TSB perspective
Two Questions to Keep in View
Within TSB’s framework, a vegan representation concerns animal-derived ingredients and processing aids within its stated scope. A cruelty-free representation concerns a defined animal-testing policy. Understanding one does not automatically resolve the other.
TSB considers relevant records for the particular claim, such as ingredient-origin information, records for compound ingredients, a testing policy, or a current certificate when certification is represented.
Sources: The Skincare Bureau: Our Standards
Read the Animal-Testing Policy
FDA’s guidance on “Cruelty-Free” and “Not Tested on Animals” explains that these terms do not have legal definitions in its U.S. cosmetic-labeling context. It describes differences in how companies may apply them, including whether a statement concerns a finished product, ingredients, or current testing.
That guidance makes the scope of a policy important. Ask what products, suppliers, entities, and testing arrangements the statement covers. An unanswered question is a reason to seek clarification, not proof that a claim is false.
A Certification Can Address More Than One Question
Some certification programs combine requirements. For example, The Vegan Society’s published Vegan Trademark standards address animal ingredients and animal testing under specified conditions. Its criteria explain the parties and activities covered.
Read the named program’s own current standard rather than assuming all vegan or cruelty-free marks have identical rules. Naming a program here is an educational example, not a statement of affiliation or an assessment of a particular brand.
Questions to ask
Questions for a Clearer Picture
When comparing statements, ask:
- What exactly is the claim, and what does it cover?
- Is there a named certification or a published brand policy?
- Is the specific product included in the current scope?
- Where can I read the criteria and any qualifications?
Sources & Further Reading
Sources checked September 26, 2026. Consult the linked source for its current wording and full scope.
- The Skincare BureauOur Standards
- FDA“Cruelty Free” / “Not Tested on Animals”
- The Vegan SocietyVegan Trademark Standards
