Cruelty-free certification for Indian cosmetics brands: the law, the programs and the paperwork

What Indian law says about animal testing of cosmetics

The ban arrived in two steps in 2014. In May, the Ministry of Health and Family Welfare amended the Drugs and Cosmetics Rules, 1945 with a new rule 148-C: “No person shall use any animal for testing of cosmetics” (G.S.R. 346(E), 21 May 2014). In October, a further amendment inserted rule 135-B, prohibiting the import of any cosmetic tested on animals after that amendment came into force, thirty days after publication (G.S.R. 718(E), 13 October 2014).

When cosmetics moved into a code of their own, the Cosmetics Rules, 2020 (G.S.R. 763(E), 15 December 2020), both prohibitions moved with them. Rule 39(7) repeats the testing ban word for word, and rule 18(4) provides that no cosmetic tested on animals after 12 November 2014 shall be imported into the country. The same rules build the point into paperwork: applicants for import registration and for a manufacturing license each sign an undertaking about animal testing.

What the law leaves open

The rules are prohibitions, backed by undertakings in licensing and import registration. They do not use the words “cruelty-free”, they create no mark, and they prescribe no file a brand would keep to prove the claim: no supplier-declaration format, no cut-off date policy, no audit of the claim. Rule 36's general bar on false or misleading claims applies to every claim on a cosmetic, this one included, so a cruelty-free line on a pack is worth being able to support.

The open questions sit in the supply chain and in the sales plan. Were the ingredients tested by a supplier, anywhere, for any market? From what date does the commitment run? Does the brand sell into markets whose regulators ask for animal data? Which products does the claim cover? The undertaking you signed for your license is a starting point for those answers, not the answers themselves. The law tells you what you may not do; a certificate shows a buyer what you did.

The programs open to an Indian brand

Cruelty Free International. For a brand headquartered in India, the Leaping Bunny route runs through Cruelty Free International: the Leaping Bunny program's own Company FAQ says CFI certifies companies headquartered outside the US and Canada. CFI's current program brochure, which calls the scheme the Cruelty Free International Approval Programme, lists its criteria: a fixed cut-off date after which no animal testing is permitted, examination of the supply chain down to ingredient level, annual independent audits, and the criteria applied across all markets. Its website lists the eligible categories as cosmetics and personal care, household and cleaning, and animal care.

PETA's Ultimate Cruelty-Free List. PETA relaunched its Beauty Without Bunnies list under this name on 1 July 2025, and a company must sell in one of its eligible regions, which include India, to be listed. A company submits a legally binding statement of assurance, signed by its CEO, that neither it nor its ingredient suppliers conduct, commission, pay for or allow tests on animals for ingredients, formulations or finished products anywhere in the world, now or in the future. It also files paperwork on how its products are tested, where they are sold and what they contain, and must hold agreements with its suppliers to the same effect.

V-Cert Cruelty-Free. A remote, document-based review built as a cosmetics add-on to vegan, so ingredient origin and testing policy are answered from one file. The mark's definition: No animal testing of the product or its ingredients after a dated cutoff, in the markets named on the certificate. The review reads supplier declarations for the ingredient grades you actually buy, a dated cut-off policy, and the markets you sell into, and the claim is scoped to the certified products, never the whole group.

How to choose: start from who is asking

• A buyer names a program. Use that program. A different mark does not meet a requirement written around a named scheme.
• You need audited assurance across every market. CFI's fixed cut-off, ingredient-level supply-chain checks and annual independent audits are built for that. How it compares with PETA's method is set out in Leaping Bunny vs PETA.
• You also make a vegan claim. Ingredient origin and testing policy draw on the same supplier file, so a review that covers both saves collecting it twice — see V-Cert Vegan.
• You sell into the EU. The wording you may print beside a logo there is its own question; the vegan and cruelty-free cosmetics guide covers the regulatory side.
• You are weighing cost. Published program fees and what drives a review's cost are on the cruelty-free cost page.

Preparing the file before you apply

Whichever program you choose, the work is mostly in your supply chain, and it is the same work. Gather it once:

• A formulation list by ingredient grade, naming the supplier of each grade you actually buy, not the trade name in a brochure.
• Supplier declarations on animal testing for each of those grades, signed and dated. Suppliers can be slow to return them, so send the requests first.
• A written cut-off policy with a date on it. A pledge without a date cannot be checked.
• A list of the markets you sell into, including through distributors, so any market whose regulator asks for animal data is visible before a reviewer finds it.
• The undertakings already on file in India for your manufacturing license or import registration. They show the legal baseline; the declarations above show the rest.

Cruelty-free is not the same as vegan

Cruelty-free is a testing claim; vegan is an ingredient claim. A lipstick can be untested and still contain carmine or beeswax, and an all-plant formula can still carry an ingredient tested somewhere in its history. If both are true of your products, say both, and have each one checked. Brands that also sell food or supplements will find the separate food-law picture in vegan certification in India.

Frequently asked questions