The Environmental Protection Agency (EPA) is taking another step toward reducing its reliance on animal testing, with new methodologies that could directly affect chemical manufacturers and pesticide registrants required to provide safety data.
On August 27, 2026, the agency announced updated approaches for assessing the respiratory irritation of surfactants and predicting acute oral toxicity for certain pesticide formulations. The changes advance EPA Administrator Lee Zeldin’s stated goal of eliminating mammalian animal testing by 2035.
EPA’s Push to Reduce Animal Testing
The announcement is the latest in a series of steps that began with the January 22, 2026 memorandum, “Recommitment to Reducing Animal Testing and Eliminating Mammalian Testing by 2035.” The memorandum, which built on efforts taken by the EPA during President Trump’s first term, committed the agency to phasing out all remaining mammalian study requests and funding by 2035.
The memorandum emphasizes developing and implementing high-quality alternatives to animal testing, known as new approach methodologies (NAMs). NAMs include advanced chemical-testing technologies such as computer modeling, cell-based studies, data-sharing platforms, and in vitro tests. The EPA describes NAMs as functionally equivalent alternatives to mammalian testing.
The memorandum directs the agency to work in targeted ways to reduce mammalian testing and collaborate with other government agencies to develop alternative methods. The EPA's three-pronged strategy includes:
- Identifying NAMs that can currently be used as alternatives to traditional animal testing.
- Reviewing agency guidance and the Code of Federal Regulations to provide flexibility in fulfilling toxicity-assessment data requirements and issuing waivers to further reduce animal-testing requirements.
- Encouraging external researchers and data providers to use NAMs and apply for animal-testing waivers whenever possible.
New Framework for Surfactant Respiratory Irritation
Surfactants are chemicals used in cleaning products, detergents, and soaps. The EPA reviews new chemical submissions that may include surfactant-based formulations under the Toxic Substances Control Act (TSCA).
The first change announced by the EPA is an updated scientific framework for evaluating the potential respiratory irritation of surfactants. Instead of relying on animal-testing results, the framework uses 3D human airway tissue models and existing computational models to predict how specific formulas irritate the lungs.
The EPA says the approach provides faster, more human-relevant science and decreases reliance on animal testing without compromising safety, although some critics dispute that conclusion.
GHS Mixtures Equation for Acute Oral Toxicity
The second advancement involves pesticide safety reviews. The EPA announced that it will use the Globally Harmonized System (GHS) mixtures equation, an internationally recognized, data-driven calculation used to predict acute oral toxicity for certain pesticide formulations.
The decision followed an analysis conducted with the National Institute of Environmental Health Sciences that evaluated approximately 700 pesticide formulations. The analysis concluded that the equation reliably identifies products that are minimally toxic through the oral route.
Using the GHS mixtures equation, the EPA can reportedly assess risk based on the known toxicity value of a mixture’s ingredients without requiring animal testing.
What Chemical and Pesticide Companies Should Consider
Chemical manufacturers and pesticide companies required to disclose safety data for EPA review will be affected by the agency’s shift away from traditional animal testing. Companies should consider several steps:
- Assess applicability and update plans. Determine whether the newly adopted surfactant respiratory-irritation framework or GHS mixtures equation applies to current or planned products. Retesting would be required only if the EPA specifically requires it as part of a chemical-specific review under TSCA or registration review under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).
- Engage the EPA early. Communicate with the agency to clarify whether particular NAMs are acceptable for specific products.
- Evaluate waiver opportunities. Monitor EPA guidance and rulemakings for new waiver provisions and submit waiver requests when NAMs can support the required safety determinations.
- Retain contingency plans. Because some mammalian testing may remain necessary to satisfy statutory obligations, companies should be prepared to conduct conventional animal studies if the EPA determines that NAMs are insufficient for a particular product category.
As the EPA continues its transition away from traditional mammalian testing, companies should monitor how the agency implements these new methodologies and adjust testing strategies accordingly.
If you have any questions, or would like additional information, please contact one of the attorneys on our Environmental, Land Use & Natural Resources team.
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