Cruelty Free Europe

Cruelty Free Europe (CFE) thank the Commission for the opportunity to share our thoughts on the proposal of a Circular Economy Act (CEA) for the EU. CFE supports the CEA as we see the clear environmental and economic benefits that it will bring for the EU, and beyond. However, this comes with the caveat that we do not support new tests on live animals being performed as a result of this Act.

Cruelty Free Europe welcomes the opportunity to provide feedback on the European Commissions adopted act for the initiative Targeted revision of the EU rules for medical devices and in vitro diagnostics. We support the aim of this initiative to streamline and future-proof the regulatory framework for medical devices and in vitro devices.

Full feedback provided in the attached document. In their current form, Regulation (EU) 2017/745 on medical devices and Regulation (EU) 2017/746 on in vitro diagnostic medical devices lack sufficient clarity around pre-clinical testing requirements, in particular, tests needed for conformity with the general safety and performance requirements and marketing authorisation of medical devices which may involve the use…

Thank you for the opportunity to provide feedback on the proposed revisions to the EU general pharmaceuticals legislation. Cruelty Free Europe welcomes the provisions that support a shift away from testing on animals and towards greater use of non-animal methods this would advance many of the goals of the revision including addressing unmet medical needs, improving competitiveness, fostering innovation, improving…

Thank you for the opportunity to provide feedback on the proposed revisions to the EU general pharmaceuticals legislation. Cruelty Free Europe welcomes the provisions that support a shift away from testing on animals and towards greater use of non-animal methods this would advance many of the goals of the revision including addressing unmet medical needs, improving competitiveness, fostering innovation, improving…

To achieve the goal of safe and affordable medicines and to support the European pharmaceutical industry to innovate, the Commission must put humane and human-relevant preclinical assessment at the heart of this strategy. Currently 90% of drugs fail in clinical trials on humans despite having passed pre-clinical studies, including extensive tests in animals.

The proposal for a new European Biotech Act is perfectly placed to not only accelerate biotech products from laboratory-to-factory-to-market, but to also expedite the development of non-animal science, including test methods, for the protection of human health and the environment.

Cruelty Free Europe believes that the revision of the CLP Regulation in parallel with the Revision of REACH is an opportunity to bring animal testing to an end and move towards a modern EU regulatory system for chemicals based solely on non-animal methods. This would ensure better and more reliable information on chemicals for human health and the environment while ending cruel animal testing.

Cruelty Free Europe (CFE) thanks the European Commission for the opportunity to provide feedback on the Biotech Act II. We understand that plant protection products (PPPs) are being considered to fall under scope of this potential new Act.

Cruelty Free Europe sees the revision of REACH as an opportunity to move towards a modern EU regulatory system for chemicals based on non-animal methods. This would end the suffering of millions of animals and address citizens’ concerns while providing better information on chemicals for human health and the environment.

Cruelty Free Europe (CFE) thanks the European Commission for the opportunity to respond to this Call for Evidence on the Revision of the European Institute of Innovation and Technology (EIT) Regulation and of the Strategic Innovation Agenda.

Revision of the CPR could simplify the implementation of EU legislation applicable to chemicals. The Call for Evidence asks whether the CPR is internally consistent and whether it aligns with other chemicals legislation. The answer, certainly in relation to alignment of animal testing provisions, is clearly that it does not.

Cruelty Free Europe welcomes the European Commission’s initiative ‘Chemical safety – better access to chemicals data for safety assessments’ and is grateful for the opportunity to respond to the call for evidence. Please refer to the attached document for further details.

Revision of the GPSD is an excellent opportunity to demonstrate the EUs’ progressive stance on animal welfare, drawing on the experience of the intent of the animal testing bans in the Cosmetics Directive (7th amendment, in 2003).

Cruelty Free Europe supports closer alignment of EU agencies tasked with chemicals management, and the streamlining of substance assessments, in order to ensure a high level protection of human health and the environment. As part of these efforts, the avoidance of animal testing must be a common, shared goal across all agencies.

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.

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.

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 welcomes the opportunity to provide feedback on the draft Commission implementing regulation, laying down certain uniform quality management and procedural requirements for the conformity assessment activities carried out by a notified body designated under Regulations (EU) 2017/745 and (EU) 2017/746 of the European Parliament and of the Council.

CFE welcomes the opportunity to input into this call for evidence. The upcoming public consultation, targeted Member State consultation and stakeholder consultation must enable the evaluation of EFSAs performance specifically on the overall progress made towards the objective of the complete replacement of testing on animals.

Cruelty Free Europe thanks for the Commission for the opportunity to provide comments on the EU GLP Directives, an invaluable tool for ensuring the quality and reliability of data used for regulatory decision-making.