In skincare and beauty, ‘cruelty-free’ is one of the claims I see the most confusion around – from both brands and consumers.
It might sound simple, but it isn’t. There’s no regulated definition, regulations around animal testing have changed significantly in recent years and consumer expectations haven’t kept up with any of it.
So in this article I’m answering the questions I get asked most often by my clients:
- What does ‘cruelty-free’ actually mean?
- How is ‘vegan’ different from ‘cruelty-free’?
- Can skincare brands still test their products on animals in Australia – or overseas?
- Are beauty consumers still looking for ‘cruelty-free’ brands?
- Can I legally say my skincare brand is ‘cruelty-free’?
- Am I allowed to say my products are ‘not tested on animals’?
- Do I need to get cruelty-free certification for my cosmetic brand – and is it worth it?
- Can I use a bunny icon if I’m not certified?
- Is ‘cruelty-free’ still a selling point – or just expected?
Plus you’ll find a free cheat sheet to download at the end.
This article is written with Australian skincare and beauty brand owners in mind, but if you’re on the other side trying to figure out what ‘cruelty-free’ actually means, or you’re reading from overseas, there’s still plenty here for you too.
What does ‘cruelty-free’ mean?
There’s no regulated definition or industry-agreed definition of ‘cruelty-free’ for cosmetics in Australia. Similar to words like ‘sustainable’, ‘clean’ and ‘natural’, it’s a broad claim that can be interpreted in different ways.
Beauty consumers generally understand ‘cruelty-free’ to mean that a brand does not test its products on animals, and this is often how small to medium brands in Australia intend the claim to be understood.
Some consumers apply their own criteria to the claim, and look at things like whether a brand sells in markets where animal testing may be required or is owned by a parent company that tests on animals.
As one Redditor commented on a post where someone asked for cruelty-free skincare recommendations:
“No offence, but there are like 2,000 different definitions of what cruelty free means. Without being specific about what you define as cruelty free it’s hard to recommend anything.”
What’s the difference between ‘vegan’ and ‘cruelty-free’ skincare?
‘Cruelty-free’ doesn’t mean the same thing as ‘vegan’, but the two are often confused or used interchangeably by consumers.
While both relate to animal welfare, ‘cruelty-free’ relates to animal testing, while ‘vegan’ relates to ingredients – so a product can be cruelty-free but still contain animal-derived ingredients like beeswax, lanolin, or salmon-derived PDRN.
Consumers don’t always realise the two claims are separate, so it can come as a surprise that a cruelty-free brand isn’t necessarily vegan, or that a vegan product may still have been tested on animals.
‘Vegan’ is more straightforward – it simply means the formula doesn’t contain any animal-derived ingredients. Because of that, it’s usually easier to substantiate, as long as you have the right supplier information.
Is animal testing banned for cosmetics in Australia?
Yes – animal testing conducted solely for cosmetic purposes is effectively banned in Australia through two key frameworks:
- The Industrial Chemicals Act 2019 restricts the use of new animal test data for cosmetic ingredients. In practice, this means brands can’t rely on animal testing conducted after 1 July 2020 to support the introduction (import or manufacture) of those cosmetic ingredients in Australia.
- The National Health and Medical Research Council (NHMRC)’s Australian code for the care and use of animals for scientific purposes, which sets the standards for animal use in scientific research and is enforced through state and territory legislation, does not permit the testing of finished cosmetic products on animals. Testing of ingredients is only permitted where it’s for a non-cosmetic purpose, such as pharmaceutical, and certain criteria are met.
What about overseas animal testing requirements?
Animal testing requirements vary between countries, and this is where a lot of confusion comes in. I mainly focus on Australian regulations, but it’s helpful to understand some of the nuance globally, so here’s a very basic overview.
Similar to Australia, the European Union, United Kingdom and New Zealand have also introduced restrictions or bans on animal testing for cosmetics. In the United States, animal testing regulations vary by state.
In recent years, China has been progressively relaxing its animal testing requirements, meaning that today, depending on the product type and how it is supplied, many brands can sell there without requiring animal testing.
However, consumer perception hasn’t fully caught up, and China is still often discussed online in relation to ‘cruelty-free’ claims. Many people still assume that any brand selling into China must test on animals. In reality, selling in China does not automatically mean a product has been tested on animals – but it also doesn’t guarantee that it hasn’t.
This highlights how complex and inconsistent global requirements can be. For larger, multinational brands operating across multiple markets, this can make ‘cruelty-free’ claims more complicated. For most small to medium Australian brands that aren’t selling into these regions, the situation is usually much more straightforward.
Are consumers still looking for ‘cruelty-free’ brands?
There isn’t much recent, reliable data on how often ‘cruelty-free’ drives purchase decisions, but if you look at Reddit discussions, a few clear patterns show up.
For many people, it’s either a baseline expectation or just not something they think about too deeply anymore.
As one Australian Redditor put it:
“It’s become such a default checkbox for smaller Aussie brands rather than a genuine differentiator, especially since animal testing is literally banned here anyway. Cruelty-free is lowkey the bare minimum now – what else are you actually doing?”
For some, it still matters – but it’s flexible when other factors come into play:
“I’m CF for all products apart from pharmaceuticals and sunscreen… it’s really hard to find a HG [Holy Grail] sunscreen at a good price point.”
And then there’s a smaller group where it’s non-negotiable:
“It’s one of the first things I check about a business. It determines whether I purchase from a brand.”
“If you mention cruelty-free and vegan upfront it’s likely you’ll get me as a customer. If I have to spend more than 2 minutes trying to figure it out I’ll just move to the next company.”
My take: Yes – there are still people actively looking for cruelty-free brands, but they’re not the majority. For most people, it’s more of a “nice to have” than a deciding factor, and it tends to drop down the list when price, performance or availability comes into play.
Can I say ‘cruelty-free’ on my skincare labels?
‘Cruelty-free’ is not recommended as a label claim – and here’s why.
Now that you understand the context of cruelty-free claims, let’s look at what you can and can’t say, and where the risks sit.
Under the Australian Consumer Law, claims that are false or misleading are prohibited – even if it’s not intentional.
Because ‘cruelty-free’ doesn’t have a clear, consistent or regulated definition, it can be interpreted in different ways, e.g. whether it refers to finished product testing, ingredient testing or broader ethical considerations. It’s an emotive claim, but ambiguous, which is where it can become misleading if your customers don’t understand exactly what it means.
Accord Australasia’s Voluntary Industry Code of Practice to Support the Australian Ban on Testing Cosmetics on Animals (the Accord Code) states that ‘cruelty-free’ and other vague terms like ‘animal friendly’ shouldn’t be used for this reason.
While the Accord Code isn’t legally binding, it does reflect the intent of Australian Consumer Law, so I think it’s a sensible framework for brands to follow.
For that reason, I always recommend clients avoid adding the text ‘cruelty-free’ to labels and packaging (and even in Instagram bios!).
Can I say ‘not tested on animals’ on my skincare labels?
Possibly – but only under specific conditions that are harder to meet than most brands realise.
This claim is more specific than ‘cruelty-free’.
The Accord Code states that ‘not tested on animals’ should only be used where both the finished product and its ingredients have never been tested on animals – not by the brand itself, or by anyone else in the supply chain, including ingredient manufacturers or suppliers.
This is where things get a bit more complex. While animal testing is no longer used for cosmetic approval in Australia, many cosmetic ingredients have been tested on animals in the past. Ingredients can still enter the cosmetic supply chain today through non-cosmetic regulatory pathways, such as therapeutic use.
That means a broad ‘not tested on animals’ claim could potentially be misleading.
The Accord Code suggests a more accurate option may be a qualified claim, such as ‘not tested on animals since [year]’. But in practice, it can be difficult to substantiate, and it’s not something I’ve seen used yet.
For larger international companies that have shifted away from animal testing and have supplier documentation around the testing history of ingredients, this may be an option. But for many small to medium Australian brands, it may create more confusion than clarity for customers.
This is why some brands choose to get third-party certified instead. As the Accord Code notes, a third-party logo carries a specified meaning given to it by the scheme that manages it – which is exactly what a vague claim lacks.
Do I need to get cruelty-free certification for my skincare brand?
It’s not legally required for Australian skincare and beauty brands, but it’s a clear, strong way to support ‘cruelty-free’ claims if you want to use them confidently.
Because they have published criteria and defined standards sitting behind the claim that consumers can look up, the wording isn’t being left open to interpretation in the same way a standalone ‘cruelty-free’ claim often is.
There are a few cruelty-free certification schemes that have been used internationally and in Australia, but the landscape has changed over time.
Historically, there were three main options for Australian skincare and beauty brands:
- Choose Cruelty Free (CCF) – an Australian certification scheme that discontinued in 2021 after it merged with Cruelty Free International, so this logo shouldn’t be used anymore.
- PETA “Beauty Without Bunnies” – a global certification scheme that is currently reviewing its eligibility requirements and, at present, is only accepting companies based in or selling into the US, Canada, India and Germany.
- Leaping Bunny (Cruelty Free International) – the most widely recognised global cruelty-free certification programme and generally considered the most rigorous standard.
Currently (as of April 2026), Leaping Bunny is effectively the only certification option available for Australian brands that want to support ‘cruelty-free’ claims through an independent scheme. It requires brands to meet strict criteria across both finished products and ingredient supply chains, including supplier declarations and ongoing compliance checks.
Is cruelty-free certification worth it?
This really depends on your brand and your customers.
Certification gives people a trusted signal and removes the confusion (and potential regulatory risk) around what you mean, because the scheme has published criteria that anyone can look up.
It also comes with cost, time and effort, including data gathering, liaising with manufacturers and ingredient suppliers, and ongoing compliance requirements.
So the real question is whether your customers actively look for certification when making a decision about what cosmetics to purchase, or whether they’re making decisions based on other factors like budget, brand story, product benefits or how much they trust your brand.
If you know your target customer actively researches cruelty-free credentials for any brand they choose – cross-checking lists, looking for logos or checking parent company ownership – then certification is worth considering.
If they’re not, your time and budget are probably better spent elsewhere.
Can I use a bunny logo if I’m not cruelty-free certified?
A bunny logo might seem like a harmless design choice – but it carries more risk than most brands realise.
Under the Australian Consumer Law, it’s not just the words you use on your packaging, website or social media that matter – it’s the overall impression your branding creates. That means imagery alone can still land you in trouble if it creates a misleading impression, even without any text.
The risk here is that bunny imagery is so closely associated with cruelty-free certification that consumers will often assume it signals independent verification – whether that’s intended or not.
This is exactly the issue both regulators and industry guidance are trying to tackle. The ACCC’s greenwashing guidance warns against imagery that gives the impression of certification or verification where none exists. While it’s framed in an environmental context, the same principle applies to cruelty-free claims under Australian Consumer Law.
The Accord Code previously mentioned takes a similar line, flagging the use of generic or ambiguous symbols where consumers could reasonably be misled about what’s actually behind the claim.
In practice, I usually come across two types of bunny logos when reviewing cosmetic labels. In some cases, brands have used generic bunny imagery sourced from a designer or stock library, without realising the potential association it carries. In other cases, the issue is more serious – where the icon used looks very similar to (or the same as) an existing certification mark, but they aren’t certified.
If you’re not certified by a recognised scheme, my recommendation is simple: avoid bunny imagery altogether.
Does saying my brand is ‘cruelty-free’ help it stand out?
In short, no.
‘Cruelty-free’ isn’t something I’d recommend using as a USP (point of difference) – regardless of whether the claim is misleading or not.
I see a lot of brands leading with ‘natural | cruelty-free | vegan’ on their labels or Instagram bios, but the reality is these aren’t what make a brand stand out anymore.
Unless you’re a large, multinational brand operating in complex markets, it’s very unlikely you’re testing on animals anyway. So calling it out doesn’t necessarily put you ahead – it just brings you in line with what many consumers already expect (and what’s legally required in Australia).
So what should skincare brands do instead of saying ‘cruelty-free’?
As you’ve seen, ‘cruelty-free’ is a complicated claim, shaped by changing regulations, differing consumer expectations and often a gap between perception and reality.
It’s also an area where many brands aren’t fully aligned with regulator and industry guidance, which can make it feel unfair. If they’re saying it and getting away with it, why should you hold back?
You don’t want to risk losing sales by not communicating it at all (for the minority who do look for it when buying cosmetics), but you also don’t want to risk regulator attention or reputational damage by saying it incorrectly.
Instead of relying on vague ‘cruelty-free’ claims or generic bunny logos, here are two options I recommend (do both if you can!).
Get certified – if you want the strongest, most substantiated way to support the claim, certification is the clearest option.
Be transparent — if certification isn’t an option, rather than making a broad claim you can’t back up, explain on your website (e.g. your FAQ page) what you do and don’t do, and why.
This approach is in line with my Clear Beauty philosophy: educating consumers, being clear and transparent (not just compliant), building trust, and not adding to consumer confusion or following trends blindly.
(I’ve included an example FAQ response in the free cheat sheet you can download below that you’re welcome to adapt for your own brand.)
At the end of the day, it’s your business, so ultimately it’s your decision what claims you make. But I hope the information above gives you enough context to make an informed decision.
It’s also worth remembering – what actually makes the biggest difference isn’t a single ‘cruelty-free’ claim. It’s how you communicate what your product does, who it’s for and why it’s worth choosing.
That will sell more products than a ‘cruelty-free’ claim slapped on a skincare label ever will.
Want the cheat sheet?
I’ve pulled everything into a quick guide – including suggested FAQ wording you can copy and paste directly onto your website.
And if you ever need help navigating the grey areas around claims and what you can (and can’t) say about your brand or products, you can check out my services here.
Jen has worked with Australian and international skincare and beauty brands on regulatory compliance since 2018, drawing on a background in corporate risk and compliance and degrees in Business and Psychology. Jen speaks regularly on cosmetic regulation, including at the Australian Society of Cosmetic Chemists (ASCC), the New Zealand Society of Cosmetic Chemists (NZSCC), in-cosmetics Korea, and Monash University.
0 Comments