Misc

All the questions you wanted to ask about the Leaping Bunny program!
Leaping Bunny is known as the gold standard of cruelty free beauty lists. They certify cruelty free brands, and they’re the ones behind the jumping bunny logo you have probably seen on your favorite beauty and cleaning brands. You can see a full list of Leaping Bunny certified cruelty free brands here.

Recently I interviewed a senior VP from PETA to learn more about their methods. I wanted to compare and contrast a bit and learn more about how Leaping Bunny differs from PETA, so I interviewed Kim Paschen, the Program Manager for Leaping Bunny to find out more about how they certify brands, and what their stance is on China and post-market testing.
In my interview, I included the questions you guys wanted me to ask, as well as some questions of my own. Whether you’re a cruelty free consumer or a brand who is wondering how to get certified with Leaping Bunny, this should help.
Kim Paschen works for the American Anti Vivisection Society. As part of the CCIC, they have been chair of the Leaping Bunny program since 2007, and they oversee its administration. Kim is the Program Manager for Leaping Bunny.
I conducted a phone interview with Kim (who I have known for years!) and these are my notes from that call (not her words verbatim).

Kim Paschen, Program Manager, Leaping Bunny
Which organizations make up Leaping Bunny? 
By 1996, cruelty-free shopping had become popular, but it was also confusing, sometimes misleading, and ultimately frustrating. Companies had begun designing their own bunny logos, using their own definition of ‘cruelty-free’ or ‘animal friendly’ without the participation of animal protection groups.
In response, eight national animal protection groups banded together to form the Coalition for Consumer Information on Cosmetics (CCIC). The CCIC promotes a cruelty-free standard and an internationally recognized Leaping Bunny Logo. They work with companies to help make shopping for animal-friendly products easier and more trustworthy.
What does a brand have to do to become Leaping Bunny certified?
When a brand contacts Leaping Bunny, they ask some preliminary questions. They create an account via their website and ask them to apply. The company fills out the Application for Approval which asks them in-depth questions about their operations.
Brands need to have a “fixed cut-off date” after which time they agree to have no ingredients or finished products that have been tested on animals. Pretty much all ingredients have been tested at some point (even water), so the fixed cut-off date ensures there will be no testing in the future.
You’d think because many ingredients have been tested, there would be no need for animal testing today. Unfortunately, there is still a lot of cosmetic testing on animals being done around the world today.
The company that is applying for Leaping Bunny certification is the one to complete the application. They also must get signed declarations from each supplier after the company’s fixed cut-off date. Or, they can submit amended purchase orders which contains language requiring that the supplier will not test on animals.
If a company has distributors that sell in countries outside of the US, the brand must also include language in their contracts that says they cannot sell to any countries that require animal testing.
I have read their application but they asked me not to make it public. I can tell you it’s VERY thorough. You can learn more about the application process here. You can read about their Corporate Standard of Compassion for Animals here.
An important note – if a brand is using a third-party manufacturer, only the manufacturer has to submit a declaration (not the ingredient suppliers themselves), though the manufacturer is required to implement its own cruelty-free Supplier Monitoring System independently. Leaping Bunny would ask the manufacturer to sign a declaration saying they are only working with cruelty free ingredient suppliers. Most of the time manufacturers will not reveal who their ingredient suppliers are – they consider that proprietary information.
Is the Leaping Bunny logo recognized in countries outside of the US? Are the standards for approval different outside of the US?
The North American brand of Leaping Bunny covers US and Canada. Their partner is Cruelty Free International (CFI), based in the UK. CFI certifies all other countries. Leaping Bunny and CFI share the same cruelty free brand list, so if CFI certifies a brand, they can add them to their list and vice versa.
Do brands pay to join the Leaping Bunny program or to license the logo? If so, how does that work? 
Leaping Bunny certification in North America is free. Companies do not have to pay to be listed as cruelty free. The only cost associated is for brands to license the logo for packaging and/or website. 
But, Leaping Bunny certification outside of North America (via Cruelty Free International) DOES have an annual listing/administrative charge.

Does the EU’s animal testing (because of REACH laws) have any effect on the Leaping Bunny list?
The particularities are slightly different in regard to CFI’s process in the UK and EU vs Leaping Bunny’s process in North America. Safety rules (such as the EU’s REACH laws) can mean that some EU ingredient suppliers are being forced to test on animals. Leaping Bunny doesn’t allow REACH tests for North America but CFI does have some exceptions. More and more chemicals used in cosmetics are being tested under REACH, and there is currently no way to avoid it.
Their shared goal is to do as much research as possible and find alternatives to chemicals tested under REACH. So if an ingredient supplier (who makes raw materials) has never tested on animals, but REACH required one test, that could be an exception for CFI. This is not common and doesn’t happen often.
Important food for thought: As I often say, the world of cruelty free beauty is never black and white. If an ingredient supplier in the EU is forced to test on animals, a cruelty free brand and their manufacturer might not even know about it! That brand might even be a US brand (the supply chain is becoming more and more global). Another caveat is that one ingredient supplier may be asked to test a chemical on animals, and other suppliers may use that safety data going forward. They didn’t conduct the test but they used the data…so are they innocent? You can read more about how murky the definition of cruelty free can get here.
Is there a specific number of years required for a fixed cut-off date for animal testing by ingredient suppliers? What about for brands (i.e. if a non-cruelty free brand stopped testing TODAY, how long would you want them to wait before applying)? 
There is no specific timeline, but a fixed cut off date for animal testing is required. There is no waiting period, so if a brand said their fixed cut off date was today, they could potentially be Leaping Bunny certified tomorrow. But Kim said that doesn’t happen often.
How is the Leaping Bunny cruelty free brand list different from the PETA brand list?
They require companies to recommit annually. They check with each brand and if info is not up to date then the brands can’t stay on the list. They also do in-person audits to 20 random companies each year using a third-party auditor (more on this below).
Do you note if a brand is vegan? Is there any specific requirements to be listed as vegan?
No, they do not mention if a brand is 100% vegan or not, and it is not required for Leaping Bunny certification.

Do you note if the parent company is cruelty free or not?
Yes, when you view the list of Leaping Bunny certified brands, you will see a symbol to note if a parent company is not cruelty free.
Are companies required to recommit each year? 
Once a year, brands have to go through the recommitment process. The Leaping Bunny team re-checks their status and looks for things like being acquired by another company, selling in China, changing or adding ingredient suppliers or manufacturers, etc. If anything changes, new declarations are required.
How often do you audit brands? What does an audit entail?
They do in-person audits to 20 random companies each year using a third-party auditor (who is an independent consultant). They make sure purchase orders and records correspond to manufacturers and suppliers that they have declarations for. The auditor meets with the brand to discuss China, parent companies, supply chains, etc – making sure what is in the system is correct and hasn’t changed.
How do you assure that brands are not conducting pre-market and post-market testing when entering China?
Currently, the North American arm of Leaping Bunny does not allow companies to sell in mainland China (except via cross border e-commerce – which is not regulated by the Chinese government – no registration or tests are required). It’s important to note that pre-market animal testing requirements for imported goods in China continues to be a big problem. But, we discussed and agreed that post-market testing on animals just isn’t happening. Kim also agreed that in the event of a complaint, a recall is more likely than animal testing.
However, all that being said, CFI (the UK arm that approves Leaping Bunny applications for the UK and EU) started a Leaping Bunny pilot program for EU brands to sell in China. It includes a small handful of brands such as Bulldog Skincare, 7th Heaven, Brighter Beauty and Neal’s Yard Remedies. The companies in that program are able to bottle and/or manufacture their finished products in China and are selling non-special-use cosmetics (using the same standards as PETA).

My final thoughts
I think most people will agree that Leaping Bunny is truly the gold standard, and the best cruelty free list out there. They go the extra mile to make sure brands are cruelty free, and they re-check every year.
But, there is no way for the Leaping Bunny list or ANY cruelty free list (including mine) to be 100% airtight. It’s just not possible. Ultimately, we all have to take what the brand representatives say at their word. Whoever is filling out the questionnaires could be ignorant or even lying. Just as an example, I’ve had so many brands tell me they are Leaping Bunny certified, and when I go to the site to check, they aren’t listed. I’ve talked to a lot of people in the beauty industry and it seems that everyone wants to believe their brand is cruelty free (even if it’s not).
At some point though, you just have to rely on the brands being honest and truthful (and knowing what their ingredient suppliers are doing), and there have to be repercussions for the ones who are caught lying.
Exceptions also have to be made for government laws because at this time, there is really no way around it. That is why I have changed my views on post-market testing in China. I have learned that they are not so different from Western laws (including REACH laws in the EU). You can read more about that here.
We just need to keep being LOUD and telling brands that we want them to pledge to go cruelty free! I can tell you that a lot has changed since I started this cruelty free blog in 2009. There is a lot more interest in cruelty free cosmetics from consumers and that has made brands take notice. More