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Beyond the Ban: Beauty’s Race to Build Human-Relevant Testing

Updated October 13, 2026
Updated October 13, 2026
Entropic Biosciences

Key Takeaways:

  • Forty-five countries now ban cosmetic animal testing, but the US still has no federal ban, and REACH chemical-safety rules still allow testing.
  • Brands now need evidence of why a product works, not just proof that it is safe; human skin models are starting to provide that.
  • Validation is now the main bottleneck, and the switch will happen one test at a time rather than on a single date.

The beauty and cosmetics industry has been moving to stop animal testing. However, it still has to prove, without animals, that products are safe and effective. The UK moved first. In 1998, it banned animal testing of cosmetics and their ingredients. In May 2023, a High Court challenge revealed licenses granted pre-Brexit, and the Home Office stopped issuing new licenses for testing chemicals that are used only as cosmetic ingredients. The EU banned testing on finished products in 2004 and on ingredients in 2009.

The rest of the world has since caught up. India (2014), South Korea (2017), Australia (2020), Mexico (2021), and Canada (2023) have all passed bans; Canada’s took effect in December 2023. Brazil, one of the world’s largest beauty markets, enacted Law 15,183 in July 2025. The nonprofit Humane World for Animals counts 45 countries with full or partial bans. The US is the outlier. Twelve states, including California, New York, and Illinois, ban the sale of animal-tested cosmetics, but there is no federal ban. The Humane Cosmetics Act was reintroduced in 2025 with the backing of more than 400 companies, and has yet to be passed by Congress. China dropped mandatory testing for imported “general” cosmetics in 2021, but “special use” products such as hair dyes and sunscreens can still require it.

Gaps remain. In November 2023, the EU General Court ruled that chemical company Symrise could be made to test two UV filters on animals under Registration, Evaluation, Authorization, and Restriction of Chemicals (REACH) worker-safety rules, even though both are used only in cosmetics. Campaigners estimated the tests would involve 5,500 animals. Across all sectors, Great Britain still recorded 2.54 million procedures on living animals in 2025. The question now is which methods can replace animals and still substantiate claims, satisfy chemical regulators and persuade pharma. The commercial stakes are large. The in vitro toxicology testing market was worth $31 billion in 2023 and is forecast to reach $64.8 billion by 2030, according to Grand View Research. Roots Analysis expects the organ-on-chip market to grow from $129 million in 2026 to $944 million by 2035.

Claims Need Biology, Not Just Clinicals

Ten Bio was spun out of the University of Dundee in 2020 by CEO Dr. Robyn Hickerson and co-founder and COO Dr. Michael Conneely. It keeps donated human skin alive under restored physiological tension. Once removed from the body, skin “immediately relaxes and contracts because you’ve removed the physiological tension it normally experiences,” Hickerson explained to BeautyMatter. Its TenSkin model keeps the epidermis, dermis, intact stratum corneum, hair follicles, sweat glands, and resident immune and pigment cells. The tissue stays viable for 14 days.

Hickerson sees ex vivo skin as a complement to clinical studies. “Clinical studies are important because ultimately they tell you about an effect in people. What they don’t always tell you is why you’re seeing that effect or what the product is actually doing to the biology of the skin.” Ex vivo testing lets brands measure gene and protein expression, histology, transepidermal water loss, hydration, and permeability. She said this data can be incredibly valuable in the product development and optimization process.

Broad claims are the hardest to prove. “‘Anti-aging,’ for example, covers a huge amount of biology. Aging isn’t one pathway, and you can’t meaningfully measure ‘anti-aging’ as a single endpoint,” said Hickerson. Peptides and other bioactives are raising the bar, she warned. “As the biological claim becomes more sophisticated, the evidence needed to support it also has to become more sophisticated.”

Brands increasingly need data from a range of donors. Ten Bio sources consented to surgical tissue across donor ages and Fitzpatrick skin types. It recently co-authored research showing that visible light can particularly induce oxidative stress in melanin-rich skin. “Skin from different population groups doesn’t necessarily respond in the same way, and brands are increasingly recognizing this,” Hickerson noted.

Removing Animals from the Model Itself

Many reconstructed skin models are still built on animal-derived collagen, Matrigel, or gelatin. Dr. Amir Nasajpour is founder and CEO of UCLA spinout Entropic Biosciences. He has developed a vegan, chemically defined liquid-crystal material that oscillates at 37°C. The motion prompts human keratinocytes and fibroblasts to form 3D tissue and lay down their own extracellular matrix, with no hydrogel scaffold. “Cells are really smart. If you just give them the right environment, they’ll do what you want them to do,” he told BeautyMatter.

Nasajpour argued that “once you encapsulate the cells inside of a matrix you get a lot of mass transfer diffusion limitations.” He added that many reconstructed skin models can only be studied for about a week. Entropic ships living tissues or pre-coated multiwell plates. It says its automated process has a higher throughput than bioprinting, which typically yields 12 to 24 constructs per plate. The company says several large incumbents are evaluating the technology.

Its next target is a model with a working immune system for skin sensitization testing, due within a year. In chemicals regulation, sensitization is still commonly tested with the mouse Local Lymph Node Assay. That is despite the Organisation for Economic Co-operation and Development (OECD) adopting non-animal defined approaches in 2021.

Sylwia Pawlaczyk, COO of AV Laboratories, sees bioprinting as promising but immature. She pointed to a 2026 study of a full-thickness bioprinted model that responded to substances linked to irritation and sensitization. For formulators, the value is in testing finished products. “A finished cosmetic is a complex system,” she told BeautyMatter, but “bioprinted skin is not yet a perfect copy of human skin,” she cautioned. It lacks immune cells, blood vessels, nerves, sebaceous glands, and a microbiome. For Pawlaczyk, alternatives are much more than an ethical issue. They are increasingly about generating data that are more relevant to human biology.

Validation Is the Bottleneck

The European Commission’s 2026 roadmap to phase out animal testing in chemical safety assessments sets out 22 actions across 15 domains. Progress will be reviewed in 2029. The UK’s November 2025 strategy aims to end animal testing for skin and eye irritation and skin sensitization by the end of 2026. In the US, the Food and Drug Administration (FDA) Modernization Act 2.0 removed the requirement for animal testing of new drugs in December 2022, and in April 2025 the FDA announced plans to phase out animal testing for monoclonal antibodies and other drugs.  On September 21 of this year it went further, issuing a direct final rule that replaces terminology with nonclinical studies across its regulations. “The legislation in Europe is much more open, but the United States is catching up,” said Nasajpour.

Yet legislation can only clear the path; the science still has to fill it. “It isn’t going to involve replacing the animal model with one new model. There isn’t a single alternative that answers every question,” Conneely argued. Pawlaczyk expects an integrated evidence system, and warned that a sophisticated-looking tissue model is not automatically a regulatory test method. “It must be reproducible, standardized and shown to predict relevant human outcomes consistently.”

Contract research organizations (CROs) will set much of the pace. As developers adopt more new approach methodologies (NAMs), Hickerson says CROs must decide whether to build these capabilities, buy them, or partner for them. “Researchers, CROs, and regulators need to know where it works, where it doesn’t, how reproducible it is, and what decisions can reasonably be based on the data,” she said.

Consumers are unlikely to force the issue. Nasajpour conceded that consumers oftentimes don’t care. They just want the best product that works for them. He also argued that informing the consumers is really the next big inflection point. Hickerson won’t set a deadline. “I think we’ll see the change happen application by application rather than on one particular date. Where there is already a validated human-relevant method that answers the research question, there is a clear opportunity to replace animal testing,” she concluded.

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