If you follow our work at Replacing Animal Research, you’ll know that our mission is to build a world where no animal suffers for science, and if you have read our new Policy Approach you might wonder, given this vision, why we focus so much on the legislation around animal research. Isn’t that just propping up a system we want to replace?  

It’s a great question, and the answer is that there is an ethical responsibility to avoid animals, but also a legal one. This gives a great starting point to engage with scientists and policymakers to help them meet this obligation, but also to push for greater ambitions around replacement.

What does the law say?

The existing legislation that regulates animal research in the UK, the Animals (Scientific Procedures) Act 1986 (ASPA), and the EU law EU Directive 2010/63/EU govern the use of protected animals in scientific procedures and provide protections to animals through ethical oversight, licensing, auditing systems, and adherence to something called the 3Rs principles. It’s here that the principle of Replacement is enshrined in law. The law requires that animals are not used in a procedure if there is a scientifically valid and satisfactory non-animal alternative available.

Inroads to change

This Replacement principle within the legislation provides us with a crucial lever for driving change. By supporting the implementation of Replacement in the context of the 3Rs, we are not condoning animal research but using the rules that permit it to help push for its end.

This is where our work begins: we target the system’s weak points by providing training and resources to researchers and review bodies. We push for stronger enforcement of the ‘Replacement’ principle, ensuring that alternatives are properly explored before any animal research project licence is granted. We question the relevance of certain animal models and advocate for human-relevant science.

Focusing on the legal frameworks also gives us access to a seat at the table with decision-makers. We provide advice to the Government on how to strengthen regulations and increase transparency. By doing so, we can influence the direction of policy, ensuring that the legal frameworks evolve to favour non-animal methods.

Where are the gaps?

The legislation (ASPA) only kicks in for specific species in specific circumstances.

• Scientific procedures must meet a threshold for the legislation to apply – the procedure must cause pain, distress or suffering equal to, or more, than the insertion of a hypodermic needle, so as much pain as an injection. This leaves the door open for disagreement around what constitutes harm and distress and how it is assessed. The regulatory frameworks do provide guidance on this – but a level of subjectivity remains.

• Not all invertebrate species are not covered by the legislation. The law sounds like it protects all animals in all research situations, but in reality it doesn’t. The principle of Replacement as it is currently written also includes the replacement of a protected species e.g. a mouse, with a non-protected species e.g. an insect, or a crab (despite the Animal Welfare (sentience) Act (2022) recognising sentience in crabs).  This is misleading if the ultimate aim is to replace all animal use. This type of ‘partial’ replacement is a step change that should be recognised separately to full replacement. They are different.
• On top of this we also know that the Replacement requirement that does exist is not being implemented well.

These are also all gaps we can, and do, help with.

Our Policy Approach

Some may argue that ignoring animal research legislation altogether and focusing only on animal-free methods would be more direct. But this overlooks a critical reality: animal research continues today, countless animals are used each year, in 2015 a scientific paper estimated 192.1 million animals had been used worldwide, and there are still areas where alternatives are not advanced enough to replace animals.

By strengthening the existing regulatory frameworks, we can help bring about positive change for animals now and accelerate the transition away from animal use. It is not a compromise; it’s a strategic, tactical approach to building a better world, one step at a time. We are leveraging the present to create the future.

Read about our goals to strengthen the regulation of animal research, increase transparency and advance Government strategy in our updated Policy Approach.