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Fluffywashing: 8 actionable tips for detecting whether a brand is truly cruelty-free

23 February 2017

There’s a dodgy practice going on that you might not be aware of.

Let me fill you in.

You’ve heard of the term greenwashing, whereby companies employ various tactics to make their products appear ‘greener’ or more eco-friendly than they actually are.

Well, there’s a similar process happening with companies trying to make themselves or their products seem cruelty-free, vegan, or in general animal-friendly when they simply aren’t.

I like to call this ‘fluffywashing’.

If you’re out to be a conscious consumer you absolutely MUST be aware of common fluffywashing tactics and how to avoid them.

Let’s start by looking at how fluffywashing came to be an issue.

Just like greenwashing, many brands are guilty of fluffywashing to make their products look more animal-friendly than they really are. Learn 8 tips on how to avoid falling for it in the new blog post!

How and why do companies fluffywash?

There are two main ways companies get their hands dirty with fluffywashing:

Either (1) quite deliberately, showing a distinct lack of company ethics;
(2) somewhat mistakenly or out of ignorance.

Although this is sucky, it is actually happening because of a very awesome reason.

How so?

Well, consumers are becoming more aware of animal-testing practices and more interested in the origin of the ingredients in the products they are using. In other words, it comes down to the basic economic principle of supply and demand.

Consumers are making smarter purchasing choices. They are putting their money towards brands with stronger ethics and animal-friendly policies. They are creating DEMAND for animal-friendly products.

Companies big and small are noticing this, and realising they want a piece of the cruelty-free pie. They want to be a part of the SUPPLY of seemingly animal-friendly products.

Today, people spend well over fifteen billion dollars a year on cosmetics, and with that kind of money at stake, some companies will use any method they can think of to get you to buy their products. It’s a copy-cat business.

Aubrey Hampton of Aubrey Organics

The many meanings of 'cruelty-free'

Unfortunately, there’s no universal definition of the term 'cruelty-free’. Just like how the label 'free-range’ on eggs still isn’t regulated in various countries and the term 'natural' remains undefined and overused across a number of industries.

So, what does that mean in practice?

Companies who put statements like 'cruelty-free' or 'not tested on animals' on their products, or perhaps even an unofficial bunny logo, could really mean any of the following:

  • The product is cruelty-free in the strictest sense (without being vegan). Neither the product nor its ingredients have been tested on animals, neither by the company itself or a third party acting on its behalf, their ingredients supplier has not tested the ingredients on animals. Normally to have any meaning this has to be the case from a certain cut-off date, as a majority of ingredients have been tested on animals at some point in the past.
  • The company has not tested the product on animals but it has tested one or more of the ingredients. This is very common, as the majority of animal testing happens at the ingredient level.
  • The company has not tested the ingredients on animals but it has tested the final product on animals.
  • The company has not tested the product on animals but it has commissioned a third party to do so.
  • The company has not tested the ingredients on animals but it has commissioned a third party to do so.
  • The company has not tested the product or ingredients on animals in their country of main business (i.e. the US), but the product or ingredients have been subject to mandatory animal testing elsewhere (for example, in China, where animal testing of cosmetic products remains largely mandatory).

Now that we have an idea of the issue at an international level, let’s look to whether fluffywashing is also an issue in the European Union.

Fluffywashing in the EU

On the surface, the situation in the EU seems positive. The Cosmetics Regulation actually deals directly with the ability of companies to make animal-testing claims on cosmetic products. The following conditions need to be satisfied:

  • Neither the manufacturer nor their suppliers may have carried out testing or have commissioned testing by a third party;
  • the testing must not have been on the finished product, its prototype or its ingredients; and
  • the product may not contain ingredients that have been tested on animals by others for the purpose of developing new cosmetic products.

So, what are the issues then?

Well, that last part is interesting to note: “for the purpose of developing new cosmetic products.”

This is why:

Ingredients can still have been tested on animals, so long as the testing was for a purpose other than cosmetics. So, for example, under the REACH legislation where ingredients can be tested on animals for pharmaceutical or other purposes.

It doesn’t end there.

Also interesting to note is that the regulation doesn’t expressly mention the words ‘cruelty-free’. In fact, the previous guidance given on the subject was that any wording could be used (or pictures!):

Any person who wishes to use a claim to indicate that no animal testing has been carried out is free to choose the wording of the claim and/or to use any pictures, figurative or other signs...

Commission Recommendation of 7 June 2006

This has contributed to the problem of companies using random bunny-themed logos that can actually mislead the consumer into believing the product has attained some actual cruelty-free certification.

Additionally, the Commission Recommendation says that the place of testing is not relevant, meaning that companies cannot test their products on animals in China, for example, and then sell them in the EU with a cruelty-free claim / image on it. This explains why the majority of products sold in Europe still don’t have ‘free of animal testing’ claims on them. It's additional proof that no one can claim all products sold in the EU since the animal testing ban are cruelty-free.

On top of all this, it’s also very difficult for the EU to oversee that every single product placed on the EU market complies with these requirements.

With this in mind, and knowing that the EU is certainly not free of fluffywashing practices, it’s very important to be familiar with the various fluffywashing tactics.

Let’s look at some actual examples of fluffywashing tactics so you know what to look out for.

Actionable tips for avoiding falling for fluffywashing tactics

Example of fluffy-washing tactic Actionable tips!
1 Using the phrase 'cruelty-free' or 'not tested on animals' just because a company notices a consumer demand for this. Visit the company’s website and look at (1) their values / brand philosophy and (2) their FAQ. I personally find it dubious when I have to really dig and dig and still can’t find any mention of being cruelty-free on their website. A brand that is truly committed to being animal-friendly should make it easy enough for you to discover their stance on the issue.

Extra tip! Be wary if they speak of not testing on animals ‘except when required by law’. See example 6, below.

2 Applying fake certification logos to their products (or use of a certification that doesn’t really ensure cruelty-free status). This is commonly a picture of a rabbit or some similar animal-reference. Be wary of certification logos you do not recognise, and make sure to read up on what the common certification logos actually mean in terms of the cruelty-free status of the product. Don’t just blindly assume a product is cruelty-free from the presence of a rabbit logo!
3 Saying ‘Product not tested on animals’, when the ingredients have been tested Decide what meaning of ‘cruelty-free’ you are comfortable with. If you don’t want your products nor their ingredients to have been tested on animals, be wary of these sorts of phrases where companies make a distinction between testing on products and testing on ingredients.
4 Saying ‘We don’t test on animals’. Be aware that this kind of wording leaves the possibility open that a 3rd party was commissioned to test on animals on the company’s behalf (or on behalf any of the suppliers in their supply chain). If you’re unsure, send the company an email to dig a bit further.
5 Saying ‘We do not test on animals, except when required by law.’

‘We don’t test on animals. We do comply, however, with the laws of each country we sell to.’

Be aware of the situation with China. This is real complex and will have a whole blog post devoted to it shortly. But for now be aware that when a company chooses to sell in China, they are choosing to allow their products to be tested on animals. There are a couple of exceptions, for example selling in Hong Kong, or manufacturing products in China but not selling them there. More on this real soon!


Admittedly, fluffywashing is mainly about the appearance of being cruelty-free in the common definition of that term, meaning a lack of animal testing. But making one’s company appear more animal-friendly than it really is can also mislead consumers searching for vegan products (i.e. products neither tested on animals nor containing animal-derived ingredients).

So, here are a few bonus vegan examples:

6 Saying a product is ‘free from animal ingredients.’ Always double check the ingredients yourself. I was in contact with a company when starting up Lumabelle and noticed they had basically copy-pasted the phrase ‘free from animal ingredients’ on virtually all product descriptions – even on a product with beeswax! I’m sure this was an honest mistake, but it goes to show that fluffywashing can still occur with good intentions and you need to be an alert consumer.
7 Claiming their ingredients are vegan but only thinking of the obvious animal products like honey, lanolin, or beeswax. Companies who don’t research their ingredients fail to understand that many can be animal based or synthetic (i.e. Urea) or derived from either animals or plants (i.e. Lactic Acid). This is information they should require from their suppliers in order to avoid making misleading claims on their products.

Get educated about animal ingredients, if they are something you want to avoid.

Also be aware that a company who has actually checked that none of their ingredients are animal-sourced will almost always state that their products are vegan, in order to appeal to vegan consumers and show they know what goes into their products. If they don't state that their brand or certain products are vegan, assume they are not until you have further information.

Emailing the company is a great start. Don't assume all companies understand what constitutes a vegan ingredient.

8 Proclaiming their products are vegan (either some or all) and using this as a way to claim their products are 'kind to animals', or other such phrases. Although if true, this is a great start, be aware that not all vegan brands or products are also cruelty-free, in the sense that they are still tested on animals.

Become fluffywashing-immune

Although claims on packaging can be very misleading, as soon as you do a bit of digging it usually becomes quite obvious whether the company is legitimately cruelty-free. A visit to the company’s values section on their website, then to their FAQ to check their stance on animal testing, and finally, emailing them if you still aren’t sure exactly what their stance is.

All the brands on Lumabelle have been thoroughly vetted and are legitimately cruelty-free. In other words, it’s a fluffywashing-free zone!

What's your experience?

Have you seen any of these fluffywashing tactics in use? Or do you have even more to add to the list? Scroll down and leave a comment below!

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