Consultation participation and their own register declarations, side by side. Counts, not judgments — participation is not influence.
Counts here are a floor, never a total: they cover the 583 consultation files tracked so far (42,224 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
Register facts self-declared (snapshot 2 Sept 2026); cost bands are floors. Shared files are shared attention, not evidence of coordination.
What each said, in their own words
Their opening passages on the files they share, verbatim and in filing order. We do not summarize, compare, or characterize positions — read them at source.
Animal testing for cosmetic products is still required in some cases by ECHA. According to a recent study, 63 ingredients used solely in cosmetic products have been tested on animals after the Cosmetic Regulation ban on in vivo testing. As the intention of legislators and of EU citizens aimed to ensure that animal testing for cosmetic products is banned completely, this review should close the gaps (i.p.
The revision of the CPR provides an opportunity to ensure that cosmetics and their ingredients are not tested on animals. Cruelty Free Europe is disappointed to see that the initiative does not aim to protect and strengthen the animal testing bans, for which there is overwhelming public and political support.
Care should be taken to increase the acceptance of non-animal research methods for safety testing and to reduce animal testing. The wording of the laws must be clear and there must be no loopholes. Particularly in the field of testing endocrine disruptors, mixtures and polymers, care must be taken not to increase animal testing.
Filed in German · English published by the European Commission
The need to use non-animal methods to the maximum possible extent and to transition away from testing on animals is clear. ECHA is very well placed to make valuable contributions to these efforts; the tasks and structures of ECHA must be fit for purpose.
Cruelty Free Europe thank the Commission for the opportunity to provide a second round of feedback on the proposal for an ECHA Basic Regulation, following the publication of the proposed text. ECHA is perfectly positioned at the interface of chemical safety and the advancement of regulatory toxicity testing to play a pivotal role in Europes transition away from the use of animals in science.
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