This is the moment to say where we stand ourselves, because we believe you should be able to know that before you believe us.
All our products fall under the COSMOS standard and are certified by ECOCERT. That standard prohibits the product from being tested on animals by the manufacturer or by a third party engaged by them, and it is audited externally, from the ingredients to the final product.
And our sun protection works exclusively with mineral filters, zinc oxide and titanium dioxide. No homosalate, no ethylhexyl salicylate, no bemotrizinol, nor any other chemical UV filter. This applies to our SPF50 stick without tint, the SPF50 stick with tint, and the liquid SPF30.
We didn't know this story when we made that choice. We chose mineral filters because we set stricter standards than the law requires, even when an ingredient is perfectly permitted. Sometimes it becomes clear in hindsight why that matters.
Things are moving
More than a million Europeans signed a citizens' initiative about this exact loophole. On June 1, 2026, the European Commission presented a roadmap to phase out animal testing in the safety assessment of chemicals, with 22 actions and a public dashboard coming later this year. By 2029, legislation should be adapted so that unnecessary animal testing disappears.
That is real progress, and it happened because citizens asked for it. It just takes a few more years. Until then, the loophole remains, and we will continue to monitor it. As soon as that dashboard is live, you will find what is on it here.
How you can check it yourself
You don’t have to take our word for it. You can do it yourself in two minutes.
Step 1. Turn your sunscreen over. Look for homosalate and ethylhexyl salicylate in the ingredient list. If they are on it, you now know something about those substances that the packaging doesn't tell you. It says nothing about the safety of the product for you. It says something about how it came to be.
Step 2. Look up the brand in a certification list. The two largest are the Leaping Bunny program and the PETA list. A certification label looks beyond the law: at the entire company, at every raw material, with a fixed cut-off date, annual declarations from every supplier, and an independent audit. If a brand isn't listed, it doesn't automatically mean testing is taking place. It means they haven't undergone the check.
Step 3. Look at the logo on the packaging. A logo from an independent certifier means that someone other than the brand has checked the formula. A sentence on the front means that the brand is saying it itself. That difference is never explained on the packaging, and it is precisely the difference that matters.
In closing
This is not a call to empty your cupboards. If you didn't know, you couldn't have changed anything about it. And products that meet European law are safe for your skin; that is not what this is about.
It is about the fact that you can know. That is why we always show the full ingredient list, explain what a certification does and does not mean, and say so when we cannot prove something. So that you can judge it yourself instead of having to take our word for it.
And if that gives you peace of mind, we have done our job well.









