Written evidence submitted by People for the Ethical Treatment of Animals UK (PETA) (SDY0018)
People for the Ethical Treatment of Animals (PETA) UK is grateful for the opportunity to submit feedback in response to the Science Diplomacy Inquiry. As one of the largest animal protection organisations in the UK, we are submitting these comments on behalf of our 1.3 million members and supporters. The scientists and policy experts who work for PETA UK and PETA entities worldwide have a proven track record of productively assisting many international regulatory and government agencies and companies, including the European Commission. This assistance includes providing expert opinions for the development of strategies, regulatory advice and technical support in a broad range of fields.
How effective is the UK Government’s strategy for positioning the UK as a global leader in science and technology and what role does the Department for Science, Innovation and Technology (DSIT) play in advancing this agenda?
The Government’s ambitious strategy to position itself as a global leader in science and technology will require an effective roadmap, including key milestones and indicators of progress, to advance the development and use of non-animal technologies in the UK. DSIT will play a key role in executing this roadmap through the orchestration of diverse activities while working with all stakeholders. Please find examples of responsibilities that DSIT must fulfil for the UK to become a leader in animal-free innovation in science and technology.
DSIT must ensure meaningful engagement with all stakeholders
As outlined in PETA’s Research Modernisation Deal, phasing out animal testing will work in parallel with effectively positioning the UK as a global leader in non-animal methods and technologies.1 The government has already committed to “partner with scientists, industry, and civil society as we work towards the phasing out of animal testing.” DSIT must play a key role in leading this initiative and ensuring its success. It must ensure that actions to phase out the use of animals in research and testing go hand in hand with actions to support the development, validation, acceptance and adoption of non-animal methods. There are different barriers to this across research and testing; overcoming these barriers will require meaningful engagement and commitment from all stakeholders, including researchers, regulators, industry and funders, as well as the animal protection community.
DSIT must address the innovation crisis through the adoption of non-animal methods
One area primed to benefit from the adoption of non-animal methods is the pharmaceutical sector. It is facing an innovation crisis, a major cause of which is the inability of biotechnology companies to translate technological advances into effective therapeutics.2 The reproducibility crisis contributes to this issue: 50-89% of preclinical research is not reproducible, with experiments on animals frequently highlighted as a major contributing factor.3 The Prime Minister recently announced plans to reduce the time taken to establish clinical trials from over 250 days to 150 days;4 this is a small reduction in the drug development pipeline considering that the average time from target discovery to approval of a new drug is about 14 years.5 Enabling clinical trials will not address the issue of ineffective drugs in the drug development pipeline and will not increase the clinical trial success rate. The drug development pipeline must be revolutionised to address the innovation crisis.
Non-animal methods can replace the use of animals in research, drug development and regulatory testing. In recent decades, various advanced non-animal methods have been developed, including in vitro, in silico, and in chemico methods. This is an untapped area of huge economic potential: by 2028, the demand for induced pluripotent stem cells and 3D cell cultures is set to reach $5.2 billion and $14.8 billion, respectively.6,7 These are eclipsed by the demand for cell-based assays, which is expected to reach $56.3 billion by 2029.8 Phasing out the use of animals will create a unique opportunity for the non-animal methods sector to expand and thrive, given the right support and appropriate legislative/policy changes.
DSIT must redirect funds towards non-animal innovation
Activities driven by DSIT should include ensuring appropriate financial support for specialised biotechnology companies to develop scientifically valid non-animal methods that are fit for regulatory purposes and for pharmaceutical companies to adopt non-animal methods. Public research institutes, such as universities, must be encouraged to support the development and uptake of non-animal methods for advancing knowledge across basic, translational and applied sciences, with the provision of special grants. DSIT must encourage funders, such as UK Research and Innovation, the Wellcome Trust and the Medical Research Council, to direct funding away from scientifically invalid animal methods and towards advanced, non-animal methods. This shift can be promoted through legislative or policy changes. Redirected funds could support establishing core facilities for complex in vitro technologies (for mass production) and specialised equipment and reagents needed to support the development of, for example, organs-on-chips and organoids.
DSIT must enhance the publication of non-animal research and innovation
DSIT must encourage journals to support the publication of novel non-animal methods and data generated using new and current non-animal methods. Animal methods bias, a form of peer review bias which involves a preference for animal tests or a lack of expertise to evaluate non-animal methods, can negatively impact the likelihood of publication of manuscripts which include non-animal methods.9 It may also affect the outcome of funding applications. To overcome this, DSIT should raise awareness of animal methods bias and encourage inclusion of more non-animal methods experts in the peer review process, as well as requesting annual self-reports from publishers that detail the number of publications on non-animal methods. This will encourage researchers, particularly in academia, to adopt non-animal methods.
DSIT must enable legislation and policy to keep pace with scientific innovation
To exploit the full potential of non-animal methods, regulatory systems should retain legislative flexibility and adapt to evolving methods for safety assessment. This involves incorporating the latest “weight of evidence” analyses and integrated approaches to testing and assessment rather than maintaining rigidity, e.g., standard information requirements. It also includes updating legislation, guidance and policy, and embracing opportunities to eliminate reliance on data from tests on animals.
By facilitating the development and use of non-animal methods, the UK can drive economic and scientific progress. Incorporating non-animal methods into the regulatory system, biotechnology, pharmaceutical and research sectors can lead to safer medicines and products, quicker development of effective therapeutics and more accurate scientific data. If orchestrated successfully, the transition to non-animal methods will position the UK as a global leader in science and technology, and healthcare.
Does the UK need an International Science Strategy and what would it contain?
To effectively support the transition to non-animal methods, the UK must work with other countries that have made progress in this area. The EU is an example of this. The European Commission has already committed to developing a roadmap to phase out animal testing for chemical safety assessment. To support the development of this roadmap, the Commission has established three working groups (Human Health, Environmental Safety Assessment and Change Management). Activities, including consultations, surveys, workshops, and interviews, have been held to support and inform the roadmap. For example, the European Partnership for Alternative Approaches to Animal Testing (EPAA) Animal-Free Chemical Safety Assessment Conference in Brussels, held on 4–6 March 2025, united cross-sector stakeholders to identify key learnings, opportunities, and challenges, culminating in recommendations for inclusion in the Commission Roadmap to phase out animal testing for chemical safety assessment. The UK government can extract learnings from the EU Commission’s activities and initiatives to optimise the government’s strategy to transition to a non-animal methods research and regulatory system.
The U.S. is also making progress in its transition to non-animal methods. The U.S. Food and Drug Administration (FDA) has published a roadmap to replace tests on animals in the development of monoclonal antibody therapies and other drugs with more effective, human-relevant methods.10 The U.S. National Institutes of Health (NIH) announced that it is prioritising human-relevant research and moving away from experiments on animals, and that its grant review staff will “participate in mitigation training to address any possible bias towards animal studies.”11 The UK must keep pace with such developments to maintain competitiveness in the drug development arena.
Harmonisation of the regulatory system and drug development process with European and international procedures and guidelines will support the commercialisation of medicines and products. This will increase the UK’s economic growth and position the UK as a leader in healthcare and producer of consumer goods.
What are the key international scientific relationships for the UK?
The UK can take learnings from the EU’s activities in this area and develop collaborations to enable a more rapid transition in the UK. To maximise funding for leading scientists in non-animal methods, the UK must facilitate international collaborations. This will promote data sharing between institutes and enable rapid scientific and technological advances. For example, UK-European collaborations between biotechnology and pharmaceutical companies will greatly advance the development and commercialisation of novel technologies and increase economic growth in the UK. The EU has already experienced rapid growth of its biotechnology sector in parallel with a reduction in the number of animals used for scientific purposes.12 EU momentum and progress can be used to the UK’s advantage by establishing strategic relationships across UK-European funders, research institutes, industry and regulatory bodies.
How can the UK be made an attractive destination for global R&D investment, and how can the benefits of this investment be maximised locally and nationally?
To make the UK an attractive destination for global R&D investment, a coordinated strategy should focus on policy leadership, infrastructure investment, and skills development. For example, the UK can lead globally by establishing clear, progressive regulatory frameworks that actively encourage the adoption of non-animal methods in research and development. Aligning regulatory approval pathways with cutting-edge innovations such as organ-on-chip systems, advanced in silico models, and human tissue-based platforms would provide companies with confidence that investment in non-animal methods will be commercially viable. Likewise, setting concrete goals and milestones for phasing out animal testing will create a strong market signal for advancing non-animal technologies.
Investment in world-class non-animal technology hubs would make the UK a magnet for global R&D. 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. To spread the benefits, regional hubs can be established with local universities and innovation clusters, ensuring job creation and skills development across the country. See, for example, the Dutch Transition Programme for Innovation without the use of animals, in which regional hubs have been established.13 By nurturing the non-animal methods sector, the UK will experience economic growth with more specialised biotechnology companies offering the latest technologies, and pharmaceutical companies that can effectively translate pre-clinical results into patient clinical benefits.
How can the government ensure leading scientific researchers continue to view the UK as an attractive place to base themselves?
Investing in the non-animal methods sector and exploiting the subsequent economic and scientific benefits will make the UK a pioneer in this area. This will attract the attention of scientific researchers who work with cutting-edge non-animal technologies or those who intend to. Increased biotechnology and pharmaceutical companies will increase employment opportunities for those researchers. Likewise, new specialisms at public research institutes will increase research and teaching jobs. Embedding non-animal technologies into educational curricula and professional development programmes will help establish a pipeline of talent and strengthen the UK’s appeal to leaders in the field. To encourage their settlement in the UK, the government must ensure that employment opportunities for leading researchers are stable. There must be sufficient opportunities for funding, publication, training, education, and collaboration. DSIT can achieve this by working with all stakeholders, providing the right incentives and driving the required policy changes.
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References
1. PETA. Research Modernisation Deal. Accessed April 15, 2025. https://www.peta.org.uk/features/research-modernisation-deal/
2. Laermann-Nguyen U, Backfisch M. Innovation crisis in the pharmaceutical industry? A survey. SN Bus Econ. 2021;1(12):164. doi:10.1007/s43546-021-00163-5
3. Romania, P., Folgiero, V., Nic, M., Dibusz, K., Novotny, T. et al. Advanced non-animal models in biomedical research – Immuno-oncology. Publications Office of the European Union. 2021. https://data.europa.eu/doi/10.2760/393670
4. Independent. Starmer pledges to slash time needed to set up clinical trials to 150 days. Published April 07, 2025. Accessed May 2, 2025. https://www.independent.co.uk/news/uk/politics/keir-starmer-prime-minister-nhs-britain-government-b2728895.html
5. National Center for Advancing Translational Sciences. New Therapeutic Uses. Accessed May 2, 2025. https://ncats.nih.gov/research/research-activities/ntu
6. bcc Research. Induced Pluripotent Stem Cells: Global Markets. Published November 2024. Accessed May 07, 2025. https://www.bccresearch.com/market-research/biotechnology/induced-pluripotent-stem-cells-report.html?srsltid=AfmBOorHpHn721CrhivB2ripMFU26mvGuQqhUgnE7WzXtM4Hc2tf5CyV
7. bcc Research. Global 3D Cell Cultures Market Set to Reach $14.8 Billion by 2028. Published March 15, 2024. Accessed May 07, 2025. https://www.bccresearch.com/pressroom/bio/global-3d-cell-cultures-market-set-to-reach-148-billion-by-2028?srsltid=AfmBOopS7EfK9e2YJkPLF0cwFBoCIZFrC1GJZkE7v3n1NbWRbrOQ0raw
8. bcc Research. Cell-Based Assays: Technologies and Global Markets. Published February 2025. Accessed May 07, 2025. https://www.bccresearch.com/market-research/biotechnology/cell-based-assays-technologies-markets-report.html
9. Krebs CE, Geissler S, Herrmann K, et al. Exploring animal methods bias in biomedical research funding: Workshop proceedings and action steps. NAM J. 2025;1:100004. doi:https://doi.org/10.1016/j.namjnl.2024.100004
10. US Food and Drug Administration. Roadmap to Reducing Animal Testing in Preclinical Safety Studies. Published April 10, 2025. Accessed May 07, 2025. https://www.fda.gov/media/186092/download?attachment
11. Science. New NIH office to reduce use of animals in research. Published April 30, 2025. Accessed May 2, 2025. https://www.science.org/content/article/new-nih-office-reduce-use-animals-research#:~:text=Reducing the use of animals,train researchers in their use
12. European Commission: Joint Research Centre, Zuang, V., Baccaro, M., Barroso, J., Berggren, E., Bopp, S., Bridio, S., Capeloa, T., Carpi, D., Casati, S., Chinchio, E., Corvi, R., Deceuninck, P., Franco, A., Gastaldello, A., Katsanou, E., Langezaal, I., Malinowska, J., Mennecozzi, M., Milcamps, A., Piergiovanni, M., Prieto-Peraita, P., Selfa Aspiroz, L., Valsesia, D., Whelan, M., Wittwehr, C. and Worth, A. Non-Animal Methods in Science and Regulation, Publications Office of the European Union. 2024. https://data.europa.eu/doi/10.2760/9648771
13. Transition Programme for Innovation. Animal Free Innovation. Accessed May 7, 2025. https://www.animalfreeinnovationtpi.nl/
9th May 2025
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