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…

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 (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.

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 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.

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.