BLOG: ‘No-deal’ Brexit could result in duplicate animal tests! – Eva Pereira, Animal Justice Project Science Advisor


The UK government has recently published guidance for Chemical Regulation under the scenario in which the UK leaves the EU without agreement. The final outcome of such a scenario, and their failure to include any mention of the impact on animal testing, has revived the concern of some Animal Rights Non-Governmental Organisations about the possible increase in animal tests duplicating experiments unnecessarily.

The government notice of 24 September 2018 sets out how businesses producing, registering, importing or exporting chemicals would be affected if the UK leaves the EU in March 2019 with no deal.

The UK chemicals industry is currently regulated through a framework largely based on EU legislation. The European Chemicals Agency (ECHA) is the leading body in implementing this framework. The main piece of legislation is REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals). REACH requires EU companies to register chemicals with ECHA before placing them on the market and puts in place additional regulatory controls on hazardous chemicals.

The registration of new chemical substances with ECHA requires developing hazard assessments of the substances. That affects the performance of numerous animal tests, including procedures classified as moderate or severe by the European Animal Directive (DIRECTIVE 2010/63/EU). Despite ECHA’s commitment to reduce animal experiments when alternative methods are available, acute toxicity tests (oral, inhalation and dermal), irritation and corrosion (skin and eye), repeated dose toxicity, genetic toxicity, toxicity to reproduction, fertility or development, and carcinogenicity experiments performed on different species of vertebrates are in many cases mandatory for a successful registration of new compounds.

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After March 2019, if there is no deal, the Health and Safety Executive (HSE) would deliver the functions currently performed by ECHA and would act as the leading UK regulatory authority. The recent government notice claims that the legislation would preserve REACH as far as possible, while making technical changes that would need to be made because the UK has left the EU.

In a ‘no deal’ scenario, the UK would not be legally committed to medium- or long-term regulatory alignment with the EEA. The government explains that “if a business wished to place new chemicals on both the EEA and UK markets, in a ‘no deal’ scenario, they would have to make two separate registrations, one to ECHA and one to the UK” and recognise that “the information and data package needed would be the same for both”.

Cruelty free International (CFI) states that “if EU animal-test data is not shared with the UK, then the same animal tests would have to be carried out again by the UK for the same information”.

CFI Director of Science and Regulatory Affairs, Dr Katy Taylor, says: “We are deeply concerned that what could be used as a unique opportunity to move the country away from cruel and unnecessary animal testing and toward modern, humane alternatives, will instead lead to an increase in chemical tests on animals. We urge the UK government to use this moment in history to stop unnecessary animal experiments and do what it can to prevent the needless suffering of animals in UK laboratories”.

Since 2016, the National Anti-Vivisection Society (NAVS) has also repeatedly expressed their concern about the effects of Brexit negotiations on animal research and is working to ensure their protection. In a collaborative work published by the Association of Lawyers for Animal Welfare (A-LAW) and Wildlife and Countryside Link, the NAVS outlines “how animal experiment standards should NOT be rolled back following Brexit, and opportunities to advance more human and scientifically relevant non-animal methods”.

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In summary, under the no-deal scenario exposed by the UK government, the performance of two separate registrations for each chemical substance could mean the unnecessary duplication of cruel and painful animal tests for both regulatory authorities. This would be completely at odds with both ECHA’s and the UK government Home Office’s commitment to reducing unnecessary animal experiments.

Animal Justice Project advocates the abolition of animal breeding, and the abolition of the use of animals in all forms of research and within educational institutions. We are opposed to animal experiments on moral and also scientific grounds. We adhere to the petition of the mentioned NGO and urge the UK government and the EU to give a clear commitment to stop animal experiments and under no circumstances increase or duplicate the number of experiments performed.

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