Last week, the Environmental Protection Agency (EPA) announced its renewed intent to end testing on vertebrate mammals by 2035. The agency first made this commitment during Trump’s first term, but it didn’t last—the Biden administration quietly stripped the policy “off the books in the dead of night.”
Now, the EPA is reviving that same commitment. And in so doing, it joins other federal agencies in publicly posturing around so-called “new approach methodologies” (or NAMS)—methods meant to improve science while reducing the number of (at least some) animals in labs.
This sounds hopeful—and it well might be—but let’s be clear: posturing isn’t progress, and real change has yet to be realized.
Just ask Dr. Paul Locke.
An attorney and scientist at Johns Hopkins, Dr. Locke recently issued a damning report card on the federal government’s performance in transitioning away from animal research and toward human-relevant science.
His grades confirm what we already know: no agency has earned our trust, yet.
Worse still, even the foundations of this supposed federal shift are dangerously unstable.
Case in point: According to Dr. Locke, no one—not Congress, not the federal agencies charged with leading the transition—can even agree on what NAMS actually are.
There’s no shared terminology or definition, no consensus among the stakeholders and regulators, no clear boundary for what qualifies and what doesn’t. The result, in Dr. Locke’s words, is an absence of any “[a]greed upon articulation of critical concepts”—a failure that makes real progress nearly impossible.
Dr. Locke’s Grade for Congress: D
Congress says it supports the transition to NAMS, but, of course, talk is cheap.
Despite considering several promising bills—like the FDA Modernization Act 3.0, the Humane Cosmetics Act, and the Federal Research Accountability Act—Congress has failed to use its power to meaningfully shift federal science policy away from animal experimentation. As Dr. Locke puts it, Congress has done little to back its rhetoric with action.
Perhaps even more troubling? Many lawmakers do not appear to understand key distinctions—like the difference between applied and basic science.
Overall, says Dr. Locke, Congress may be talking the talk, but it’s not walking the walk.
Dr. Locke’s Grade for EPA: B
Of the leading federal agencies, Dr. Locke says the EPA is furthest along in supporting a shift away from animal research. The agency has developed a roadmap for reducing animal use in chemical testing, and its recent 2035 pledge signals potential progress.
But, let’s not forget: 2035 is nine years away—and animals are still being poisoned and killed in EPA labs today.
Still, says Dr. Locke, real opportunity for change exists.
Dr. Locke’s Grade for FDA: D
Despite the passage of the FDA Modernization Act 2.0 in 2022, the FDA continues to rely almost entirely on regressive, unreliable, and unethical animal tests—and Dr. Locke shared recent findings that the FDA’s use of NAMS remains extremely low.
So, even though the FDA has been “talking the talk” about NAMS since the early days of Trump’s second term, the agency has yet to turn its words into action.
Dr. Locke’s Grade for NIH: C
The NIH—the largest funder of animal research in the world, which also decides how research is conducted, establishes what kinds of models are deemed “credible,” and supplies scientific information and data to other agencies—is still clinging to animal models; it’s still propping up the very status quo it claims to want to move beyond; and it’s still positioning NAMS as complements to (not replacements or displacements of) animal research. (We warned about this back in mid-2025, and it’s still true.)
Dr. Locke warns that the NIH’s grade could drop even further depending on upcoming funding decisions.
The Bottom Line: It’s all unstable.
The entire promise of change remains unmoored—and the risk is very real.
If we don’t legally lock in changes over the next three years, any forward progress could vanish overnight with the next administration.
We’ve seen that happen before—including in 2020, when EPA’s promise to end animal testing was gutted behind closed doors.
And, it will happen again, unless we can stop it. Which means:
We can’t wait to act.
We can’t blindly trust.
And we absolutely can’t celebrate empty pledges while animals remain locked in laboratories.
We need deadlines.
We need laws.
We need accountability.
And, we need to fight for it all—right now.
Your Call to Action: Send a letter urging your U.S. Representative to support the FDA Modernization Act 3.0. This bill would require the Food and Drug Administration to revise its regulations to remove the requirement for animal research. The Senate has already passed this bill.