Cruelty-free and vegan are two different claims, and neither is automatically protected by law in NZ or Australia. "Cruelty-free" means no animal testing of the product or its ingredients; "vegan" means no animal-derived ingredients. Third-party certification (such as Leaping Bunny for cruelty-free, or a vegan trademark) is how you prove either claim to customers and retailers.
At The INCI Lab we formulate cruelty-free and vegan products every week, and the most common thing we see is founders using both words on a label before they can back them up. This guide explains what each claim means in practice, where NZ and Australian law stops, and how certification fits into your formulation timeline.
What is the difference between cruelty-free and vegan skincare?
They answer different questions. Cruelty-free is about testing: was the finished product, or any ingredient in it, tested on animals by you, your suppliers or anyone acting for you? Vegan is about composition: does the formula contain anything from an animal, such as beeswax, lanolin, carmine, honey, silk or collagen?
A product can be one without the other. A beeswax balm can be cruelty-free but not vegan. A vegan formula can use an ingredient that a supplier tested on animals for another industry, so it is not automatically cruelty-free. Treat them as two separate claims, each needing its own evidence.
Is animal testing for cosmetics banned in New Zealand?
Partly. New Zealand amended the Animal Welfare Act 1999 in 2015 to ban animal testing of finished cosmetic products within the country. Advocacy groups note two gaps: the ban does not stop imported products tested overseas from being sold here, and it applies to ingredients used only in cosmetics, not those also used in things like medicines or cleaning products.
So a product being sold legally in NZ says nothing on its own about how its ingredients were tested elsewhere.
Is animal testing for cosmetics banned in Australia?
Australia restricts it under the Industrial Chemicals Act 2019, which limits reliance on animal test data for chemicals used only in cosmetics. The RSPCA points out a multi-use exception: an ingredient also used in non-cosmetic products can still be tested on animals. A voluntary industry code of practice on "not tested on animals" claims has also been introduced to bring consistency to advertising, and it recognises Leaping Bunny as good-practice labelling.
Because the law has these gaps, a "cruelty-free" claim is a promise about your supply chain, not just your own lab. Note that under Australian Consumer Law and NZ's Fair Trading Act, claims must be true and not misleading, so it pays to hold evidence before you print.
How do you back up a cruelty-free claim?
The credible route is a supplier-level declaration for every raw material, gathered before launch. In practice that means:
- A written statement from each ingredient supplier that they do not test, and do not commission testing, on animals for cosmetic use.
- A fixed cut-off date policy so you can show the claim holds over time.
- Certification such as Leaping Bunny if you want an independent logo retailers and shoppers recognise. Programmes assess your whole supply chain and typically involve their own fees and audits, so check the current requirements with the certifier.
Because we hold the supplier paperwork as part of formulation, this evidence trail can be built into your project from day one instead of chased after launch. Our Accelerator and Visionary pathways both include ingredient documentation.
How does vegan certification work in NZ and Australia?
Vegan trademarks are run by organisations such as the NZ Vegetarian Society, the Australian Vegan Society and the UK Vegan Society. The NZ Vegetarian Society's Vegan Certified trademark requires animal-free ingredients, no cross-contamination during production and no animal testing commissioned or conducted, and lists an initial application fee of NZ$250 at the time of writing. Fees and criteria change, so confirm on the certifier's site.
The step that trips up brands is the ingredient list itself. Hidden animal derivatives appear in emulsifiers, glycerin, squalane, vitamin D3 and some colours. We check each raw material's source, so your INCI list and supplier evidence line up before you apply.
What does it mean for your formulation and timeline?
Choosing vegan and cruelty-free early is far cheaper than retrofitting. It narrows ingredient choices slightly, but modern plant-derived emulsifiers, waxes and actives cover almost every product type. Building it in at the brief stage adds little to timelines: an Accelerator project runs 4 to 6 months and a Visionary project 9 to 12 months, with certification paperwork prepared alongside stability and compliance work.
If your brand also wants to sell into other markets, we prepare compliance documentation for NZ, Australia (including AICIS obligations), the EU and the US. Batches start from an MOQ of 100 to 500 units, and you receive full IP transfer before manufacturing. Not sure where to begin? Ask The Chemist is a 30 minute consult for NZ$150, and our services overview shows all four pathways.
Frequently asked questions
Can I say "cruelty-free" without certification?
Yes, but you need evidence to support it. Certification is not legally required in NZ or Australia, though claims must not be misleading. Supplier declarations are the minimum; a third-party logo adds trust.
Is a vegan product automatically cruelty-free?
No. Vegan refers to ingredient origin, while cruelty-free refers to testing. An ingredient can be plant-derived yet still have been tested on animals by a supplier.
Does an NZ or Australian ban mean my imported ingredients are animal-test free?
Not necessarily. Both countries' rules have gaps for imported products and multi-use ingredients, so supplier evidence matters.
Is beeswax vegan?
No. Beeswax, honey, lanolin and carmine are animal-derived. Plant waxes such as candelilla or sunflower wax are common vegan swaps.
Can The INCI Lab formulate vegan and cruelty-free products?
Yes. We are a cruelty-free formulation studio and build vegan formulas with documented ingredient sources, supporting brands across NZ and Australia.
How much does certification cost?
It varies by scheme and company size. One NZ vegan trademark lists an NZ$250 initial application fee; other programmes charge differently, so always check the current fee schedule directly.
This article is general information, not legal advice. Check current requirements with the relevant certifier or regulator before making label claims.
