Save Cruelty-Free Cosmetics: We chose an ECI because it has meaning, and it has force!

Kerry Postlewhite is the Director of Public Affairs at Cruelty Free Europe, a network of animal protection organisations from over 20 European Union Member States and neighbouring countries. Their mission is to end animal experiments across Europe, and they are one of the main promoters of the 'Save Cruelty-Free Cosmetics / End Animal Testing' European citizens' initiative. The Initiative managed to collect 1 217 916 validated statements of support, surpassing both the 1 million signatures threshold and the number of threshold countries where more than the required number of signatures have been collected. The initiative is currently in the verification process.

In this interview Ms. Postlewhite describes the goals of the Initiative, the reason for choosing the European Citizens’ Initiative as a tool, discusses the challenges and shares tips on organising a successful campaign.

Kerry Postlewhite, Director of Public Affairs at Cruelty Free Europe 

Q: What is it exactly that your Initiative aims to achieve?

Kerry Postlewhite: The Save Cruelty Free Cosmetics / End Animal Testing European citizens' initiative has three propositions:

First of all, we want to see the European cosmetics animal testing bans, which have been in force since 2013, strengthened, protected and properly implemented. I think what people may not know is that those bans are currently being undermined by requests from the European Chemicals Agency (ECHA) for tests on ingredients used in cosmetics.

We all think that there is no animal testing for cosmetics in Europe, sadly that's no longer the truth.

The first proposition in our ECI is to make sure that those bans that people think exist, and that people care about and campaigned for, are properly upheld.

The second proposition of our ECI is for European Union chemical safety legislation to be based on modern innovative animal-free science and not to default to outdated and cruel animal experiments. The European Union is currently involved in a review of its chemicals legislation, known as REACH, alongside CLP and other related regulations, and we want that review to be predicated on animal-free science. So our ECI is also making that call at a crucial moment when the Commission and Member States are considering that legislative review.

The third and final proposition of our ECI, which wraps all of the package together, is a demand for a legislative proposal from the Commission to bring forward concrete actions to end all animal experiments in Europe. We know that this is something that citizens feel very strongly about and last year, in September 2021, the European Parliament almost unanimously passed a resolution calling for an action plan with measurable targets and actions from the Commission to achieve an end to animal experiments. 

Q: Why did you decide to use the European Citizens’ Initiative as the tool to achieve these objectives?

Kerry Postlewhite:

I think everybody that's been involved in ECIs and everyone that is currently involved in an ECI knows how hard it is to achieve the one million validated signature threshold. Understandably, it's not like any other petition. It is firmly rooted in the Treaties of the European Union and that, I think, is why we specifically chose the ECI as a mechanism.

It has meaning and it has force, and  in theory it means that the Commission has to listen and act.

Ideally, we wouldn't want to have to resort to an ECI. There was, in 2015, one of the first successful ECIs, 'Stop Vivisection', which achieved the threshold of signatures and achieved a parliamentary hearing but sadly next to nothing was done in response to the clear demands from European citizens.

Whilst the ECI is a powerful tool and a brilliant democratic opportunity that we have in Europe, as citizens to say "we want these laws brought forward, we want these laws implemented”, it only really works if the ECI mechanism is really accessible to ordinary European citizens; and, when you achieve a successful ECI, if the Commission acts upon it and listens to the wishes of the citizens who've signed that ECI.

I think without that connection we risk undermining what could otherwise be a very powerful democratic tool.

Kerry Postlewhite, organiser of Save Cruelty Free Cosmetics, gives tips on running a successful campaign

Q: What, in your view, makes a successful campaign for a European Citizens’ Initiative?

Kerry Postlewhite:

An ECI is not easy. There is understandably a high bar to meet in terms of the one million validated signatures, and experience shows that a fair proportion of signatures are rejected after the validation process in Member States. So one million validated signatures probably means that you have to collect considerably more than that. So before you embark on an ECI and start campaigning, there are a number of elements that you have to have in place that are key for a successful ECI.

The first one is the proposition behind your ECI. I think you have to know if your proposition is one that European citizens, North, South, East and West, really care passionately and strongly about and want to see the European Union act on. You need to have a proposition that will gather supporters, will engage people, will motivate people, and that people feel empowered to be involved in change for.

We were very disappointed to have to resort to an ECI because we have the 2015 Stop Vivisection ECI and we have consistent polling and the support of parliamentarians behind an end to cosmetics animal testing but it's good that the mechanism exists and that we can revisit it and that we can emphasize just how much people do care across Europe for our proposals.

The second thing that is key to a successful ECI campaign is having a big network of invested partners and allies. It's a big hurdle and it's a long slog - 12 months.

Not every organisation will be able to be 100% active on the ECI at any given time and not every organisation has all the answers and all the skills. Pooling those across a network of individuals of partners and of allies so that everyone can bring their strength to the table is really important. We all have really busy agendas these days and we all have all sorts of other things going on. If you have a broad network, then different people in different organisations can take the strain at different times over the 12-month ECI campaign.

Having prepared, before you even register your ECI, a toolbox of campaign assets and ideas is really, really critical. 12 months goes quite quickly, you need to keep different audiences engaged and active and motivated. They need to see different things coming from you as ECI campaigners over that period – so it’s really important to have a campaign plan. The campaign plan may differ between Member States as people consume campaign activity and materials differently in different Member States. We utilised Days of Action. For example, we created various activities through the day of March 11, which is the eighth anniversary of the cosmetics animal testing bans; we organised an online protest on April 24 which is the World Day for Laboratory Animals. So, ultimately, it is important to have a plan – research and organise your key days, but also look at the news and try to stay relevant to the news agenda as it is something that people consume every day. See where your ECI campaign fits in with that news agenda so you can keep it live, keep it relevant, keep it on people’s radars.

Look at how you’re going to create stories:

• Can you do some polling, for example, to create a story,
• can you create some case studies to create a story,
• can you use an investigation,
• do you have strong powerful visuals to create a story?

Nobody is going to do the work for you for an ECI, so it is really important to go in with that full suite of materials and that really comprehensive campaign plan for the 12 months.

You need to understand what content works best with your different audiences – is it video, graphics, or should you take a more long-form storytelling approach? Maybe it’s a combination of all three. But you need to constantly analyse what content – be it social media, supporter emails, a news story, television or radio coverage, or public events – gains the most signatures and represents the best use of your time and money. Once you know what gives you your biggest return, focus on that.

Setting up a spreadsheet to analyse daily and ongoing totals was vital for us. Knowing how many signatures each country received every day helped us to notice spikes in support, which we could then link to campaign activity to see what works best.

For us, it was paid social media advertising, but that also needs regular analysis to ensure that you are targeting the right content to the right audiences in the right country, to get the lowest possible cost per signature. Towards the end of the campaign, we were monitoring and adjusting our targets every day.

Your plans to reach your core audience – people who already support your issue – will differ from those you use to reach new people. There will come a point in your campaign where you reach saturation point with your core audience and need to identify wider targets, those who are broadly supportive of your aims but haven’t yet engaged with the specific ideas or your organisation. They may need softer, more generalised messages rather than the hard-hitting content which your existing supporters respond to.

Make use of networks and tap into other audiences through partner organisations. In the final months, we researched, contacted and mobilised the vast network of animal shelters and rescue organisatons across Europe, and these were vital in reaching people who love animals but didn’t necessarily know of the issues around animal testing in Europe.

Another piece of advice I would give in regard to managing a successful ECI is to think of the ECI as a bit like the fable with the hare and the tortoise. You can get started right at the beginning with a big launch, really exciting, you see the signatures coming in really fast because this is something new but you've got 12 months, so don't use everything that you have right at the beginning.

Make sure that you've got enough to keep you running for the 12 months to ensure that you get the one million validated signatures.

You also have to make sure that you do not panic. It can feel as though you are never going to hit that one million mark, but we received over 175,000 signatures in the last week of our campaign, and over 400,000 signatures in the final month. The urgency that you are feeling, as an organiser, will also be felt by the public. An imminent deadline – particularly reinforced by a countdown marking key milestones in the closing stages – will focus the minds of those who are aware of the ECI but have not yet got round to signing.

If you do feel overwhelmed by it all, and are unsure of what to do, try to make use of existing expertise. Contact people who have been involved in similar successful ECIs and ask if they can share their experiences. Being able to speak to people who have been through the same process and overcome the same challenges was key to us, to know what tactics worked for them and at times to simply be reassured that we weren’t doing anything wrong. And finally, resources - be that people or be that funding. Campaigning at this level is not cheap and you do need to make sure in advance that you have the resources that will help you to achieve a successful ECI. It's a great idea that seven motivated individuals, the seven individuals that you need from the different Member States to register an ECI, have the power to influence legislation - but to actually deliver a successful ECI you need resources, you need partners and allies, you need a campaign plan, and you need ideas to keep it fresh over the whole duration of the year.

Q: What have been your biggest challenges?

Kerry Postlewhite: 

It’s a big thing to embark on an ECI, but in addition perhaps to the challenges that everyone who is involved in an ECI faces, with the Save Cruelty Free Cosmetics we hit the challenge of the COVID-19 pandemic. 

When we launched our ECI in August 2021, a number of Member States still had in place Covid restrictions and we had really hoped to be able to mobilise in person, it's something that our organizations are really good at, like our brand partners. We have the involvement in our ECI of the Body Shop, Lush and Dove which are household names that I'm sure everyone will be aware of, we've had amazing support from them. A lot of our initial campaign plans were for in-person campaigning and because of the Covid restrictions still in place we were not able to do that, so we had to adjust really quickly. If we cannot do in-person campaigning what can we do instead?

We knew from other organisers of successful ECIs, particularly the End the Cage Age ECI, that paid social media advertising is a really important component in stacking up your ECI signatures, so we invested a lot of time and a lot of thought into paid social media, paid digital advertising and then came across the challenge of Facebook and Instagram and other platforms being in the process of changing their rules for what they say is political advertising.

You could say that's ironic - it's not political advertising, it's a citizens mobilisation tool, firmly rooted in the Treaties of the European Union, but however you argue, that was a really very real challenge to us, and that was happening in real time. Facebook and Instagram and the other platforms were changing their rules as we shifted from in-person campaigning to paid online campaigning, and try as we could, those obstacles were really difficult to overcome, so again we had to think very quickly on our feet: in-person campaigning is restricted, paid digital is restricted, what can we do instead? So, we had to really make our organic digital, our organic social media presence work for us.

It had to have reach and it had to have impact. The example that I give is of the Svoboda Zvířat viral video (in Czech) in Czechia, which was one way of doing that and it's something that we continue to rely on very heavily, and something we continue to think about a lot, is how can we make our organic digital or organic social media presence really powerful. 

The third challenge that we had as ECI organisers is the tragedy that's unfolding in Ukraine following the Russian invasion and all the things that we all see on our news every day. We have animal protection organisations in our ECI coalition who have switched their focus, very understandably and very correctly, to actually rescuing animals on the border of Ukraine so their focus has had to shift from the ECI to getting animals alive and out of Ukraine. It's also the case again, very understandably, that people's attention is with the plight of the people in Ukraine and that makes it difficult to think about how to adjust the frequency and the tone and the nature of your campaigning for an ECI.

Overall, with Covid, with changes of rules on social media platforms and, sadly, with Ukraine, the lesson for ECI organizers is:

Yes, have the concrete plan well in advance, but also be prepared that anything can happen and be quick to adjust, be nimble to adapt and make sure that you have communication going on all the time between all the people who are involved in your ECI to enable you to do that and to respond quickly.

Q: What would you advise potential future organisers out there?

Kerry Postlewhite:

If you're thinking about running a European citizens' initiative, think hard, but remember it really is a powerful opportunity for citizens right across the European Union to achieve the change that they want to see!

For more information about the Initiative go here.