CIA and its members fully support the 3Rs principle (replacement, reduction, and refinement of animal tests). Our members are working to develop and validate non-animal testing methods.

Chemical regulations can require the testing of chemical substances on vertebrates to ensure safety of consumers, workers, and the environment. Many jurisdictions have therefore enshrined the 3Rs principle within their legislation to limit this, e.g. in both UK and Europe it is embedded within REACH (Registration, Evaluation, Authorisation and restriction of Chemicals), CLP (Classification, Labelling and Packaging) Regulations and in sectoral legislations.

Following publication in November 2024 by the Health and Safety Executive of guidance on minimising animal testing in UK-REACH, the government published a Strategy in November 2025 on ‘Replacing Animals in Science: A Strategy to Support the Development, Validation and Uptake of Alternative Methods’. A key objective of this is to raise awareness and increase the regulatory acceptance of New Approach Methodologies (NAMs). NAMs are any non-animal approach used on its own, or with others to demonstrate the safe use of a chemical substance.

With the publication of the UK Strategy, the opportunity is here now for the UK science community to be at the forefront and lead the way towards better testing strategies globally. The chemicals sector strongly encourages the UK government to maximise this prospect.

 

ACTIONS (for authorities):

·       Continue to develop and implement the UK Strategy on ‘Replacing Animals in Science’ for supporting the “Development, Validation and Uptake of Alternative Methods”.

·       ‘Champion’ the regulatory acceptance of NAMs by establishing an international programme beyond that of OECD, for validation and promotion of these with the aim of achieving multi-regulatory acceptance and use across all regulations. 

·       Promote the use of NAMs for demonstrating the safe use of a chemical substance through science, especially when evaluating grouping and read-across, or through adoption of novel risk-based Next Generation Risk Assessment (NGRA) approaches and Integrated Approaches for Testing and Assessment (IATA).

·       Support targeted pragmatic testing approaches, that ensure industry is not asked to conduct or repeat any animal test(s) where reliable data already exists (including through substance grouping or read across). Industry does not agree with a ‘tick box’ approach to fill data gaps, nor that (eco)toxicity testing/data needs should be linked to production/import volume as a proxy for exposure.

·       Request additional information that involves animal testing only when it is absolutely necessary, thereby adhering to the last resort principles enshrined by Articles 13 and 25 of UK/EU REACH.

For further information see our Position statement.

 

 

 

 

POLICY AREA: Chemicals Management

WEBSITE LOCATION: Our Asks

TITLE: Reducing and Refining the Reliance on Animal Testing in

Chemicals Regulation

CIA and its members fully support the 3Rs principle (replacement, reduction, and refinement

of animal tests). Our members are working to develop and validate non-animal testing

methods.

Chemical regulations can require the testing of chemical substances on vertebrates to

ensure safety of consumers, workers, and the environment. Many jurisdictions have

therefore enshrined the 3Rs principle within their legislation to limit this, e.g. in both UK and

Europe it is embedded within REACH (Registration, Evaluation, Authorisation and restriction

of Chemicals), CLP (Classification, Labelling and Packaging) Regulations and in sectoral

legislations.

Following publication in November 2024 by the Health and Safety Executive of guidance on

minimising animal testing in UK-REACH, the government published a Strategy in November

2025 on ‘Replacing Animals in Science: A Strategy to Support the Development, Validation

and Uptake of Alternative Methods’. A key objective of this is to raise awareness and

increase the regulatory acceptance of New Approach Methodologies (NAMs). NAMs are any

non-animal approach used on its own, or with others to demonstrate the safe use of a

chemical substance.

With the publication of the UK Strategy, the opportunity is here now for the UK science

community to be at the forefront and lead the way towards better testing strategies globally.

The chemicals sector strongly encourages the UK government to maximise this prospect.

ACTIONS (for authorities):

• Continue to develop and implement the UK Strategy on ‘Replacing Animals in Science’

for supporting the “Development, Validation and Uptake of Alternative Methods”.

• ‘Champion’ the regulatory acceptance of NAMs by establishing an international

programme beyond that of OECD, for validation and promotion of these with the aim of

achieving multi-regulatory acceptance and use across all regulations.
DRAFT

• Promote the use of NAMs for demonstrating the safe use of a chemical substance

through science, especially when evaluating grouping and read-across, or through

adoption of novel risk-based Next Generation Risk Assessment (NGRA) approaches

and Integrated Approaches for Testing and Assessment (IATA).

• Support targeted pragmatic testing approaches, that ensure industry is not asked to

conduct or repeat any animal test(s) where reliable data already exists (including

through substance grouping or read across). Industry does not agree with a ‘tick box’

approach to fill data gaps, nor that (eco)toxicity testing/data needs should be linked to

production/import volume as a proxy for exposure.

• Request additional information that involves animal testing only when it is absolutely

necessary, thereby adhering to the last resort principles enshrined by Articles 13 and 25

of UK/EU REACH.

For further information see our Position statement.

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