Written evidence submitted by the People for the Ethical Treatment of Animals (PETA) UK (IGR0041)

Submission to the Call for Evidence: Innovation, Growth, and the Regions
 

People for the Ethical Treatment of Animals (PETA) UK appreciates the opportunity to contribute to the call for evidence on “Innovation, Growth, and the Regions.” PETA’s network of scientists and policy experts offer extensive expertise in the development of non-animal methods. Our scientists come from diverse fields, including biochemistry, ecotoxicology, epidemiology, and animal welfare, and are actively involved in the development, validation, and global implementation of non-animal methods. PETA entities have worked with various government agencies and regulatory bodies including the European Food Safety Authority, the US Environmental Protection Agency, and the European Chemicals Agency, providing technical support and advice to move away from animal experiments.

We are pleased that the Labour Party's manifesto includes a commitment to “partner with scientists, industry, and civil society as we work towards the phasing out of animal testing.”[1] We are happy to offer our recommendations on ensuring that investments in innovation and economic growth align with the values of citizens, and we stand ready to assist in developing a comprehensive plan to phase out animal experiments in the UK. Given the role of the Science, Innovation and Technology Select Committee in shaping the UK’s science and technology policies, promoting innovation, and ensuring that the government invests in and regulates these sectors effectively, it is well positioned to ensure that only the most innovative, effective, and species-relevant non-animal methods are promoted wherever possible.

Building on the commitment to phase out animal testing and the pivotal role of the Committee in advancing effective and human-relevant methods, we propose three key recommendations for this consultation:

(i)             Establishing a joined-up, strategic approach to phasing out experiments on animals, led by an overarching body tasked with developing and implementing a comprehensive roadmap;

(ii)            Enhancing targeted funding and fostering coordinated efforts to drive innovation in non-animal methods; and

(iii)          Ensuring broader stakeholder input to shape a collaborative and inclusive transition
 

1. A Strategic, Coordinated Approach to Phasing Out Animal Experiments with a Dedicated Oversight Body

The first step in creating a successful strategy is developing a roadmap with an ambitious time frame, clear milestones, and achievable goals to reduce and ultimately phase out experiments on animals. PETA scientists have developed the Research Modernisation Deal (RMD),[2] which outlines the necessary elements in forming a comprehensive strategy to accelerate the uptake and development of non-animal methods in biomedical research and regulatory testing, highlighting key areas where investment is urgently needed.

The RMD includes the following steps:

1. Immediately eliminate animal use in areas in which animals have already been shown to be poor and unreliable predictors for humans and their use has impeded progress.
2. Conduct critical scientific reviews to identify the areas in which the use of animals has failed to advance human health and should therefore be ended.
3. Implement transparent, robust prospective and retrospective evaluations for all projects using animals and allow for a public commenting period.
4. Work with organisations and agencies globally to harmonise and promote international acceptance of non-animal testing methods for regulatory testing requirements.
5. Increase funds for non-animal studies and decrease funds for animal studies.
6. Educate and train researchers and regulators on the benefits of and how to use non-animal testing approaches.

Without a clear and actionable roadmap, there is a risk of the UK falling behind international developments in accelerating 21st century science — continued reliance on animal methods is a significant obstacle to our becoming world leaders in this sector and delivering advanced research and testing methods that are human-relevant.

Before leaving the EU, the UK was mandated under Directive 2010/63/EU on protection of animals used for scientific purposes, to contribute to the development and validation of non-animal methods. Article 47 of Directive 2010/63 outlines specific responsibilities for EU member states, including the need to identify and nominate specialised and qualified laboratories for validation studies, set priorities for validation, and ensure the promotion and dissemination of non-animal methods. This comprehensive approach reflects the EU's commitment to actively supporting and integrating non-animal approaches into research and testing frameworks.

In contrast, the UK’s Animals (Scientific Procedures) Act 1986 (ASPA), as outlined in Article 20B, lacks the same level of detail and commitment to driving these initiatives. While ASPA requires that the Secretary of State considers Replacement, Reduction, and Refinement (the 3Rs) in regulating scientific procedures involving protected animals, and support the development of validation and alternative strategies, it does not provide clear mechanisms for identifying appropriate laboratories, setting validation priorities, or promoting non-animal methods. Furthermore, ASPA does not include the overarching goal of phasing out animal experiments, a principle enshrined in recital 10 of Directive 2010/63/EU. The absence of a structured, strategic framework in the UK legislation points to a significant gap in governmental efficiency and leadership when it comes to advancing research and innovation in non-animal testing methods.

Innovate UK’s 2015 report, “A Non-Animal Technologies Roadmap for the UK: Advancing Predictive Biology”, identified “non-animal technologies as one of a series of emerging technologies with the potential to drive future UK economic growth” that could present commercial opportunities and attract international investment.[3] Yet no meaningful progress has been made in implementing the report’s recommendations for achieving its 2030 vision for non-animal technologies to be used as standard in the UK. Indeed, there are numerous recommendations and reports on the theme of non-animal methods, emerging technologies, and improving the integration of such outputs to progress scientific capabilities and better protect human health and the environment. However, the country lacks a unified, strategic approach to drive such ambitions forward.[4],[5],[6] Without an overarching approach, any ongoing or future initiatives risk becoming fragmented and failing to effectively achieve their innovation and regulatory goals.

The former Conservative government committed to “publish a plan to accelerate the development, validation and uptake of technologies and methods to reduce reliance on the use of animals in science”[7] and the current Labour government have committed to “work towards the phasing out of animal testing”.[8] A UK roadmap to phase out animal use and foster innovation in non-animal methods should prioritise strategic funding, foster cross-sector coordination, ensure coordinated leadership, provide a comprehensive change management strategy and establish clear guidelines for supporting innovation in non-animal methods across the UK’s nations and regions. We must ensure that the transition to more ethical, efficient, and non-animal research methods is both streamlined and impactful.

2. Boosting Innovation Through Targeted Funding and Coordinated Efforts

There is a strong economic case for transitioning to non-animal methods. It has been estimated that “[t]he average time from target discovery to approval of a new drug is about 14 years. The failure rate during this process is more than 95 percent, and the cost per successful drug can be $1 billion or more”.[9] Clearly there is a problem with the current paradigm for developing and testing drugs and getting them to market, and experiments on animals have been identified as one of the contributing factors.

The US Environmental Protection Agency (EPA) has demonstrated the economic benefits of moving away from animal testing, reporting significant cost savings through the adoption of non-animal methods, with reductions in time and resources for chemical safety assessments.[10] For example, in 2023, metrics from the Hazard and Science Policy Council estimated that waivers granted avoided the use of 10,024 animals, saving $15.7 million for industry and $378,746 in EPA review costs. Additionally, the EPA’s workplan for incorporating new approach methodologies includes measures for monitoring and assessing the effectiveness of these methods, ensuring a data-driven transition. This approach not only highlights the financial advantages but also provides a framework for setting targeted innovation goals to maximise future benefits. These findings reinforce the economic rationale for prioritising the development and adoption of non-animal methods.

Given the unsustainable economic cost of the poor predictivity of animal tests and the high attrition rates plaguing the development of new therapies and vaccines, investment in non-animal methods can provide a valuable starting point for many companies, encourage new investors, and provide a valuable long-term solution to this problem. The RMD identifies the areas in which improved approaches are most urgently needed and proposes a strategy for optimising investment in the development and use of non-animal methods in biomedical research and regulatory testing.

The market for human-based in vitro technology in biomedical research and regulatory testing is growing rapidly, with the global in vitro toxicology testing market valued at approximately USD 31.03 billion in 2023 and projected to reach USD 64.81 billion by 2030.[11] Significant opportunities for innovation also exist in the field of chemical regulatory testing – particularly by supporting the development of new scientific and technological advances and incorporating them into the regulatory framework at an accelerated rate. Indeed, the innovation in non-animal methods and chemical risk-assessment strategies seen following implementation of the animal testing and marketing bans for cosmetics[12] across the EU are testament to what can be achieved.

Through UK Research & Innovation (UKRI), funding is directed toward developing 3Rs-based techniques, primarily via the National Centre for 3Rs (NC3Rs). Since its establishment two decades ago, the NC3Rs has invested around £90 million in research and £27 million in contracts through its CRACK IT Challenges, some of which includes investment in developing non-animal methods.[13] In February 2024, the Conservative Government committed to supporting the growth of the 3Rs and non-animal research methods by doubling research funding to £20 million in 2024/25.[14] The Labour government has since announced UKRI will invest £50m over the five-years in the NC3Rs, with an additional £5m allocated for 2024/25.[15] It is important that these figures are set in the context of the annual R&D budget set by the government, which is over £20 billion a year.[16] At the same time, around a third of Medical Research Council and the Biotechnology and Biological Sciences Research Council (BBSRC)’s funded research programmes involve regulated animal use.[17] Given that funding for the 3Rs is also reserved for reduction and refinement methods that use animals, the high attrition rates in drug development, and the substantial potential of non-animal technologies, the funding dedicated to replacement of animal use is insufficient, and puts the UK at a disadvantage to other countries with dedicated investment in non-animal methods. In 2024, the Dutch National Growth Fund allocated a staggering €124.5 million for the establishment of the Centre for Animal-Free Biomedical Translation, marking significant progress in animal-free science.[18] Expanding investment and aligning funding levels with the transformative potential of non-animal technologies is critical if the UK wishes to remain at the forefront of innovation and scientific progress.

We encourage the Committee to review the RMD’s section on funding strategies, which outlines how reallocating resources from animal studies to non-animal methods can drive economic growth, scientific progress, innovation, and better protect human health and the environment.[19]

3. Fostering Collaboration Through Broader Stakeholder Engagement

The urgent need to transition away from using animals in research and testing and towards human-relevant non-animal approaches is already changing policies around the globe, and the benefits to animal welfare, public health, scientific advancement, and the economy are widely recognised by all stakeholders.[20],[21],[22],[23] For example, the European Commission’s commitment to developing a roadmap for ending all mandated tests on animals for industrial chemicals, pesticides, biocides, and human and veterinary medicines[24] was triggered by the European Citizens' Initiative launched by five animal protection NGOs, including PETA, which has been involved from the outset. Other strategies are in place in the Netherlands,[25],[26],[27] Germany,[28] and the US,[29],[30],[31] with PETA entities in each country playing pivotal roles in supporting the implementation of their respective roadmaps. For example, PETA co-hosted a multi-stakeholder roundtable workshop[32] to help shape discussion concerning the EU roadmap towards phasing out animal testing for chemical assessments and is part of the organising committee for the upcoming European Partnership to Alternative Approaches to Animal Testing workshop on animal-free chemical safety assessment. PETA also collaborated with experts from the Dutch Centre for Animal-Free Biomedical Translation to launch the Global Education Hub for animal-free innovation, whose mission is to share and disseminate knowledge, best practices, and animal-free education tools around the world.[33] In all these efforts, stakeholder participation has proven to be invaluable, as demonstrated by successful involvement of PETA entities in shaping strategies globally, ensuring that diverse perspectives are integrated and that the transition is both effective and inclusive.

The Netherlands has provided a strong example through its National Committee for the Protection of Animals Used for Scientific Purposes. Its recent evaluation on the "Transition to Animal-Free Research" highlights the critical importance of change management and transformative governance in overcoming barriers to adopting non-animal methods.[34] This evaluation emphasises that transitioning away from animal use requires more than technological innovation; it demands significant shifts in practices, behaviours, mindsets, infrastructure, and regulations. Established norms often impede progress, making it essential to engage societal stakeholders beyond traditional animal research to foster change. Broader discussions about societal paradigms—such as prioritising continuous economic growth or focusing solely on human health and safety—are necessary to address how these frameworks may hinder or support a shift towards an animal-free paradigm.

A majority of EU member states have committed to taking concrete steps to accelerate the phasing out of animal testing, reflecting growing global momentum. We invite the Committee to consult the RMD’s section on 'World Leadership' for further details on these international efforts, which can serve as a valuable guide for the UK in drafting its own plan to maximise the benefits in terms of economic growth, scientific advancement, innovation, and the protection of human health and the environment.[35]

Experiments on animals are of high concern to the electorate, and for several years, the public has wanted to see more being done to move away from their use, including policies to end animal testing and greater investment in non-animal methods.[36],[37] For example, a 2023 YouGov poll revealed that 77% of respondents supported a government-led phase-out strategy of animal use in research and testing.[38] We therefore encourage the government to use the RMD in developing a roadmap to phase out experiments on animals, not only because this aligns with the values of its citizens and represents the moral path forward, but also because it is the scientifically and economically sound approach, one that is already being embraced globally. Consulting with stakeholders is essential to drafting a roadmap that will have the greatest chance of success, ensuring that all parties with the power and ability to contribute to the transition are on board. PETA is ready to offer its extensive expertise and support to help ensure the UK leads the way in this critical transition.

To conclude, there are clear lessons to be learned from international models and previous work in the UK to help boost innovation to benefit both regional and national economies within the scientific sector. Using PETA’s RMD to help develop a roadmap to phase out experiments on animals will be key to this endeavour.

20 January 2025

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