In June 2007, the EU chemicals regulation REACH came into force. Thousands of long-existing chemicals - from turpentine to fabric dye, from machine oil to plasticizer - had to be tested for toxicity by 2018, mostly on animals. In the run-up to the negotiations, our NGO and our umbrella organization, the European Coalition to End Animal Experiments (ECEAE), campaigned intensively for REACH to avoid animal testing. Unfortunately, the EU missed this opportunity for a paradigm change, but at least the so-called 45-day rule was introduced thanks to our intervention.
Within the REACH regulation, chemical companies must register their chemicals at the EU authority ECHA and submit extensive information. This can be data that is either already available or obtained from new animal experiments. Planned animal experiments must be proposed to ECHA. ECHA then gives third parties the opportunity to find out whether the data is already available or can be determined by other methods than animal testing. This is done in a public advisory process. Third parties can comment on the testing proposals within 45 days.
We used this chance over a period of 8 years (2010 - 2018) to prevent as many animal experiments as possible.
REACH animal tests prevented
Around 139,497 rats, rabbits, and fish were saved from an agonizing death by poison by our REACH project, which we have been running together with our umbrella organization ECEAE since 2010.
As of March 2017, ECHA has published 1,557 test proposals for 905 substances for commenting. In cooperation with the ECEAE, our experts commented on 540 test proposals (35%). In at least 98 cases we were successful, i.e. the proposed animal tests were not carried out. As a result, tests on at least 103,427 animals could be prevented.
The test proposals include experiments like repeated dose toxicity in which rats are administered substances in the stomach every day for 90 days, developmental toxicity tests in which the substances are administered to pregnant rats to study the effect on the unborn offspring, and two-generation studies in which the chemicals are given to rat mothers, their children and grandchildren.
In the last phase in 2018, which dealt with the pending Extended One Generation Reproductive Toxicity Study (EOGRTS), further 17 animal studies could be prevented or modified, which saved 11,710 animals, mainly rats, from suffering and death. Overall, animal experiments on 115,137 animals could be prevented by commenting on the test proposals alone.
Tests on further 6,360 animals could be prevented by supporting appeal cases. Some companies opposed the ECHA requirements to conduct certain animal tests. We supported those companies and we were successful in at least four cases. For example, the Honeywell case, in which the company did not have to conduct an inhalation test on 120 rabbits after filing a complaint. We had provided the company with expert opinions and statements.
Years of intervention by our ECEAE scientists led to the EU removing the skin and eye irritation test on rabbits from REACH in May 2016. This cruel test, in which the substance is rubbed on rabbits' shaved back skin or into their eyes, was included in REACH, although non-animal test methods had been validated by the EU since 2009. The successful, though far too late, removal of the test from REACH will save around 18,000 rabbits suffering and death per year.
The fact that these cruel animal experiments could be omitted due to our expert work is a complete success!
Overall, we can look back on at least 139,497 rats, rabbits, and fish that were saved from animal testing thanks to our ambitious project.
Our REACH project was one of the rare opportunities where we knew about planned animal testing in advance and were able to prevent it. We would like to thank all members and donors who supported our very complex REACH project!
8th May 2023
Dr. med. vet. Corina Gericke