We have shared our concerns over the lack of clarity in the European Commission’s proposals to change Europe’s main chemicals law, REACH – and have emphasised the need to speed-up the phase out of animal testing for chemical safety assessments and to strengthen measures to ensure animal testing is used only as a last resort.

We also highlighted the potential impact of new or expanded legal requirements which could lead to a huge increase in testing on animals, such as in tests aimed at identifying endocrine disruptors (chemicals which harm the production and function of hormones in people and the environment) and to generate information about polymers (long molecules made of a series of repeating smaller molecules). 

The EU presented its latest version of plans to change the REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) regulation in a meeting on 3-4 April, after which we were invited to submit comments. 

In collaboration with other animal protection organisations (Eurogroup for Animals, Humane World for Animals, People for the Ethical Treatment of Animals and the European Coalition to End Animal Experiments), we raised a number of points: 

• The need for changes to REACH to be coherent and complementary to other initiatives, such as the Commission’s chemicals roadmap towards phasing out animal testing and the Chemicals Strategy for Sustainability 

• The limited detail and lack of further opportunities to analyse proposed changes, and their likely impact, especially on the use of animals in testing – this has made it difficult for any stakeholder to give a fully-informed response and help amend the law in a way which works for everyone 

• The need to prioritise the use of non-animal methods, considering the anticipated surge in new testing demands – with potentially millions more animals being used - but also the need to only use animal testing as a ‘last resort’ 

• Support for improvements to the Testing Proposal process to encourage greater collaboration and consultation to avoid new tests on animals wherever possible 

• Prioritising non-animal strategies for assessing polymers, for which standard approaches often do not work, and also for nanomaterials (particles which measure one billionth of a metre), which are too expensive to assess using traditional methods 

• Creating tailor-made approaches to assessment the safety of chemical mixtures 

Estimations vary, but for polymers alone up to 24 million animals could be used in additional tests, and up to 25 million animals could be used for testing for endocrine disruptors. These tests conducted for the REACH regulation would be on top of the 9.3 million experiments already conducted on animals in the EU and Norway, for REACH and other purposes. This highlights the scale and urgency for our concerns to be addressed. 

Our Director of Science and Regulatory Affairs, Dr Emma Grange, said: “The need to move to non-animal testing methods for chemical safety assessment is not just an ethical consideration, it can also make those assessments faster, more efficient and more relevant to human health, all of which supports EU goals to increase economic competitiveness and protect health and the environment.  

“The opening up of REACH to incorporate new changes to the legal requirements brings an opportunity to improve this key regulation and better support both the reduction of animal testing and transition to non-animal approaches. Some of the EU’s new proposals are likely to bring significant increases in animal testing, so greater clarity regarding the alignment of the REACH revision with the Commission's forthcoming roadmap towards phasing out animal testing would be appreciated. The changes we make now will have an impact for decades to come.”