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Lush’s response to the Ethical Consumer Research Organisation’s 2019 audit findings

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 companies that are not involved in the use of, or commission the use of, animals for testing and have no plans to do so in the future. We believe that animal testing is not acceptable. We recognise that customer safety is of importance and believe that this can be assured without the use of animals.

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. This is unless the supplier commits to no further animal test in the future and commits to using acceptable to Lush 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.

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. 

Lush has always stuck by this policy and back in July 2013 asked the Ethical Consumer Research Association to verify, in the form of an audit, that everything we say in regard to no-animal testing, is also what we do. 

The scope of the 2019 Ethical Consumer audit, Responsibilities of Lush and Ethical Consumer, the audit work undertaken, and the audit visits are explained in the Lush Cosmetics Non-Animal Testing Audit Assurance Statement February 2020. 

We were pleased to learn that ECRA determines our annual assessment of our entire supply chain in terms of non-animal testing to be comprehensive and a ‘genuine attempt to identify non-compliance with [our] animal testing policy” and that ‘the systems for tracking non-compliance and for replacing suppliers with compliant ones were found to be structured and functional at each of [our] manufacturing bases.

We want to take this opportunity to give further detail/clarity around the point that was raised in regards to the number of non-compliant suppliers: 

“Overall the number of our 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.”  

Non-compliance by suppliers does not necessarily mean that suppliers were found to be animal testing. We have a system in place internally to determine different levels of non-compliance; this includes the following as of March 2020: 


After our annual review every supplier in any of the above categories is recorded as non-compliant. This will include a number of suppliers who have simply failed to complete or return Lush’s NAT declaration forms or can include suppliers who are no longer in line with Lush’s non-animal testing policy due to the merger with for example a non-compliant company. All suppliers found to be non-compliant are added to a resourcing sheet and resourced by our buying teams in order of priority. 

Our Non-Animal Testing policy goes much further than simply labelling products as ‘not tested on animals’, we want to guarantee that everything that goes into our products has not been tested on animals. It is not only about the finished product not being tested but also everything that goes into it. This also includes our packaging. Especially since the EU animal testing ban on the 11th March 2013, when the EU completed the ban on the sale of cosmetics that were animal tested after that date anywhere in the world, most animal testing occurs at the ingredient level. We require that no animal testing is carried out or commissioned in any phase of product development by our suppliers or the manufacturers of the materials that we buy. This includes tests for new foods, drugs or similar. Lush does not deal with companies that test anything on animals anywhere in the world. We try not to pass our money and our customers’ money on to companies that do animal testing and we hope that the independent annual audit by the Ethical Consumer Research Association proves this and assures customers how seriously we take the fight against animal testing.



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