Vegan and Cruelty-Free Cosmetics: What the Claims Actually Mean and How Brands Prove Them
“Vegan” and “cruelty-free” now appear on everything from lip balm to protein powder, and they are often printed side by side as if they meant the same thing. They do not. One describes what is in the product; the other describes how the product and its ingredients were tested. A product can be cruelty-free and still contain beeswax, and a product can be free of animal ingredients while one of its raw materials was tested on animals for another market. This article explains what each claim actually covers, how the main certification schemes differ from a self-declared statement, which common ingredients quietly break a vegan claim in cosmetics and supplements, and what documents a brand owner should collect before printing either word on a pack.
Quick answer: “Cruelty-free” means neither the finished product nor its ingredients were tested on animals by or for the brand; “vegan” means the product contains no animal-derived ingredients or by-products. They are separate claims and need separate evidence. In most markets, including Malaysia, neither word has its own statutory definition for cosmetics, so the claim is judged under the general rule that marketing claims must be truthful and supportable. Third-party schemes such as Leaping Bunny (cruelty-free) and the Vegan Society’s Vegan Trademark (vegan, which also excludes animal testing) give a defined standard and an external check. A self-declared claim is legal in many markets, but the brand then carries the full burden of proof, which in practice means supplier declarations for every raw material.
Key takeaways
- Vegan is an ingredient claim; cruelty-free is a testing claim. Neither automatically implies the other.
- The EU has banned animal testing for cosmetics, and the sale of cosmetics tested on animals, since 2013, but that ban does not make every product sold elsewhere cruelty-free.
- Certification schemes differ in what they check: some audit the supply chain, others rely on signed statements.
- Many common ingredients can be animal- or plant-derived (glycerin, stearic acid, squalane, vitamin D3), so the INCI name alone does not settle a vegan claim.
- The working evidence is a file of supplier declarations, kept current through change control whenever a supplier or grade changes.
Who this is for: founders and product teams planning vegan or cruelty-free skincare, cosmetics, personal care or supplement ranges, and anyone deciding whether a certification logo is worth the cost.
What is the difference between “vegan” and “cruelty-free”?
The two claims answer different questions, and a product can meet one without meeting the other.
| Question | Cruelty-free | Vegan |
|---|---|---|
| What does it cover? | Animal testing of the finished product and its ingredients | Presence of animal-derived ingredients and by-products |
| Can it contain beeswax, honey or lanolin? | Yes | No |
| Does it say anything about testing? | Yes — that is its whole purpose | Not by itself, although the leading vegan certification also excludes animal testing |
| Main evidence | Non-animal-testing declarations from the manufacturer and every ingredient supplier | Ingredient origin declarations, including processing aids and carriers |
| Typical certification | Leaping Bunny | Vegan Society Vegan Trademark and similar schemes |
The distinction matters because consumers increasingly read the claims separately. A buyer avoiding animal ingredients for dietary or ethical reasons and a buyer avoiding animal testing are not always the same person, and each expects the claim to be precise.
Is animal testing for cosmetics still allowed?
It depends on the market. The European Union has the most developed position. According to the European Commission’s page on the animal testing ban, the testing ban on finished cosmetic products has applied since 11 September 2004 and on ingredients since 11 March 2009. A marketing ban, which stops cosmetics and ingredients tested on animals from being sold in the EU, has applied in full since 11 March 2013. These provisions are now in Article 18 of the EU Cosmetics Regulation (EC) No 1223/2009.
Three nuances keep the topic from being simple:
- Other laws can still require animal data. Some substances used in cosmetics are also used in industrial products and may fall under chemicals legislation, which can require testing for worker or environmental safety. A cosmetic ban does not override those rules.
- Other markets have different rules. China, for example, changed its rules in 2021 so that many imported “general” cosmetics no longer need mandatory animal testing if the brand provides a recognised GMP certificate and a safety assessment, but certain “special-use” categories are treated differently. Brands selling into China should check the current requirements of the national regulator before claiming cruelty-free status.
- Supplements and food are outside the cosmetics ban. A cruelty-free claim on a supplement relies entirely on supplier declarations and the brand’s own policy, not on a cosmetics-specific law.
How do Leaping Bunny, the Vegan Trademark and self-declared claims differ?
A logo is only as meaningful as the standard and the checking behind it. The main options a brand owner will meet are summarised below.
| Option | What it covers | How it is checked |
|---|---|---|
| Leaping Bunny | No animal testing at any stage of product development, across the brand’s products | Supplier monitoring system, annual recommitment, open to independent audit |
| Vegan Society Vegan Trademark | No animal ingredients or by-products, and no animal testing of the product or its ingredients by or for the company | Product-by-product registration with ingredient and supplier information |
| Statement-based programmes | Usually a company-wide no-testing pledge | Signed statement of assurance; typically no audit |
| Self-declared claim | Whatever the brand defines | Only the brand’s own file; the regulator or a complainant can ask to see it |
According to its own published standard, the Leaping Bunny Program has run since 1996 under a Corporate Standard of Compassion for Animals and requires companies to pledge to end animal testing at all stages of product development, recommit each year and remain open to third-party audits. The Vegan Society’s Vegan Trademark has certified products since 1990 and is product-based rather than company-wide, so a brand may register some products and not others.
Analysis: neither type of certification is legally required for the claim in most markets. The value is mainly external credibility and a ready-made definition that saves arguments about what the claim means. For small brands, a well-kept self-declared file is a legitimate starting point; certification becomes more useful when retailers or export partners ask for it.
Which ingredients most often break a vegan claim?
Some animal-derived ingredients are obvious. Others hide behind names that sound chemical or neutral, or are available from both animal and plant sources under the same INCI name.
| Ingredient | Where it is used | Animal source | Common non-animal alternative |
|---|---|---|---|
| Beeswax (Cera Alba), honey | Lip balms, balms, creams | Bees | Candelilla, carnauba or sunflower wax |
| Lanolin | Lip and hand care; source of most vitamin D3 | Sheep’s wool grease | Plant butters; lichen-derived vitamin D3 |
| Carmine (CI 75470) | Red lipsticks, blushes, coated tablets | Cochineal insects | Iron oxides, plant-based colourants |
| Collagen, keratin, gelatin | Serums, hair care, capsules, gummies | Bovine, porcine or fish | Plant peptides; HPMC or pullulan capsules; pectin gummies |
| Squalane | Moisturisers, facial oils | Historically shark liver | Olive- or sugarcane-derived squalane |
| Glycerin, stearic acid, magnesium stearate | Almost every cream, soap and tablet | Can be from animal fat | Vegetable-derived grades of the same substance |
| Shellac, lactose, fish oil | Tablet coatings, fillers, omega-3 products | Insects, milk, fish | Plant-based coatings, cellulose fillers, algal oil |
The last two rows cause the most trouble. Because glycerin from palm oil and glycerin from tallow share the same name on a label, the only reliable check is a declaration from the supplier of that specific grade. The same applies to processing aids and carriers that do not appear on the label at all, such as the carrier in a powdered extract or the coating on a vitamin bead.
Supplement brands face this most often at the dosage-form decision. The Creaton Poh guide to choosing between capsules, tablets, powders and gummies explains why a vegan supplement usually means an HPMC capsule or a pectin gummy rather than gelatin.
How does a vegan claim relate to halal certification?
The two overlap but are not interchangeable. Halal rules govern whether an ingredient, including an animal-derived one, comes from a permissible source and is handled correctly. A halal-certified product can contain bovine gelatin from a halal source, which rules out a vegan claim. A vegan product avoids animal ingredients entirely, which removes many halal concerns but not all of them, since halal also covers alcohol content, cross-contamination and facility controls. The Creaton Poh article on halal certification for health and beauty products covers those wider requirements.
What evidence should a brand hold before making either claim?
A defensible claim rests on paperwork collected before the artwork is approved, not after a complaint arrives. In Malaysia, the National Pharmaceutical Regulatory Agency’s Guidelines for Control of Cosmetic Products require cosmetic claims to be supportable, and at the time of writing Creaton Poh has not identified a separate statutory definition of “vegan” or “cruelty-free” for cosmetics. The general rule therefore applies: the brand must be able to show the claim is true.
A practical evidence file usually contains:
- A raw material origin declaration for every ingredient, confirming whether it is of animal, plant, mineral or synthetic origin, including carriers and processing aids.
- A non-animal-testing declaration from each supplier, ideally with a fixed cut-off date after which the supplier confirms no testing was carried out by or for it.
- The manufacturer’s own declaration covering the finished product.
- A written definition of the claim, so that the brand, its manufacturer and any reviewer are checking against the same standard.
- Certification documents, if a scheme is used, with the scope (which products, which markets).
Collecting these declarations is part of normal raw material sourcing and supplier documentation, and it is easiest when the claim is part of the development brief from the start. Asking for vegan-grade glycerin at the sampling stage costs nothing; discovering after production that the glycerin was tallow-derived can mean a relabel or a write-off. The wider process of qualifying suppliers is covered in the Creaton Poh guide to raw material sourcing for health and beauty brands.
How can a vegan claim become untrue after launch?
The most common way is a quiet supplier change. A manufacturer switches to a cheaper source of stearic acid, or an extract supplier changes its carrier from maltodextrin to lactose, and the product formula on paper stays the same. Unless the claim is linked to the specification, nobody checks.
The control is to flag “vegan” and “cruelty-free” as critical attributes in the raw material specification, so that any change of supplier or grade triggers a review. The Creaton Poh article on change control when a formula or supplier changes describes how that review works in a manufacturing setting.
Common mistakes to avoid
- Treating the two claims as one. Printing “vegan & cruelty-free” requires evidence for both.
- Relying on the INCI name. Dual-source ingredients need a declaration for the specific grade.
- Forgetting the packaging and the capsule. Gelatin capsules, shellac coatings and some label adhesives can be animal-derived.
- Using a certification logo without a licence. Scheme logos are trademarks, and use is limited to registered products.
- Implying competitors are cruel. Claims that disparage other products, or suggest a product is unusual for meeting a legal requirement, can be treated as misleading. The Creaton Poh guide to what health and beauty brands can legally say explains the general principles.
Frequently asked questions
Can a product be vegan but not cruelty-free?
Yes. A product can contain no animal ingredients while one of its ingredients was tested on animals, for example to meet another market’s requirements. If both claims matter to the target customer, both need evidence. The Vegan Society’s trademark covers both points, which is one reason brands choose it.
If a product is sold in the EU, is it automatically cruelty-free?
Not in the sense consumers usually mean. The EU bans animal testing for cosmetic purposes and the sale of cosmetics tested for those purposes, but ingredients may still have animal data generated under other laws, and the same brand may sell differently tested products elsewhere. A cruelty-free claim still needs its own evidence.
Is “plant-based” the same as vegan?
No. “Plant-based” usually describes where the main ingredients come from, and it has no fixed threshold. A plant-based cream can still contain beeswax or lanolin. If the intended meaning is “no animal ingredients”, “vegan” is the clearer word, provided the evidence supports it. The related claims “natural” and “organic” are explained in the Creaton Poh article on what COSMOS, ISO 16128 and clean beauty labels mean.
Does a small brand need certification to say “vegan”?
In most markets, no. A self-declared claim is generally allowed if it is true and the brand holds the evidence. Certification adds an external check and a recognisable logo, which some retailers and export partners prefer. It also costs money and requires annual renewal, so many brands start self-declared and certify later.
Can a contract manufacturer make vegan and non-vegan products on the same line?
Usually yes. Vegan schemes generally focus on ingredients rather than requiring dedicated equipment, although cleaning procedures should prevent carry-over. A brand should check the specific scheme’s rules and ask the manufacturer how shared lines are cleaned between batches.
Limitations
This article is a general educational overview based on publicly available information from the European Commission, the EU Cosmetics Regulation, NPRA guidelines and the published standards of the Leaping Bunny Program and the Vegan Society, as available in October 2026. It is not legal advice. Certification criteria, fees and market rules (particularly in China and other export markets) change, and should be confirmed with the scheme or regulator before a claim is printed. The ingredient table is illustrative, not exhaustive.
Sources
- European Commission. Ban on animal testing (cosmetics).
- European Union. Regulation (EC) No 1223/2009 on cosmetic products, Article 18.
- Leaping Bunny Program. Corporate Standard of Compassion for Animals.
- The Vegan Society. The Vegan Trademark.
- National Pharmaceutical Regulatory Agency (NPRA), Malaysia. Guidelines for Control of Cosmetic Products in Malaysia.
Creaton Poh is the pen name of Poh Tze Kheng, founder of ORIZI Group — one of Malaysia's most comprehensive one-stop OEM, ODM, private label and contract manufacturing groups, spanning skincare, cosmetics, personal care, perfume and fragrance, supplements, functional food and nutrition, pet care, home care and medical devices. Across six specialised companies and three manufacturing divisions, the Group brings together 20+ years of industry experience, 5,000+ formulations, and internationally recognised quality, manufacturing and regulatory standards. These articles are written to educate, not to promote.
Written by Creaton Poh
Industry Researcher • Author • Vlogger • Manufacturing Strategist
Turning ideas into products. Turning experience into knowledge.
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