25 July 2023

The European Brain Council (EBC) acknowledges and welcomes the European Commission’s (EC) Communication on the European Citizens’ Initiative (ECI) ‘Save cruelty-free cosmetics – Commit to a Europe without animal testing.  As a network of key players in the ‘Brain Area’ representing 179 million Europeans living with brain conditions, mental and neurological alike – scientific societies, patient organisations, professional societies and industry partners – EBC appreciates the relative alignment of the proposed actions with brain research practices and the outlined priorities with evolving scientific and technological developments.

EBC particularly welcomes the EC’s consideration that a legislative proposal is not the right way forward towards phasing out all animal testing. The Communication’s Objective 3 on ‘modernising science in the EU’ rightly acknowledges that there are cases in research where scientific progress and innovation are unpredictable and that setting a universal reduction target may not account for the diversity of research needs. The EC also acknowledges that animal models remain unavoidable at the moment to understand some more complex biological or physiological processes involved in health, disease and biodiversity. As long as it is not possible to predict when scientifically valid methods able to replace particular animal procedures in research, this is a wise and responsible decision supported by the brain community.

As the EC sees the description under the ECI’s objective 3 to overlap with objective 2, EBC strongly appeals to the EC to involve NGOs in the move forward and next steps. As showcased in the wide support received in EBC’s Pledge for Science, the brain community – and many actors from the broader biomedical research community –  are eager to be involved and invited to share their views and priorities at the proposed 2023, 2024 and 2025 workshops (Objectives 2 and 3) and in all expert groups meetings.

While animals are still pivotal in brain research, EBC welcomes the various funding schemes that the EC proposes to facilitate the development, validation, and implementation of alternative or, better phrased: complementary, methods. EBC believes that strategic investment in these areas will enable Europe to maintain its position as a global leader in brain research while upholding the highest ethical standards.

When moving forward, one has to keep in mind that the complexity of the brain necessitates a multifaceted approach that involves studying the interplay between various systems, including genetic, molecular, cellular, and physiological aspects. This knowledge has been instrumental in improving human health and has laid the foundation for numerous medical breakthroughs. Animal models have been essential for evaluating the safety, toxicity and efficacy of novel treatments before they can be tested in human subjects. In the absence of scientifically valid methods that can replace particular animal procedures, phasing out the use of animals in medical research would have major consequences and impact the quest to improve the quality of life of the many citizens affected by brain conditions, neurological and mental alike.

Let’s encourage scientific advancement while offering scientists the time and means  to develop viable complementary and, potentially, alternative methods.