What Cruelty-Free Skincare Really Means in Private Label Skincare?
As interest in cruelty-free skincare continues to grow, more brands are asking an important question: Can private label skincare products truly be cruelty-free in 2026?
The answer is not as simple as yes or no.
In private label skincare manufacturing, cruelty-free claims depend on the sourcing of ingredients, the structure of the supply chain, and cosmetic regulations. At the same time, terms like cruelty-free, vegan, and sustainable are often used together, even though they have different meanings.
From a manufacturer’s perspective, cruelty-free skincare is possible—but only when it is clearly defined and honestly communicated. This article explains what cruelty-free skincare really means, why these claims can be complicated, and how CALLA realistically supports cruelty-free private label projects.
What Does Cruelty-Free Skincare Really Mean in Private Label Manufacturing?
How Cruelty-Free Skincare Is Commonly Defined
In the skincare industry, cruelty-free skincare typically refers to skincare products that are not tested on animals. In some cases, it also includes avoiding animal testing during ingredient development.
However, in private label manufacturing, cruelty-free claims are primarily based on current testing practices, rather than the comprehensive testing history of every ingredient.
Many skincare ingredients were developed years ago, long before the current standards for cruelty-free products were established. As a result, guarantees are often unrealistic.
Cruelty-Free vs. Vegan Skincare
A common misunderstanding in cruelty-free skincare is confusing it with vegan skincare.
These two terms are different:
l Cruelty-free refers to how products are tested and developed.
l Vegan skincare refers to whether the ingredients are derived from animal sources.
A product can be cruelty-free without being vegan, and it can be vegan without being cruelty-free. For private label brands, understanding this difference helps avoid incorrect product claims.
Regulatory Standards and Market Differences
Animal testing regulations vary from country to country.
In markets such as the European Union, animal testing for cosmetic products and ingredients is prohibited by law. This strongly influences how cruelty-free skincare is developed and manufactured.
However, regulatory compliance does not mean that every ingredient has a complete cruelty-free testing history. It means that products meet current legal requirements.
Why Cruelty-Free Skincare Claims Are Complex in Today’s Supply Chain
The Role of Raw Material Suppliers
Most private label cruelty-free skincare brands don’t produce their own raw materials. Instead, they partner with third-party ingredient suppliers.
These ingredients can originate from various regions and may have been supplied by different companies over time. As a result, manufacturers typically depend on supplier statements and regulatory compliance documentation rather than complete historical records.
Why Ingredient-Level Cruelty-Free Certificates Are Hard to Obtain
Many ingredient suppliers follow modern cosmetic regulations and do not perform new animal testing. However, formal cruelty-free certificates are not always available for every ingredient.
This is a common practice in cruelty-free skincare manufacturing, reflecting how global supply chains operate. It does not necessarily mean that animal testing is happening today.
Manufacturers usually evaluate ingredients based on supplier communication, regulatory alignment, and internal quality control.
The Limits of Third-Party Certifications
Third-party certifications can support cruelty-free skincare claims, but they do not cover everything.
Some certifications apply only to finished products, certain regions, or specific production steps. They may not reflect the complete ingredient supply chain.
For this reason, responsible cruelty-free positioning often depends on more than one factor, rather than relying solely on a single logo or certificate.
Can Private Label Cruelty-Free Skincare Be Achieved in 2026?
What Manufacturers Can Control
In private label cruelty-free skincare, manufacturers hold the most control over the final product. They can guarantee that:
l The finished products are not tested on animals
l Manufacturing complies with current cosmetic regulations
However, control at the ingredient level is more restricted due to reliance on suppliers and ingredient history. Recognizing this distinction is crucial when assessing cruelty-free claims.
The Role of Regulations
Regulations play a key role in cruelty-free skincare manufacturing.
In regions where animal testing is restricted or prohibited, manufacturers must adhere to stringent testing and safety regulations. These regulations govern the formulation, testing, and documentation of products.
Rather than offering absolute promises, responsible manufacturers focus on regulatory compliance and realistic standards.
What Responsible Sourcing Means in Practice
Responsible sourcing in private label cruelty-free skincare involves:
l Collaborating with suppliers that adhere to modern cosmetic regulations
l Utilizing available documentation and declarations
l Avoiding unnecessary testing practices
It also requires being honest about supply chain limitations and maintaining transparent communication with brand partners.
How CALLA Approaches Cruelty-Free Skincare Manufacturing
CALLA does not conduct animal testing on finished skincare products. Manufacturing follows applicable cosmetic regulations in target markets, including the EU and California.
For raw materials, CALLA reviews available supplier compliance information and evaluates ingredient sourcing in accordance with current regulatory requirements. Claims are made according to what can be realistically supported.
Supporting Responsible Cruelty-Free Claims
CALLA works with brands to define cruelty-free skincare claims based on how products are actually manufactured today.
This involves helping brands determine which cruelty-free statements are suitable for their formulations, ingredients, and target markets. CALLA reviews ingredient considerations, explains the scope of cruelty-free and vegan claims, and supports clear, compliant packaging and marketing language.
The focus is not on broad promises, but on claims that brands can confidently stand behind.
Transparency and Communication
CALLA maintains open communication throughout each project. Brands are informed of relevant regulatory updates and sourcing considerations, and questions about cruelty-free requirements are addressed clearly and promptly.
