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Ethical Consumer Assurance Statement 2020

Lush Cosmetics Non-Animal Testing Audit Assurance Statement 

March 2020

Introduction 

Lush has had a non-animal testing policy in place since the company's inception in 1995 and fighting animal testing is a core part of its philosophy and public messaging. 

In July 2013, Lush Cosmetics first engaged Ethical Consumer Research Association (Ethical Consumer) to conduct annual audits of its supply chain in the UK for compliance with its non-animal testing policy. The audit has since widen to cover Lush's manufacturing bases globally. This 2020 statement follows the latest round of audit visits. 

Lush's current Animal Testing policy on its website states: 

"We will not knowingly purchase ingredients from suppliers that have conducted, commissioned or been party to animal testing after our fixed cut-off date 1st June 2007 unless the supplier commits to no further animal test in the future and using for Lush acceptable in-vitro (refers to the technique of performing a given procedure in a controlled environment outside of a living organism) alternatives. 

Whilst we recognise the unavoidable exception of REACH legislation (Registration, Evaluation, Authorisation & Restriction of Chemicals), Lush wishes to continue to encourage suppliers to test for safety using non-animal testing methods and to fund the development of non-animal test methods." 

Lush provides the funding for the Lush Prize(s), whereby cash awards given to organisations or individuals working for the replacement of animal testing and/or development of alternatives. 

Ethical Consumer is also contracted by Lush to manage the Lush Prize. 

Ethical Consumer has also been commissioned by Lush to produce other research since 2010 

Scope of the audit

The 2019 audit was conducted within the following parameters. 

a) The audit assessed Lush's UK, North American, Japanese, Australian and German manufacturing bases only. It did not cover the company's operations in Croatia which is visited on a bi-annual basis. 

b) In the UK the primary focus of the visits were raw materials. One packaging supplier was also visited in each manufacturing region. 

c) The audit covered compliance with the company's animal testing policy. 

That is: 

  • Suppliers should not conduct or commission animal testing, with the unavoidable exception of testing for compliance with REACH, and; 
  • The products purchased, or their ingredients, should not have been tested on animals after June 2007

d) The audit covered goods purchased between January 1st 2018 and December 31st 2018. 

Responsibilities of Lush and Ethical Consumer 

Each of the Lush manufacturing sites annually conducts an internal Non-Animal Testing (NAT) review of its suppliers. The results of this review are supplied to Ethical Consumer.

For the manufacturing countries which were included under this year's audit, the UK, North America, Germany, Japan and Australia, accompanying documentation was also supplied. This included details of each manufacturing site's purchase history along with supplier declaration forms and re-sourcing spreadsheets. 

Ethical Consumer conducted all work in relation to the audit, including the risk assessment to identify companies to visit, preparations for the visits and compilation of the report. As an independent third party, it offered commercial confidentiality to Lush suppliers if they wished not to disclose information about their downstream suppliers to Lush. 

Audit work undertaken 

Lush site visits and interviews 

Between July 2019 - November 2019 Ethical Consumer visited Lush UK premises in Poole; conducted a video conference with Lush North America, Lush Japan's premises in Tokyo; conducted a video conference with Lush Australia; and visited Lush Germany's premises in Düsseldorf. 

Key members of staff involved in purchasing, compliance with the company's animal testing policy and the development of Lush products were interviewed. 

Risk assessment 

For Lush UK, Ethical Consumer conducted a risk assessment of 254 UK raw material suppliers and 79 packaging suppliers. This was based on a range of factors including their response to the Lush NAT review, the size of company, and the nature of the materials it supplied. Following the risk assessment ten companies were chosen to be visited. 

Audit visits 

Ethical Consumer visited ten of Lush's UK suppliers. In addition two suppliers were visited at each of the overseas manufacturing bases included in the audit: Japan, North America, Australia and Germany. It should be noted that the audits for suppliers in North America and Australia were conducted via video conference. The topics covered included practical issues regarding personnel and processes, whether and how companies were engaged with REACH and the production of substance dossiers for REACH, specific questions around the supply chains of different products, and the practicalities of complying with Lush's policy. 

Findings and opinion 

Lush's annual Non-Animal Testing (NAT) review is a comprehensive assessment of its entire supply base and a genuine attempt to identify non-compliance with its animal testing policy. 

Since the 2016 audit, Lush has used a colour coding of declaration forms from suppliers to help identify suppliers who were non-compliant. All of Lush's manufacturing bases now use the same system for the NAT review and now hold annual training sessions for personnel involved in the NAT review. The global training which is now taking place has helped Lush to identify common issues and problems within Lush's supply chain to be addressed. 

Overall the number of Lush's suppliers globally found to be non-compliant with Lush's non animal testing policy had risen slightly from 12% in 2017 to 13% in 2018. Instances of non compliance by suppliers include the failure to complete or return Lush's NAT declaration forms, or the merger of compliant suppliers with non-compliant ones. The systems for tracking non-compliance and for replacing suppliers with compliant ones were found to be structured and functional at each of its manufacturing bases. 

Signed:

Rob Harrison
Ethical Consumer Research Association

Mackenzie Denyer
Ethical Consumer Research Association

Alex Crumbie
Ethical Consumer Research Association

March 2020

 

 

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