cruelty-free: some comments (5)

UPDATE (2014-05): see also

Continuing along from comments (4), with thanks to Anna for her comments on this post about the Urban Decay débâcle which generated this post. Which started out as a very lengthy comment in reply to her first comment; then I thought, no, that’s not a comment but a post—and let’s not drive the poor girl cross-eyed—then discussion continued so if you’ve been following comments on here, sorry, you’ve already seen the links and main gist of argument…

On the different rules for Hong Kong and China.

You may recall, assorted bits of broohaha over the last three months: testing MAY be required by the Chinese authorities in order for imported products to be sold in China (depending, some discretion, outside control of manufaturers or their selling agents). The ethical issue: washing hands of your responsibility for your goods once you decide to sell them in China. (Mind you, the same is true, but with slightly more transparency—very slightly—in other jurisdictions such as Japan and the USA.)

Hong Kong: such testing IS NOT required. Goods sold there ARE NOT subject to the same laws.

Hence: if a product is sold in Hong Kong, that DOES NOT MEAN that it’s been tested on animals (technically, remember also: the fact that a product is sold in China doesn’t automatically mean it’s been tested either). It IS possible for a product (and indeed a whole brand) to be sold in Hong Kong, but not China. And if that’s the case, that product, brand, and the company behind them WOULD still be cruelty-free. M’kay???

Very briefly (LOL, famous last words). Specialist lawyers please do send in any further information, especially those of you who read Chinese, which I don’t. Alas.

While Hong Kong is part of China, they have a special status (Macao ditto) and certain differences including legislative ones. Products sold in Hong Kong are subject to different regulations (and very few of them) from those sold in mainland China. They are NOT subject to the Chemical Inspection and Regulation Service and their requirement for the Registration of Imported Cosmetics in China. They are only subject to the Hong Kong Department of Justice’s Ordinances, to Chapter 456: Consumer Goods Safety Ordinance. That is: skincare & cosmetics (and other beautification products) are NOT treated as special sorts of product and subject to special regulations on them: they are treated as general consumer goods.

Hong Kong’s special status = Special Administrative Region, as a free port, a duty-free free-trade zone (the 2003 CEPA, etc.). More on the status of HK in any reference source: government sources, Wikipedia (and links there), Encyclopedia Britannica, other reference works, etc., etc., etc.

On the free trade / freedom from Chinese import legislation side:

  • helping US companies export
  • Hong Kong Industry Profiles
  • 3.2 Regulations
    Cosmetics and skincare products in Hong Kong are governed by Chapter 456 Consumer Goods Safety Ordinance. It is required that a person shall not supply, manufacture or import consumer goods unless the goods comply with the general safety requirement for consumer goods, or the goods must meet the approved standard if applicable. (
    There are no strict regulations imposed on the import of cosmetics and skincare products in Hong Kong. No import licence is required.
    (see also the rest of that New Zealand Trade and Enterprise document)
  • HK Gov Dept of Justice link, Ch. 456 of the Consumer Goods Ordinance is also available in PDF. I read through this, and there is no reference to animal testing. Which isn’t unexpected: as beautification products are being treated as general consumer goods in, I emphasize again, a free port.
  • Goods–any goods– can be seized and subjected to further testing: this is mainly for general safety provisions (ex. a bottle of whisky clearly has shards of glass in it), trade descriptions (labels are misspelled or inaccurate: ex. whisky claiming to be only 10% alc/vol), and to prevent very obvious frauds (whisky spelled with three wwws, contents are blue).
  • It’s a free port: this means more freedoms all round, including greater risks for consumers. Caveat emptor central. There’s an element of gambling. Not inappropriate, given that the special free trade zones of Hong Kong and Macao are also major gambling economies (and cultures).
  • there’s more to go through there too, if you want to do some serious legwork (comparative law getting some idea of how the system works as a whole, etc.). Same at the Hong Kong Customs & Excise Department site: though just expanding the menu items on the left there gives you some idea of what their special status entails.

Let me reiterate: Products sold in Hong Kong DO NOT have to be tested on animals.

This is precisely why The Body Shop sells there but not in mainland China. That and the fact they had shops there when HK was still a British crown colony, before sovereignty was restored to China in 1997.

Covered briefly on here on 2012-03-27; please, O gentle best-beloved readers all: next time don’t “wonder” and let that lead you into worry and vicious circles, stress and anger and fear of conspiracy. It’s not good for your mood, health, sanity, peace of mind, happiness. Next time, don’t “worry” and wallow in ignorance, fear, distrust, and anger. Sally forth on a quest for knowledge. Go and Google. The information above wasn’t from a “far and wide” search, just the very first page of what seemed to me to be the obvious search, a simple Google search: such as “hong kong cosmetic regulation” Admittedly, research is a major integral part of my job, so what seems like an obvious search to me might not be to a non-professional (re)searcher: still, if you start typing in “hong kong cosm” this is what Google suggests. Again, though, this might turn out the same for someone else. Google hints are based on your previous usage. So the more Googling you do, the more searching experience you have under your belt, the more Google’s been able to learn from you and how your searching-mind ticks, and the better those hints get. (With apologies to Google for oversimplifying matters massively.)

That loophole on third-party testing: actually, if a company has signed up to any of the European (national and EU-wide) and international certification programmes on cruelty-free-ness, that is included. This was one of the reasons precisely why these international coalitions against animal cruelty were set up in the first place…

In February 2035 New Year celebrations, retired testing-lab workers dance in the streets, their lab-coats cleverly adapted into rabbit costumes. This refers symbolically to an old practice, now long-discontinued and barely remembered, of testing products on animals. How bizarre, quaint, and pointless! We can laugh at such old-fashioned barbarism: we are old-fashioned but in the way of civilization; and we are also modern, progressive, and world leaders for the 21st century.

Dear Chinese government: the next Year of the Rabbit is 2023. Stopping animal testing by then would be fab. That leaping bunny symbol? Is ideally adapted for cultural translation:

The Rabbit is well known for its ability to attract good fortune and be lucky. Most rabbit people are also great at solving problems and situations. Many well known Chinese politicians and diplomats belong to the Rabbit. Another aspect of this Chinese Horoscope sign reveals tendency to cultural activities and the arts. Most rabbit people hate fighting and engaging in aggressive behaviors or activities because of its peaceful nature, but due to the environmental actions of manipulation and corruption, they are willing stand their ground to defend what is peaceful and justified.

(thank you Wikipedia)

and it’s a water hare year, so one should add:

intelligence and wisdom, flexibility, softness and pliancy

(thanks again, Big W)


  1. anna3101

    Thanks for the post, but please don’t be so harsh on me. I stopped using google some time ago because of their controversial politics and my current search engine does not make suggestions. And I have to admit it did not occur to me to think about cosmetic regulations… I searched around “tested on animals”, “testing on animals” etc.

    • gingerama

      OK, I see your point and think I might understand some of it. It’s a free online world (for us, anyway), and your decision not to use (*cough*) the best-made search-engine in existence. I do mean that in all seriousness:
      1. algorithms used (and constant research and refinement and development and evolution thereof);
      2. other information c/o serious nerd friends who work / have worked for Google and other companies;
      3. and through my own work using search-engines: not just looking stuff up in my spare time but in paid work, including checking and counter-checking results, use of Google Scholar and Google Books, and collaborative work with the project-team on Google Translate.

      So hey, I’m prejudiced.

      Suggestions: compromise. See, if you’ll excuse my saying so, I have to say your approach sounds to me kinda sorta like cutting off one’s nose to spite one’s face, throwing out the baby with the bath-water, etc.
      1. on some of “the politics”: read more than the first five results, or indeed the first page. This is true of all search-engines. I’ve done that with Google for many years, from even before when the top hits got dominated by placed ones (and before Google knocked out the use of meta-tags in websites; you might remember, about 10 years ago that did–for a short while–increase ranking but not for long, heheh).
      2. use at least one alternative too
      3. use more than one search-engine, at least once a week or so, for a search-query to which you know the answer: I do this to check if any of the other search-engines are improving. Because much as I know and love Google, I’m neither a True Believer nor any other sort of credulous twerp, and see no reason why other search-engines might not catch up and overtake. This happened to browsers, after all.
      4. object to the sponsored links, ad-placement, and market dominance? Well, this is the real world. People need to make a living. If you’re a tech company, you’ve got to employ good techies, you’ve got to pay them a decent salary and provide them with decent working conditions: you’re going yo have to make money to do that. Google’s managing to do that whilst still providing a free public service, and open access to knowledge.

      But: I admit I have many a qualm and niggle about how Google (and other companies) have dealt with less salubrious countries with contrary ideas about free open knowledge (and human and animal rights). I say it’s too early to tell; this kind of politics is history rather than fashion; it moves slowly, and I don’t think we’re going to be in a position to judge whether Google had done the right thing for at least another couple of decades.

      Actually, the same may be true of The Body Shop and Urban Decay. We’ll have the usual problems later, of course. By the usual problems, I mean the arrogant presumption of superior clear-sightedness that always comes with hindsight: discussion of contrafactuals (could things have been done differently at the time?), dissection of motives, intentions, intended purposes, perceived consequences.

      I think the best we may be able to do right now is to leave a record that, at this time, people were asking questions and raising issues. And (I do this, anyway) talking to anyone they know involved with such companies (ex. Google), spreading the word on these concerns.

      • anna3101

        Actually, the search engine I’m now into uses google’s algorithms – it just doesn’t give away my ip and prevents the annoying ads from being annoyingly personalized ads.

        The recent privacy politics, their relationship with China and other things like that do not encourage me to use their services. But I’m actually glad I gave up my gmail – it made me look for alternatives and I found a lot of interesting stuff I would never find otherwise.

        And although I have to admit google is very good as a search engine, it is not the best for everything. Best for English-language results, yes, but when I’m looking for something in my native language, Yandex wins each and every round.

        PS I know I’m not supposed to complain when getting something for free. The thing is, however, I’m starting to have enough of “free”. I’m willing to pay for certain services that are of utter importance to me, if paying would mean no ads, no gathering of my private information and selling it to third parties without even informing me and so on. I really like it how my email service is organized: you are getting basic features for free and then, if you like it and have money to pay for it, you can have a much better version with bigger storage etc. I wish more companies would use the same model…

        • gingerama

          Fair enough. And I completely see your point about Yandex vs. Google: I’m using it for various European languages, but not Slavic ones or others from further afar.

          This is I think a good thing too, as it
          (1) forces megacorps to recognize that there’s a big world out there, outside the USA;
          (2) they see that world is bigger than the USA (and indeed than the monoglot Anglophone world);
          (3) they see that most of the world uses other languages, uses at least 2-3 languages in everyday life, and English is as best the second of these.
          And I don’t see Google doing what might seem like the obvious thing to some people, buying Yandex up, anytime soon. Not at all: same for Baidu. Clash of the titans: a post-colonial posthegemonic world vs. cultural, linguistic, information, and commercial/consumerist imperialism. Interesting times.

          On your PS: I came to the same conclusion when I started blogging, which was long before this blog here: work-related real-life stuff which I can’t talk about here (but is completely unrelated to beautification). Henc why I’m on WordPress and pay to be ad-free; rather than being on Blogger, which looks nicer than it is in many respects. I used to use Blogger before it was taken over by Google, and it was in the process of that takeover that it went downhill. That is: downhill in my very individual estimation, and for my purposes. Who knows, maybe it’s improved life for people who want to buy and sell things online. But that’s not what I’m interested in, nor why I’ve been into online stuff for the last 20-odd years.

          Ooops, getting dirstracted from this blog’s business… Thank you for talking about olive oil earlier: I’ve been experimenting with it as I hadn’t for a long time, so I though: “let’s be properly scientific and experiment.” Great all over, so far so good 🙂

          • anna3101

            I’m glad you like it. I never used it for skin care myself but it’s my everything in cooking. I love olive oil 🙂

    • gingerama

      also: off-topic (but hey, it’s my blog and I can do what I want here): you were talking about olive oil, a while and a few womments back: just wanted to say that inspired me, I’ve been experimenting with it! Extra-virgin, the usual cooking stuff.

      I’d used EVOO for ages on my hair (fabulous): at least, off and on for years, and recently, I’ve used it before washing almost every wash. I’d tried it elswhere on my skin before, and got greasiness and breakouts. But I was thinking: that was *years* ago, and my skin’s changed since. It’s now drier, for starters. So I’ve been experimenting with EVOO.

      So far so good, will post more once I feel I’ve been experimenting with it for long enough. Much as I love meadowfoam, I’m a stingy sort of person and if two items works as well on me, I would always rather buy whichever one is cheaper (as well as ticking other environmental and otherwise ethical boxes).

      Just thought I’d pass that one along: thanks for reminding me, back when!!!

  2. Sakara

    You seen the latest? Urban Decay have withdrawn their proposed plans to sell in China. What ever the reason for their change of heart, i’m glad they have.

      • Sakara

        haha great timing! Good news at least. I keep hearing that Two Faced are selling to China, but for the life of me i can’t find any actual written evidence of this. I want to check so i can edit one of my posts and whether they are or not. Sent them a direct question asking as much, so hope to hear back.

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