The Humane Cosmetics Standard audit process

The Humane Cosmetics Standard
The European Coalition to
End Animal Experiments

ECEAE
APPROVED
Page 2 HCS Final Version 1.0 July 2008
Contents
Section 1 …….Introduction and background to the Standard……………………… 3
Section 2 …….Summary of approval process and procedures……………………. 5
Section 3 …….Independent assessment approach…………………………………...6
Section 4 …….Humane Cosmetics Standard criteria - (‘The Standard’)…………..8
Section 5 …….Definitions…………………………………………………………………. 9
Section 6 …….Cruelty free flow chart…………………………………………………... 13
Section 7 …….The ‘Rabbit and Stars’ (Leaping Bunny) Logo……………………… 14
Section 8 …….Guidance notes…………………………………………………………… 15
Section 9 …….The Forms
…………………HCS Application Form
…………………Declaration of product compliance
…………………Declaration of raw material compliance
………………... Auditor checklist
Appendix 1…..Cruelty free flow chart

ECEAE
APPROVED
Section 1
Introduction and background to the Standard
Companies sign up to the standard by
providing information on their suppliers,
products and ingredients. The HCS has
been in use since 1996. It is the most
comprehensive standard a company can
adhere to in terms of removing animal
testing from its supply chain, as it operates
at an ingredient level.
The standard requires a company to:
No longer conduct or commission
animal testing
Apply a company fixed cut-off date (a
date after which none of your products
or ingredients have been animal
tested)
Be open to an independent audit
throughout your supply chain
Adhere to your animal testing policy
The Standard was developed by an
international coalition of animal protection
groups from across the European Union
and North America, including
European Coalition to End Animal
Experiments (ECEAE)
Coalition for Consumer Information on
Cosmetics (CCIC).
In the UK the Standard is managed by the
British Union for the Abolition of Vivisection
(BUAV). The BUAV also acts as secretariat
for the ECEAE.
1. What is the Humane Cosmetics Standard (HCS)?
The HCS is the only internationally recognised scheme that enables
consumers to easily identify and purchase cosmetic and toiletry products
that have not been tested on animals.

ECEAE
APPROVED
Section 1
Introduction and background to the Standard
2. This document
This document is for:
1. New companies who wish to apply
for approval or existing partner
companies requiring any further
information about the Standard.
2. Independent assessors - for
review of auditing requirements
and a copy of the checklist to be
used during a company audit.
3. ECEAE group members for
distribution to companies in their
own countries who wish to join the
Standard.
It includes the following forms:
1. Application Form – to be
completed and returned for
approval
2. Product Declaration Form*- to
detail each product within a com-
pany’s own label range
3. Raw Material Declaration Form* –
to be copied and completed by
each supplier to the company
applying for approval – this
document requests the date that
the ingredient was last tested on
animals, so that the company may
assess this date in accordance with
their own Fixed Cut-Off Date and
ensure the ingredient is compliant
with the HCS.
4. Auditor Checklist – for use by the
auditor and for reference by a
company applying for approval, to
see how the audit is performed.

ECEAE
APPROVED
Section 2
Summary of application and approval process
1. Collection of Information
The company applying for approval
collects all raw ingredient and product
information from their suppliers using
the forms provided. Application forms
should only be submitted for approval
after all information has been
obtained.
2 Processing Applications
Applications are reviewed on receipt
for all appropriate information. Where
necessary, additional information may
be sought from the company.
3 Company Approval
Companies that are approved will be
issued with notification of approval and
a contract to sign. We also provide
advice and discuss marketing and
promotional opportunities, working
with each company individually to
provide a complete service to help
launch the HCS.
4 Logo
Formal approval under the Standard will
be issued by the ECEAE. A copy of the
logo will be made available to the
approved company. Further guidance on
logo use can be found in Section 7 of
this document.
5 Independent Assessment - The Audit
Within six months of being granted
approval, the company’s Supplier
Monitoring System must be open to
independent assessment by a suitably
qualified auditor. An audit will take place
within 12 months of approval.
The auditor conducts the assessment
and sends the report to the company.
The company considers the results of
the assessment and implements new
procedures as necessary. If such
procedural changes are fundamental,
the company will be required to undergo
re-assessment. A copy of the auditor’s
report should then be sent to the ECEAE
member group. See Section 3 for
further information.
6 Renewal
Approval may be renewed on an annual
basis on the condition that the company
continues to meet the Standard’s criteria
for animal testing and its terms and
conditions.
A company may also wish to consider
gathering this information via their
purchase order system. In this case,
we request that any statements or
text to be used on Purchase Orders
should be sent to us for review and
approval.

ECEAE
APPROVED
The audit visit typically lasts up to 1 day at
the company premises (i.e. possibly just a
morning or afternoon depending on
company size).
The inspection will include:
interviews with staff
review of the supplier monitoring
system
review of declarations and forms
if applicable, a review of any on site
manufacturing or laboratory premises.
Again, depending on the company, we are
always prepared to arrange the audit but
some may wish to appoint an auditor
themselves and we can arrange to
incorporate the audit into a company’s
current auditing system.
Full guidance, information and an agenda
explaining the details of the audit are
always sent to the company well in advance
of the audit date (which is also mutually
agreed in advance with the company).
The company will have the opportunity to
consider the results of the audit and
implement new procedures if necessary,
before the report is sent to the ECEAE
member group.
It should be emphasised that the audit,
whilst of course ensuring that a company
remains compliant with the standard, is
designed to help companies with any
supplier monitoring issues and answer any
questions they may have on managing the
Standard. Any findings or recommenda-
tions will be positively highlighted with full
guidance and assistance for future best
practice implementation.
The Auditor’s Checklist should be used to
perform the assessment (see page 19).
Section 3
Independent assessment approach - the audit
A suitably qualified auditor will conduct the independent assessment in strictest
confidence.
The audit is designed to
help companies with any supplier
monitoring issues and answer any
questions they may have on
managing the Standard.

ECEAE
APPROVED
i) A company’s Supplier Monitoring
System must be open to an
independent audit within six months of
the company gaining approval under
the Standard.
The audit will be carried out within 12
months of gaining approval and then
at least once every three years
thereafter.
ii) The audit evaluates compliance with
the Standard and ensures that a
company has effective policies and
procedures in place to monitor its
manufacturers and suppliers. This will
involve inspection of documentation
relating to the animal testing of
products and/or ingredients, and how
the company uses the monitoring
system to ensure that animal tested
ingredients are not used. This may be
a simple or a more complicated
system, depending on the size and
structure of the company.
iii) The assessment will be conducted
with professional confidentiality using
the Standard’s Independent
Assessment Approach and Auditor
Checklist.. Results will be the property
of the company but the assessor must
forward a report to the ECEAE to
confirm that the company continues to
meet the Standard’s criteria. Where a
breach of the criteria is found, the
company and auditor must notify the
ECEAE, by providing full details and
all relevant data and information
concerning the breach. The ECEAE
will then work with the company to
remedy the breach and provide
guidance on solutions available, to
ensure the company’s continued
approval under the Standard.
iv) A company that currently operates a
Supplier Monitoring System or other
quality assurance procedures should
contact us to discuss how the
Standard’s auditing requirements can
be incorporated into its current
approach.
Section 3
Independent assessment approach - the audit
The audit involves
inspection of documentation
relating to the
animal testing of products
and/or ingredients, and how the
company uses the monitoring
system to ensure that
animal tested
ingredients are not used.

ECEAE
APPROVED
Section 4
Humane Cosmetics Standard Criteria -
(“the Standard”)
Criteria for non-animal tested cosmetic and toiletry products
(Please refer to Section 5 – Definitions)
1. A company2
must not (now, or in the
future) conduct, commission3
, or be a
party to animal testing5
of any cosmetic
product including, without limitation,
formulations and ingredients7
of such
products. No animal testing of the
finished product or any individual
ingredient is permitted, regardless of
whether the testing was conducted by
the company seeking approval, the
ingredient supplier, third party
manufacturer or any other third party
commissioned so to do.
2. A company must not purchase any
formulation, ingredient or product from
any third party manufacturer8
or
supplier9, 10
that has conducted,
commissioned or been party to animal
testing for cosmetic purposes6
on
them after the company’s fixed cut-off
date11
.
3. A company must implement a supplier
monitoring system12
to ensure that
ingredients and products meet the
Standard’s criteria, and the supplier
monitoring system must be open to an
independent audit.
4. A company must obtain declarations of
product and raw material
compliance13
(or equivalent
documents), from each of its third
party manufacturers and suppliers.
This information will be kept as part of
the company’s supplier monitoring
system.

ECEAE
APPROVED
Section 5
Definitions
Ref no Terminology Definition under the Standard
1 Cosmetic A ‘cosmetic product’ shall mean any substance or preparation
intended to be placed in contact with the various external parts of the
human body (epidermis, hair system, nails, lips and external genital
organs) or with teeth and the mucous membranes of the oral cavity with
a view to exclusively or mainly to cleaning them, perfuming them,
changing their appearance and/or correcting body odours and/or
protecting them or keeping them in good condition.
2 Company Legal entity (Limited liability company/Sole Trader/Partnership/Other
entity recognised by the law) involved in selling Cosmetic/Toiletry
products under its own name.
3 Commission Where a Company requests a Third Party Manufacturer and /or
Ingredient Supplier, other company in the group or contract
testing laboratory to conduct Animal Testing.
4 Animal An animal is defined as it is under the Great Britain Animal (Scientific
Procedures) Act 1986:1) Subject to the provisions of this section, "a
protected animal" for the purposes of this Act means any living
vertebrate other than man and any invertebrate of the species Octopus
vulgaris from the stage of its development when it becomes capable of
independent feeding. (2) Any such vertebrate in its foetal, larval or em-
bryonic form is a protected animal only from the stage of its
development when - (a) in the case of a mammal, bird or reptile, half the
gestation or incubation period for the relevant species has elapsed; and
(b) in any other case, it becomes capable of independent feeding. *Also
included under this definition are cyclostomes (hagfish), cephalopods
(octupi and squid) and decapod crustaceans (lobsters, crabs and
prawns) as well as their foetal and larval forms, as recommended by
AHAW (Panel on Animal Health and Welfare) on behalf of the EFSA
(European Food Standards Agency) in their opinion on the animals that
should also be included in the revision of the European Directive
relating to laboratory animals (86/609/EEC). (The EFSA Journal (2005)
292, 1-46 - Opinion on the “Aspects of the biology and welfare of ani-
mals used for experimental and other scientific purposes”).
*Please note - it is acknowledged that the additional species listed here
do not relate to testing under the requirements of the HCS. However,
they are included to be consistent with the general BUAV definition of
an animal.

ECEAE
APPROVED
5 Animal
Testing
An experiment (defined in European Directive 86/609) “any use of an
animal for experimental or other scientific purposes which may cause
pain, suffering, distress or lasting harm….”
6 Animal
Testing for
Cosmetics Pur-
poses
Animal Testing within your supply chain of an Ingredient for use in a
Cosmetic Product (irrespective of whether the Cosmetic Product is
the Company’s or a third party’s) or where the ingredient was, in prac-
tice, first used in cosmetics.
Animal Testing within your supply chain of an Ingredient where the
testing was not specifically carried out for use in a Cosmetic Product
but where the Ingredient is in practice used more in Cosmetic Prod-
ucts than otherwise (50% or more used).
7 Ingredient Also referred to as a compound/raw material/additive*. Can be a single
substance or mixture of substances, intended for use in Cosmetic/
Toiletry products, as listed on the product label. Fragrance products
and ingredients should also be included in this definition. *An additive is
any substance which has been added to a raw material or mixture of
materials which does not contribute to the function of the compound/
ingredient in the product. These include preservatives, stabilisers and
diluents.
8 Manufacturer A manufacturer that supplies directly, through an agent or third party
any finished cosmetic products to or on behalf of the Company seeking
approval under the Standard.
9 Direct
Supplier
Any supplier that supplies directly finished Cosmetic/Toiletry products
that may or may not manufacture those products.
10 Ingredient Sup-
plier
Any ingredient manufacturer that supplies directly, through an agent or
third party, any ingredient or ingredient mixture, used in the formulation
of cosmetic products. This includes the original manufacturer of the
ingredient, the supplier who sells directly to the company and all
intermediaries.
11 Fixed Cut-off
Date
A date after which a Company, its Third Party Manufacturers and/or
Suppliers must not have conducted or commissioned Animal Testing
for the Company’s own-label Cosmetics Products and/or Ingredients
supplied for use in the Company’s products. The Company must also
not purchase any Ingredient on which any of its suppliers have
commissioned or conducted animal tests for Cosmetic Product pur-
poses after the Company’s Fixed Cut-off Date. The Company may
choose its own Fixed Cut-off Date, which must be before the date of
the Company’s application to join the Standard and it must be fixed
and consistently applied throughout its entire Cosmetic Product range,
now and in the future.
Section 5
Definitions

ECEAE
APPROVED
12 Supplier
Monitoring
System (SMS)
A system by which a Company monitors its Third Party
Manufacturers and Suppliers at least once a year (unless otherwise
agreed) to ensure that they have not conducted or commissioned
Animal Testing (tracing back to the original Manufacturer of the
Product and/or Ingredient). The system need not be complicated, but
it must be effective and open to an independent audit. Suppliers to be
monitored must include the original manufacturer of the Ingredient. A
company may also wish to include its FCOD on its purchase order
system to ensure the information is automatically gathered from
suppliers when purchasing new ingredients. A Company must not
use in its products any Ingredients that have been animal tested for
cosmetic product purposes by their suppliers or third party
manufacturers since the companies fixed cut-off date, even if the testing
was not commissioned by the company seeking approval. Agents or
Distributors may not sign the Declaration of Product/Raw Material
Compliance.
Exemption from implementing a Supplier Monitoring System
Only a company that manufactures products for which they grow all of
their own ingredients, or who purchase all ingredients from growers of
natural agricultural ingredients would be exempt. For example, the
manufacturers may grow herbs and flowers, and may purchase
bananas from a greengrocer. However, if the company uses ingredients
such as essential oils, stabilisers, preservatives or other additives that
are supplied by an ingredient manufacturer, they must indicate on the
application form that they do use suppliers. Companies who do not use
suppliers for any ingredients should confirm in writing that this is the
case.
13 Declaration of
Product/Raw
Material
Compliance
Written confirmation obtained by a Company once a year from all its
Third Party Manufacturers and Suppliers that they have not
performed Animal Testing for the Company’s products and
ingredients after the Company Fixed Cut Off Date. These
documents form part of the Company’s Supplier Monitoring System.
Equivalent documents may be used on the condition that they provide
at least the information requested on the Declarations.
Section 5
Definitions

ECEAE
APPROVED
14 Vegetarian For any company wishing to have their products declared as
Vegetarian, we ask that the Vegetarian Society definition is used:
A vegetarian product must not contain any of the following:
• Animal flesh (meat, fowl, fish or shellfish)
• Meat, fish or bone
• Animal carcass fats
• Gelatine, aspic, gelatine based block or jelly crystals
• Battery or intensively produced eggs.
• Royal Jelly
(Please note: vegetarian ingredients are not compulsory under the
HCS but companies are very welcome to declare them- see Section 8
for further information)
15 Vegan For any company wishing to have their products declared as Vegan, we
ask that the Vegan Society definition is used.
The manufacture and/or development of the product, and where
applicable its ingredients, must not involve, or have involved, the use of
any animal product, by-product or derivative. Vegan products are, as far
as is possible and practical, free from all animal ingredients, such as
meat, animal milks, eggs, honey, leather, wool and silk .
(Please note: vegan ingredients are not compulsory under the HCS but
companies are very welcome to declare them- see Section 8 for further
information)
16 Independent
Audit
An assessment of a Company’s Supplier Monitoring System.
17 Gross Annual
Sales
Gross annual sales apply to a Company’s own-label range of
Cosmetics and Toiletries.
18 Purchase
Order
A document used by a company to purchase products or
ingredients. A company may wish to include their FCOD and
policy prohibiting the purchase/use of animal tested ingredients
on this document to alert suppliers. In this case, we request that any
statements or text to be used on Purchase Orders should be sent to us
for review and approval.
Section 5
Definitions

ECEAE
APPROVED
Section 6
Cruelty Free Flow Chart
Please refer to Appendix 2 at the end of this document.
This flow chart has been developed to help companies through the process of assessing
ingredients suitable for use under the HCS. It should be repeated for each existing
ingredient a company uses when applying for approval AND for each new ingredient they
wish to add thereafter.
If you have any questions or need advice, please contact the ECEAE. Please also refer
to the definitions section above for further clarification.

ECEAE
APPROVED
Section 7
The ‘Rabbit and Stars’ (Leaping Bunny) Logo
The Standard logo (‘the Logo’) is set out in
Annex 3 and is registered as a trademark in
the European Union and the United States
and Canada.
i) The Company may, on a non-
exclusive basis, apply the Logo to
corporate communications materials
(including those used in advertising
and point of sales) (‘the materials’)
and product packaging in the territory
provided that the materials and
packaging relate solely to the products
meeting the Standard.
ii) The Logo is to be used in a
combination of its official colours
(Pantone 2728 and black) wherever
possible. It is also acceptable to
reproduce it in one of these colours
alone or reproduce the logo in a single
colour reversed out. There should be
sufficient contrast between the
background and the Logo to ensure its
legibility.
iii) No alteration or addition is to be made
to the Logo.
iv) No drawing, symbol or words other
than “BUAV approved”; “ECEAE ap-
proved”;” Approved by [ECEAE
member organisation]”, e.g. “Approved
by BUAV”, “Approved by EDEV”; or
“Approved under the Humane Cos-
metics Standard”) is to be placed on or
adjacent to the Logo so as to suggest
that such drawing, symbol or words
are part of or associated with the
Logo, unless the written consent of the
Coalition is first obtained.
v) In this clause, ‘territory’ means
European Union, the United States of
America and Canada. The Coalition
may, on written application by the
Company, extend the territory on such
terms as it thinks fit.
vi) On termination of the agreement the
Company may no longer use the Logo
except to the extent necessary to
enable it to sell or otherwise dispose
of all stocks of the products then in its
possession (subject to a maximum
period of 90 days).
Rabbit and Stars (Leaping Bunny) logo for use only by
companies approved under the Humane Cosmetics Standard.

ECEAE
APPROVED
Section 8
Guidance Notes
Vegetarian/Vegan Products &
Ingredients (Please refer to Section 5)
We welcome vegetarian and vegan
products under the Standard; however this
is not mandatory for approval under the
Standard.
These questions are included on the
declaration forms as an optional extra if
companies wish to provide this information
and be indicated on the Go Cruelty Free
website and Little Book of Cruelty Free as a
vegan or vegetarian company.
This can also prove a useful marketing
advantage for companies wishing to
promote their products to shoppers who
particularly seek vegetarian or vegan items.
(Please note: an entire range must be
declared vegan or vegetarian in order to be
indicated as such on the GCF website, to
avoid confusion to consumers.)
Product range approval
A Company must apply for approval to join
the Standard for its entire own label range
of Cosmetic Products. Individual products or
lines within a range cannot be approved as
this causes confusion for consumers and
conveys misleading information about the
standard.
The Standard works on the basis that a
company applies for approval in their own
country but are then approved worldwide.
Any companies who wish to apply for
approval in countries that do not currently
operate the HCS would be reviewed and
approved by the BUAV. Also, approval is
given on the basis of global accreditation
(For example, a company based in Holland
would go through the approval process
there but would be approved worldwide if its
products were available in other countries.)
Go Cruelty Free website and The Little
Book of Cruelty Free
Upon approval, a company has full rights to
use of the Rabbit and Stars (Leaping Bunny
Logo ) and will be added to the Go Cruelty
Free Website and Little Book of Cruelty
Free.
The Little Book of Cruelty Free is produced
for the UK - similar marketing materials may
apply in the country of the company
application and approval. Similarly,
websites profiling approved companies may
also operate in each country.

Appendix 1
Cruelty Free Flow Chart
ECEAE
APPROVED
Appendix 1 – Cruelty Free Flow Chart Page 1 of 1 HCS Final Version 1.0 July 2008
N
Has the ingredient ever been tested on
animals ?Please contact your supplier(s)
for this information.
Do you know the date that this ingredient
was last tested on animals?
Is this date AFTER your company FCOD?
Y
Y
Y
N
Please
contact
your
supplier(s)
for this
information.
N
The ingredient cannot
be included in your
products. Are you
willing/able to
withdraw this
ingredient or
reformulate/withdraw
the product?
Is the ingredient used
50% or more in the
cosmetics industry?
Please contact your
supplier(s) for this
information
Was the ingredient
FIRST USED in a
cosmetics product
after it was animal
tested? Please contact
your supplier(s) for this
information.
Your company CAN be
approved under the HCS
IS this the final ingredient
you need to check? If NO,
please return to START
and repeat for each
ingredient
The ingredient CAN be
used-please continue
below.
Your company cannot be
approved under the HCS
Y
Y
N
N
Y
Y Y
N
Was the ingredient tested on animals after
your FCOD for cosmetics purposes?
Please contact your supplier(s) for this
information.

ECEAE
APPROVED
For more information on the Humane Cosmetics Standard, please contact your local group
operating the Standard, or alternatively:
Cruelty Free Officer
ECEAE
16a Crane Grove
London
N7 8NN
United Kingdom
Telephone: +44 (0) 20 7700 4888
Facsimile: +44 (0) 20 7700 0252
Email: gocrueltyfree@buav.org
Website: www.gocrueltyfree.org

The Humane Cosmetics Standard audit process

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