NAVS FDA Comments

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In addition to NAVS’ recent comments to the NIH, NAVS also submitted comments to the FDA in preparation for the 20th annual meeting of the International Cooperation on Cosmetics Regulation (ICCR), an international body that helps shape cosmetic safety policies and testing standards across major global markets.

This opportunity is important because ICCR plays a major role in determining how cosmetic ingredients are evaluated for safety and whether regulators continue relying on animal testing or transition toward modern, human-relevant scientific methods. Decisions and recommendations coming out of ICCR can influence regulatory policy, international standards, industry practices, and the global acceptance of non-animal approaches.

The goal of NAVS’ comment was to urge the FDA and ICCR to accelerate the transition away from animal testing and toward modern, animal-free cosmetic safety assessment frameworks grounded in human biology and advanced technologies.

In its comments, NAVS called on ICCR to:

  • Prioritize international standards that support non-animal and human-relevant testing approaches;
  • Expand recognition of emerging non-animal methodologies, including advanced in vitro systems, computational toxicology, artificial intelligence tools, and organ-on-a-chip technologies;
  • Encourage broader regulatory acceptance of next-generation risk assessment (NGRA), which uses human-relevant data instead of animal tests to assess ingredient safety;
  • Improve international coordination and transparency around acceptance of non-animal methods; and
  • Adopt a bold future vision centered on replacing animal testing for cosmetics altogether.

NAVS emphasized that modern non-animal methods are not simply “alternatives” to animal testing, but increasingly represent more scientifically predictive and human-relevant approaches to safety assessment. The comments urged ICCR to position itself as a global leader in advancing modern science while ending the use of animals in cosmetic testing.

NAVS will continue to push for change through our efforts in policy and advocacy and, together with your support and your voice, we will build a future where no animal is used in research or testing.

Read more about NAVS’ impact in policy and advocacy here.

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