@article{6301,
  keywords = {REACH, alternative methods, fish toxicity tests},
  author = {Jean Knight and Costanza Rovida and Kate Willett and Jay Ingram},
  title = {Fish count, too – The animal toll of REACH aquatic toxicity tests},
  abstract = {The European Union's main chemicals regulation, Registration, Evaluation, Authorization and Restriction of Chemicals (REACH), requires chemicals to be evaluated for health and environmental impacts, with animal tests the basis for many evaluations. Most discussions of REACH animal use focus on mammals, yet fish tests are also a significant component. Here we report the animal count for fish tests completed, ongoing, and pending under REACH, based directly on test reports. The estimated total to date is 382,000 fish, used for short-term fish toxicity, long-term fish toxicity, endocrine disruption, and bioaccumulation tests. This count does not include new tests that will result from the 2022 REACH amendment, which extends requirements for long-term fish toxicity tests and removes the most common basis for waivers previously accepted for this test. An estimated 940-1,240 new long-term fish toxicity tests may result from these changes, requiring 520,000-680,000 fish. The count also does not include potential expansion of endocrine disruption testing in the upcoming REACH revision. New non-animal alternatives to long-term fish toxicity and endocrine disruption tests are needed to reduce these impacts. For other fish tests, recently defined non-animal methods for short-term toxicity and the newly approved Hyalella azteca Bioconcentration Test for bioaccumulation should be evaluated for inclusion in REACH guidance, both to incentivize their use and to better comply with the REACH mandate to use animal testing only as a last resort.
Plain language summaryThe European Union’s REACH regulation requires that chemicals be tested for their effects on health and the environment, with animal testing forming the basis of the evaluations. While discussions often focus on mammals, our study shows that fish are also used extensively. We found that about 382,000 fish have already been used in REACH tests. In addition, 520,000-680,000 fish may be required for new long-term tests resulting from REACH amendments in 2022. Current evidence indicates fish are similar to mammals in their ability to feel pain, and to empathize with companions’ suffering, making it essential to follow the REACH mandate to use animal testing only as a last resort. REACH guidance should be updated to incorporate new methods that can replace fish tests. For long-term tests, however, no new methods are available, and a focus on this is urgently needed, helping to protect both scientific integrity and animal welfare.},
  year = {2025},
  journal = {ALTEX - Alternatives to animal experimentation},
  month = {2025-10-10},
  issn = {1868-8551},
  url = {https://www.altex.org/index.php/altex/article/view/2993},
  doi = {10.14573/altex.2506011},
  language = {en},
}