R.E.A.C.H or The Bunny Gets It!

Lush Cosmetics

Written by Cari Steel

I’m sure that all our our wonderful Amelia’s Magazine readers have got a viewpoint on animal testing being conducted for cosmetic products. And I would like to think that the viewpoint is that it is JUST PLAIN WRONG! (Seriously, what other viewpoint is there?!) I don’t know about you, but I have been under the illusion that we were all in agreement about this, and so were the suits behind all legislations that decided upon animal testing. Apparently I was wrong. Because R.E.A.C.H had got there first. Under this law ( also known as Registration, Evaluation, Authorisation and Restriction of Chemicals), many more animal tests are taking place as the scientists try to work out which chemicals can harm us. Alarmingly, these include chemicals found in cosmetics and toiletries.

Having found out that one of my favourite brands, Lush, have been campaigning heavily against this, I spoke with Andrew Butler, Lush’s Campaign Manager at Lush H.Q to find out more about this situation.

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Andrew, I can’t get my head around this.

“This whole R.E.A.C.H thing is horribly convoluted situation, and a lot of people don’t know about it. R.E.A.C.H is already a reality, people have been fighting it for years, but it went through, largely because its something that people didn’t fully understand, It has been too complicated for the media to follow. R.E.A.C.H affects all products. It is a piece of legislation that is about 10 years in the making, and here’s the backround: consumer and health organisations were concerned that there were chemicals on the market that were potentially harmful, either through direct contact or consumers, or via the environment, and concerned that things were getting into the soil or the water, and getting into food chain or affecting wildlife. The kind of concerns in question were if the substance was an irritant, or carcinogenic, or a endocrine disruptor, – i.e it upset the hormonal balance. and so R.E.A.C.H was designed to be a catch all, and pull together all the diverse different bodies that dealt with chemicals in Europe into one central body and pull together existing information and fill in any blanks that there may be, and this was why R.E.A.C.H came to pass.”

But it sounds laudable, in theory?

“Absolutely, we should be ensuring that dangerous chemicals are not in the marketplace, and anything that is either cancer causing or disruptive of hormone systems should be heavily restricted or banned. But it is the way that the data is collected, and the sorts of data is used to ascertain whether something is safe or not. . And that was something that was not asked of the people who proposed the legislation. The groups were concerned about the chemicals, but not necessarily how the safety would be assessed. Traditional toxicology and eco toxicology involves animal tests, and that has always been the case. Pretty much everything that you can imagine from the carpet under your feet to the painting on the walls has been tested on animals somewhere by someone. Almost everything has been through a lethal dose 50 test which is where a group of animals is force fed a substance until 50% of them die. Its something that is done for virtually everything.

Companies who are concerned with safety testing but also don’t want to use animals have been concerned with the ingredients so there are various mechanism that companies can put in place so animal testing is not used. They can set a cut off date after which ingredients are not tested on animals, or they won’t do business with companies that are testing on animals. There are grave questions about the validity of animal testing, not just the ethics. The animal testing data is not really applicable to people.

As R.E.A.C.H was being developed there was pressure to not rely on animal test data. We ran a campaign in our stores, we collected postcards to MEPS urging them to not rely on animal tests under R.E.A.C.H, we collected 85,000 of those and sent them to MEPS. Many groups, such as Animal Aid and PETA were also campaigning against R.E.A.C.H. In the six years that the legislation was being passed, there were provisions put in place. For example, if animal test data already existed for a particular ingredient, that should be used in place of any new data. So provisions were put in place to minimise it, but not do away with it entirely. ”

I’m sure we already know it, but what is Lush’s stand on animal testing?

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Lush goes into the stocks

“For us as a company, we have an objection to animal testing – both because it isn’t ethical to inflict suffering and kill animals in order to assess safety, and we don’t believe that animal tests will result in accurate info, we feel that the animal test data is inconclusive. Generally speaking, animal tests offer an accuracy rate of 40%, whereas the non animal tests are accurate 70- 80%. We are opposed to animal tests being mandatory in R.E.A.C.H. We need to ensure safety without suffering, with modern, non animal testing methods that will give us much more accurate results. ”

When did R.E.A.C.H come into effect, and what kind of ingredients are being tested?

“The legislation passed in 2007, and it has been implemented over the last couple of years. R.E.A.C.H legislation presides over anything that has undergone a chemical process – so e.g. a lavender flower isn’t included, but lavender essential oil would be considered a chemical, because it has undergone a chemical process. Anyone manufacturing or importanting any material in Europe that is over a tone of materials have to register it to R.E.A.C.H, and collectively, almost everything comes under these guidelines. And the deadline for this was December 2008 and the European Chemicals Agency were meant to have sift through all of these registrations, come up with a final list and set deadlines for the testing to be done. 140,000 materials need to be tested and be given safety information. If the data doesn’t exist, animal testing needs to be done. There is a huge degree of uncertainty – how much of that data already exists? How much animal testing needs to be done? Potentially, millions of animal experiments will need to be done. And it tends to be the more natural substances, like essential oils that don’t have all of the data. They are the ones who are going to end up being having to have their products tested; this will be done against their will.”

This is all so bleak! Is there a possibility of a positive outcome?

“We are struggling at the moment, because of the degree of uncertainty. But there is a silver lining. There is the European Cosmetics Directive, which came into force on March 11th 2009, it is an amendment to the cosmetics directive. It says that you cannot test any ingredients for cosmetics on animals in Europe. You can’t even market a product in Europe containing ingredients that have been tested on animals anywhere in the world. So on the one hand you have this, and on the other, you have R.E.A.C.H. ”

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Before the last draft of R.E.A.C.H was passed, Lush paid a visit with a manure truck

So which one gets the say so on testing?

“That is a good question! It’s something that has to be tested in court. The whole cosmetics industry sees that there is clearly a conflict. What we need is for more companies to stand up and start questioning this, and to get the British Government to stand up and say that we are questioning this. So our campaign right now is awareness raising. R.E.A.C.H spells the end to cruelty free cosmetics. So if you care about this, you need to be aware of this, you need to start talking about this, and you need to ask other companies what they are doing about this. What are the British Government doing about this? They stood up in 1998 and said no more animal testing. Well they have signed us up to the biggest animal testing programme in Europe’s history, what’s that all about? Lush can engage corporate disobedience, and refuse to toe the line but thats not enough, if everyone is complying with R.E.A.C.H then animal testing will still go ahead. It needs to be collective. And the British public need to get involved too!”

Is there information readily available in Lush stores about this?

“Until the end of Easter there is information in all the stores, it’s being run as an in store campaign. The aim after Easter is to get a more comprehensive leaflet that will be available if you ask for it. There is also always going to be information on our website (www.lush.co.uk/reachout/ ) We are hoping to produce letters to MP’s and other companies, specifically about this issue.”

How has the feedback been from your Lush customers?

“We have had a really strong response. We have run plenty of campaigns about packaging, shark finning, human rights in Guantanamo, all sorts of things and this is one of the strongest customer responses, people have been shocked – they had no idea that this was happening. A lot of the responses have been that this is contrary to my rights, this should be going through the European Human Rights Courts because it should be my right to say, no I am not going to be alright with animal testing.

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Information booth outside Lush

R.E.A.C.H is a law, there is not one particular thing that you can do to stop it, but if we do lots of things; if we at least start talking about this, and get large companies to stand up and say that we are not happy about this situation, then we stand a chance.”

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One Response to “R.E.A.C.H or The Bunny Gets It!”

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