The European Commission’s 2019 update to Regulation 1223/2009 served as a critical reminder to cosmetics manufacturers and importers that the EU’s animal testing ban is not just symbolic—it’s enforceable and expanding in scope. This clarification addressed lingering ambiguities about imported ingredients and components tested on animals outside the EU, making it clear that any product placed on the European market must comply with cruelty-free requirements throughout its supply chain. For cosmetic brands aiming to meet both regulatory obligations and rising consumer expectations, the update triggered an urgent need to tighten supplier verification practices and enhance supply chain transparency.
A first step for companies was to revisit their supplier approval processes and incorporate verification of ingredient testing histories. The EU’s Cosmetics Products Notification Portal (CPNP) emerged as an essential resource in this regard. The CPNP, designed as an open regulatory interface, allowed brands to check whether specific ingredients, formulations, or suppliers had been flagged for non-compliance or subject to prior regulatory scrutiny. By integrating CPNP checks into their routine supplier onboarding workflows, companies could more confidently ensure that ingredient sources aligned with EU animal testing prohibitions.
Yet verifying compliance required more than simply checking a database entry. The updated regulation highlighted the importance of tracing ingredient provenance—knowing not just what substances were used, but where they originated and how they were tested at every stage of production. This requirement posed challenges, particularly for brands relying on complex global supply networks that sourced raw materials from jurisdictions where animal testing was either required or poorly regulated. As a result, cross-referencing supplier claims with independent open data sources became an indispensable part of due diligence.
Open trade data provided one of the most effective means for brands to corroborate supplier declarations regarding ingredient origin. Platforms offering access to customs filings, import/export records, and shipping manifests allowed companies to verify the actual points of origin and transit for key raw materials. By mapping these data points against jurisdictions known for mandatory animal testing requirements, brands could identify potential risk areas and probe deeper where inconsistencies arose. For example, a declared cruelty-free ingredient that repeatedly appeared in trade data linked to high-risk countries warranted further scrutiny, irrespective of supplier assurances.
Building a cruelty-free ingredient provenance log became a best practice among companies seeking to demonstrate leadership in ethical sourcing. The structure of such a log typically followed a clear, auditable format. For each ingredient, the log documented the substance name, supplier identity, geographic origin of the raw material, certification or attestation of no animal testing, and verification source (such as CPNP entry or trade data reference). Some companies also included batch-level detail where feasible, especially for high-profile or high-risk ingredients commonly scrutinized by advocacy groups and consumers alike.
The value of this provenance log extended well beyond compliance. As ethical consumerism continued to shape purchasing patterns across Europe, brands found that publicizing these records enhanced their market position. Forward-looking companies developed templates for publishing cruelty-free logs on their websites or within sustainability reports, offering stakeholders a transparent view of their sourcing practices. These templates balanced detail with clarity, ensuring that the information presented was both meaningful and accessible to non-expert audiences. A typical entry might list the ingredient, its verified cruelty-free status, country of origin, and the verification body or data source used.
Importantly, the creation and publication of such logs signaled a cultural shift within the cosmetics sector. No longer was cruelty-free status treated as a marketing slogan alone; it became a measurable, documented, and continuously monitored aspect of supply chain management. This proactive stance helped brands not only reduce regulatory risk but also build deeper trust with increasingly conscientious consumers.
In the wake of the 2019 regulatory update, the EU cosmetics market entered a new phase where animal testing disclosures became as critical as other well-established compliance measures. Companies that recognized and acted on this reality were better positioned to navigate both legal requirements and the evolving ethical landscape that defined consumer expectations in the sector.