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BUAV disappointed in chemicals agency treatment of animal testing proposals


The Agency responsible for the EU chemicals legislation REACH, the European Chemicals Agency (ECHA) has issued its annual evaluation report which gives an update on the decisions it has made on proposals to test on animals. 

The BUAV, together with our partners in the European Coalition to End Animal Experiments (ECEAE), have committed resources to comment on these testing proposals under the ‘third party commenting’ facility on the ECHA website. We search for additional information or scientific justifications that may mean that the test does not need to be done. We have been monitoring the decisions made by the Agency and have raised our concerns with them about how the process is being conducted. 

We are dismayed at the limited approach the Agency has taken to its responsibility under the testing proposals system. Legal advice received by the ECEAE is clear that REACH requires the Agency itself to consider whether a non-animal approach could be taken instead. Indeed, this is what the Agency’s own published guidance says. However, the Agency is now backtracking on the guidance and thereby misleading the public:  

So far, none of the third-party information received has given grounds for ECHA itself to reject a testing proposal directly. It is the registrant who, after obtaining the relevant information, determines if the suggested approach can be scientifically justified and whether the information requirements can be met by such an approach.

As a consequence of this approach, the report confirms that the Agency hardly ever rejects testing proposals. In this year’s report ECHA says it has made decisions on 171 tests. 130 were agreed, 40 were modified and only 1 was rejected. No testing proposals were rejected in previous years. 

However, in 84 cases (33% of cases that are now closed or finalised), companies withdrew their testing proposal before ECHA could make a decision. In some cases this was due to comments made by third parties. Unfortunately, it is not always clear to the Agency or the ECEAE if our comments contributed to the withdrawal. The report does give some examples of where comments were used to avoid animal testing. We will be investigating if these can be attributed to us and will continue to ask the Agency to improve its approach.

We were alarmed at the bizarre and unexplained claim that by asking for more animal tests, ECHA is in some way contributing to the replacement of animal testing. 

The testing proposals now agreed with ECHA will generate much more data on substances, which registrants and scientists may be able to use in the future – thereby increasing the potential for developing alternatives to animal testing.”