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How to become Endorsed by Naturewatch Foundation

A step by step guide for companies that wish to adopt a Fixed Cut-Off Date (FCOD) Animal Testing Policy.

The Fixed Cut-Off Date Animal Testing Policy is recognised as the benchmark for cruelty-free cosmetics/toiletries and household cleaning products.

Virtually all ingredients have been animal-tested in the past and testing of new ingredients is an ongoing activity.  Companies that employ a Fixed Cut-Off Date policy will not use any ingredient tested on animals after their Fixed Cut-Off Date, and insist that their suppliers comply with this. 

EU Cosmetic Testing Ban - Even if your company did not operate a Fixed Cut-Off Date Animal Testing Policy prior to 11th March 2013 when the EU Cosmetics Testing Ban came into force, any company wishing to sell cosmetic / toiletry products within the European Union must now ensure that none of the ingredients or finished products have been tested on animals anywhere in the world since this date. 


Contact your suppliers and ask if they operate a FCOD – many suppliers do. 

If all your suppliers operate a FCOD you’re home and dry, as all you need to do is use the most recent date as your FCOD.  This means you can guarantee that all the ingredients used in your products were last tested on animals before your FCOD.  Skip to step 3.

If one or more of your suppliers do not operate a FCOD, it is still possible for your company to adopt one.  Continue to step 2.


Choose from one of the following options:

  • Each of the ingredients used in your products will be supplied with a Material Safety Data Sheet, which should include the date of the most recent test conducted on animals.  Check the dates when each of the ingredients used in your products was last tested upon animals, and the most recent date will become your FCOD.  
  • Ask each of your suppliers to look at the ingredients they supply to your company and inform you of the most recent date that one of them was subject to animal testing.  The most recent date supplied would become your FCOD.
  • Speak with your suppliers and ask them to nominate a date they could comply with when supplying the ingredients for your products – the earlier the better of course.  It may be as simple as replacing one of your ingredients with another that does the same job that enables your FCOD to be moved back by several years!

Once you have established your FCOD with your supplier, continue to step 3.


In order to commit to your FCOD, you must now formalise this with your suppliers.  You can do this in one of two ways.

Either, print off a copy of the ‘Supplier Declaration of Assurance’ document for each of your suppliers. You will need to enter your company details and your FCOD in the appropriate places, then send a copy to each of your suppliers with a covering letter asking them to confirm they agree by signing the document and returning it to you.  The document can then be held in your files.

Or, include a section in your supplier contract about your FCOD requirement.

Once you have a FCOD in place and you have written proof on file, you’re ready for step 4.


You must now set up a monitoring system to ensure your suppliers continue to adhere to your FCOD.  In order to achieve this, renew the ‘Supplier Declaration of Assurance’, on an annual basis.  This way everyone stays informed of your requirement for ingredients which conform to your FCOD.


Once you have a FCOD animal testing policy and supplier monitoring system in place, you can then complete the Naturewatch Foundation Questionnaire.  

We look forward to hearing from you soon!

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