It depends on which organization certified the brand. The Coalition for Consumer Information on Cosmetics (CCIC), which certifies Leaping Bunny companies headquartered in the US and Canada, sets no expiry date for a supplier’s declaration, while Cruelty Free International, which approves brands elsewhere, requires that no declaration be older than twelve months at any time.
The two issue the same logo, so one signed declaration can be current for one brand and out of date for another, depending on where the brand is headquartered.
Two organizations issue the Leaping Bunny logo
CCIC was formed in 1996 by animal protection groups from the US and Canada. The American Anti-Vivisection Society has chaired it since 2007 and manages its Leaping Bunny Program. Its rulebook is the Corporate Standard of Compassion For Animals, “the Standard by which we certify all Companies headquartered in the US or Canada that apply for Leaping Bunny certification.” A certified company may then license the logo.
Cruelty Free International, a London-based organization founded in 1898, approves companies and brands around the world, working with a small number of partners licensed to operate its program in their own territories. Its rulebook is the Leaping Bunny criteria, published in its Leaping Bunny Programme Guidelines.
In 2026 Cruelty Free International gave its program a new name, the Cruelty Free International Approval Programme, and a new logo. Its announcement says the approval criteria “remain unchanged,” and that while its brands transition they display either “the new logo, or the ‘Leaping Bunny’ with our name underneath.” For now, the rabbit still appears under both rulebooks.
What a supplier declaration is, and who signs it
Both programs reach past the brand into its supply chain: to the suppliers of its raw materials and, where another company makes the finished product on the brand’s behalf, to that contract manufacturer. Each must confirm in writing that what it supplies was not tested on animals after a set date.
That written confirmation is the supplier declaration. CCIC’s Standard defines the one from an ingredient supplier, its Declaration of Raw Material Compliance, as “Written confirmation obtained by a Company seeking certification from its Supplier(s) that they have not conducted, commissioned, or been Party To Animal Testing for Ingredients supplied to the Company.” The set date is the brand’s fixed cut-off date, after which it accepts no new animal testing. Under CCIC each company chooses its own. Cruelty Free International uses March 11, 2013 for every cosmetics company, a date that, in its Guidelines’ words, “harmonises with the date the EU cosmetic testing and marketing bans came into force.”
The contract manufacturer gives a second kind, which CCIC calls a Declaration of Product Compliance. Cruelty Free International likewise requires declarations “from finished product and raw material suppliers,” each signed and dated by the supplier that gives it.
The brand does not write the declaration. The supplier signs it, and the date on it is the supplier’s. Where a brand only distributes finished products, CCIC’s Standard has its manufacturer “obtain and maintain on file the signed Declarations of Raw Material Compliance” from its own suppliers. Cruelty Free International lets a distributor sign only if it holds the manufacturer’s primary information, open to audit.
Both programs can spare a brand the declaration for natural agricultural ingredients supplied raw, such as grown herbs and flowers. Neither extends that to processed additives. CCIC’s Standard says “essential oils, stabilizers, preservatives or other additives that are supplied by an Ingredient manufacturer are NOT considered natural agricultural Ingredients,” and Cruelty Free International’s Guidelines draw the same line.
A cosmetics brand collects other supplier declarations too, such as the fragrance allergen declarations behind EU labels. This one answers a single question, animal testing, against a single date.
How long a declaration stays current under each rulebook
CCIC’s Standard requires declarations from “each of its Third Party Manufacturers and Suppliers,” kept on file as part of the company’s Supplier Monitoring System, its term for how a company monitors its suppliers. Read in full, the Standard sets no renewal period and no expiry date for a declaration. Its yearly cycle is the company’s Recommitment, “The annual application required for Companies to maintain their certification, in which they ensure their Supplier Monitoring System is up-to-date.” What is checked each year is the file as a whole.
Cruelty Free International’s rule is explicit. Its Guidelines say declarations “must be no older than 12 months at any time” and that “All approved companies must renew declarations from suppliers annually,” on its sample forms or an alternative that uses the same language. “At any time” means the limit runs every day, not only at audit.
Its guidance to suppliers carries the same rhythm down the chain: a finished product manufacturer must “conduct annual checks with relevant suppliers.”
| CCIC | Cruelty Free International | |
|---|---|---|
| Who it covers | Companies headquartered in the US or Canada | Companies and brands around the world, some through partners |
| Rulebook | The Corporate Standard of Compassion For Animals | The Leaping Bunny criteria, in its Programme Guidelines |
| Fixed cut-off date | Chosen by each company | March 11, 2013, for every cosmetics company |
| Declarations required from | Ingredient suppliers and third-party manufacturers | Raw material and finished product suppliers |
| How long a declaration stays current | No expiry date set | No older than 12 months at any time |
| Yearly cycle | Recommitment: the company confirms its supplier file is up to date | Every declaration renewed |
| Independent audit | If selected | Mandatory |
One declaration, read under both rules
Take one declaration, signed by a preservative supplier in the spring of 2025. A preservative needs a declaration under both programs, since neither treats it as a natural agricultural ingredient.
Held by a brand certified under CCIC’s Standard, it stays on file. Nothing in the Standard dates it out, and at each yearly recommitment the brand confirms that the file it belongs to is up to date.
Held by a brand approved by Cruelty Free International, it turned twelve months old in the spring of 2026 and has been out of date since. The Guidelines require a company to “make available to auditors all aspects of its SMS upon request,” so an auditor can ask to see it.
The supplier did nothing differently in the two cases. It follows that a supplier selling the same material to brands under both programs meets both patterns at once: one customer files its declaration and keeps it, another needs a new one every year.
Which rule applies to a brand
Headquarters decides. CCIC certifies companies headquartered in the US or Canada, and its FAQ sends readers looking for “Leaping Bunny brands headquartered outside of the US and Canada” to Cruelty Free International’s search page.
Where a brand sells does not change that. Cruelty Free International says its approval “applies to all the products that are approved, in all markets that the brand operates.” CCIC’s Standard is a pledge companies make “for all of their products,” and it reaches animal testing done for regulators outside the US and Canada as well. A certified US brand selling in Europe stays under CCIC’s Standard, and an approved European brand selling in the US stays under Cruelty Free International’s criteria. Neither body’s published text holds a brand to the other’s rule.
How to check a declaration file
Whether you keep the file as a brand or sign declarations as a supplier, the same checks show the gap before an auditor does:
- Name the rulebook first: which body certifies or approves the brand, and where it is headquartered. A supplier can ask each customer.
- For every declaration, record who signed it, when, the materials it covers, and the cut-off date it was made against.
- Check that cut-off date against the brand’s own: the date the brand chose under CCIC, March 11, 2013 under Cruelty Free International.
- Under Cruelty Free International, track each declaration’s age all year and request the renewal before it reaches twelve months.
- Under CCIC, before each recommitment, confirm that every current supplier and manufacturer has a signed declaration on file, including any added during the year.
- Read in-house statements closely. Cruelty Free International’s guidance will not accept one that only declares compliance with the EU Cosmetics Regulation or other law, and expects it to cover being party to animal testing, not only conducting or commissioning it.
A date read against the wrong rule looks the same in a file as one read against the right rule. Reading each supplier document against the rule it has to meet is the kind of check Smart-Suited Tech’s document agent, Elara, performs on other supplier paperwork, where each field is read against the client’s own definitions.
The supplier’s signature does not change. Where the brand is headquartered decides whether it is still good.
Sources
- 01 The Corporate Standard of Compassion For Animals (The Standard) — Coalition for Consumer Information on Cosmetics, Leaping Bunny Program, 2026
- 02 Who We Are — Coalition for Consumer Information on Cosmetics, Leaping Bunny Program, 2026
- 03 The Leaping Bunny Logo — Coalition for Consumer Information on Cosmetics, Leaping Bunny Program, 2026
- 04 Frequently Asked Questions — Coalition for Consumer Information on Cosmetics, Leaping Bunny Program, 2026
- 05 Leaping Bunny Programme Guidelines: Cosmetics and personal care products, Revised Winter 2020 — Cruelty Free International, 2020; copy hosted by ICEA
- 06 The Leaping Bunny Programme: Information for Suppliers, Cosmetic (and personal care) products — Cruelty Free International, undated; copy hosted by ICEA
- 07 The Cruelty Free International Approval Programme – A New Chapter Begins — Cruelty Free International, 2026
- 08 Cruelty Free International Approval Programme (brochure) — Cruelty Free International, 2026