The call for a planned phase-out is at the forefront of the political debate about animal experimentation. While authorities like the European Commission start taking a strategic approach to regulatory animal testing, they refuse to develop specific roadmaps for the phase-out of animal research. I articulate the central argument that is advanced against phase-out planning in animal research, the argument from avoidable harms: By restricting research, we may incur avoidable future harms and thus, while we may regret having to use animals in ways that harm them, for the sake of avoiding future harms we must not phase out animal research. The discussion of this argument yields two Conclusions: First, it applies only to ban-based phase-out plans, but not to plans consisting of a range of other interventions known from the literature on transformative governance. Second, the premises of the argument construe animal research as a necessary evil, thus as a conflict of unequal duties. But we have a duty not just to avoid avoidable harms, but also to avoid avoidable moral conflicts. This we can only do by taking a strategic approach. Thus, what initially looks like an argument against phase-out planning is in truth an argument for ban-free phase-out planning. This finding is important for practice because it shows that while government authorities’ reluctance to issue bans may be justified, their refusal to undertake strategic planning for the phase-out of animal research is not.

The use of non-animal, new approach methodologies (NAMs) is increasing but there has been no associated decrease in animal use. Reasons may include th…

Why (and how) total numbers should matter for animal experimentation policy