On 9 September 2026, the Netherlands National Committee for the protection of animals used for scientific purposes (NCad) published ‘From niche to norm – Transition Policy Advice: working together towards a society without animal experiments’. The advice, presented to the Ministry of Agriculture, Fisheries, Food Security and Nature, was produced on NCad’s own initiative and follows its 2016 transition advice and an evaluation of how that advice was implemented. It was informed by an open survey, stakeholder meetings involving representatives from research, industry, government and civil society, and commissioned work on transition studies and animal ethics (see EARA’s Policy Briefing – Issue 30-2025 and Issue 9-2026). EARA participated in these stakeholder meetings.

The new advice retains the ultimate ambition of a society without animal experiments, but significantly changes the way NCad proposes reaching it.

NCad places greater emphasis on changing the wider system in which animal research takes place. NCad argues that animal-free innovation will not automatically lead to further reductions in animal use unless legislation, funding, assessment practices, institutional structures and other parts of the research system change alongside it. NCad therefore presents the transition as a shared societal responsibility, involving government, researchers, funders, industry, regulators and civil society, rather than a responsibility placed primarily on individual researchers.

Validation of NAMs is one example of the system changes NCad envisages: animal-free methods should be judged not by how closely they reproduce the results of an animal experiment, but by how well they serve their intended purpose and relevance to the human, animal or ecosystem being studied.

The report does not set an end date for animal research. While NCad found unanimous support among stakeholders for the development of animal-free innovations, it also acknowledges diverging views on the pace, feasibility and scope of a transition. The report outlines how the proposed transition is intended to act as a ‘compass’ rather than a predicted or planned linear process. Different research categories will follow different pathways and require tailored interim objectives. Nevertheless, NCad has not moderated the ultimate objective itself: the objectives definition extends across research and education and also includes eventually ending the use of animal-derived research products such as foetal bovine serum and basement membrane extracts (Matrigel, for example).

NCad distinguishes between the transition and the implementation of the 3Rs. The report acknowledges the importance of refinement and efforts to further improve animal welfare while animal research is still conducted, but argues that improving existing animal research does not by itself constitute a transition. In NCad’s view, these are two different areas that should be pursued in parallel.

NCad groups its recommendations under five pillars: 1) governance and ownership, 2) reassessment of the ethical framework, 3) innovation and ecosystem policy, 4) international strategy, and 5) progress and monitoring. It places particular emphasis on governance, calling for the transition to become an inter-ministerial mission with clearer responsibilities, dedicated policy agendas and an independent coordinating role to monitor progress and connect activity across policy areas.

NCad also recommends revising the ethical framework for animal research, including the harm-benefit assessment, so that animal interests and uncertainties around expected research benefits are considered more explicitly. The remaining recommendations focus on improving the funding, validation, teaching and regulatory acceptance of animal-free innovation, strengthening international coordination and developing a broader system for monitoring progress.

The renewed advice contains several important points that EARA considers constructive, including the recognition that responsibility for transition cannot rest primarily with individual researchers or institutions, that different research areas will progress at different rates, that no overall end date should be imposed and that a transition should not come at a cost of refinement.  This is a significant change from the original advice issued in 2016. However, much of the advice remains high-level and abstract, particularly in its recommendations for system change. Its practical significance will therefore depend on how the Dutch government and other actors respond, and how the recommendations are translated into concrete policy and implementation.

The report makes some useful choices in terminology. NCad opts for ‘animal-free research’ rather than ’human-relevant’, explicitly noting that research involving animals can also be relevant to humans and that the animals themselves may be the intended beneficiaries. EARA strongly supports this important distinction, as ‘human-relevant’ is increasingly used as a substitute for ‘human-derived’ when talking about human cell-based methods.

NCad’s advice shares several important features with the European Commission’s Roadmap towardsphasing out animal testing in chemical safety assessments. Both emphasise that technological development alone is insufficient and that progress also depends on validation, regulatory acceptance, coordination and changes to the wider system in which methods are developed and used. Both also recognise the importance of international harmonisation and avoid predictions or goals regarding end dates. The main differences are scope and level of detail. The EU roadmap focuses on a defined regulatory domain and can therefore set out relatively concrete actions and implementation steps. NCad, by contrast, addresses animal use across research and education as a whole and consequently operates at a more strategic and general level, with greater emphasis on governance, ethical reassessment and societal responsibility.

The UK strategy, Replacing Animals in Science,  is broader than the EU roadmap but is still more implementation-focused than the Dutch advice, with a five-year programme, named responsible bodies and specific targets for replacing particular tests. Recent US initiatives are more targeted still, focusing mainly on particular regulatory and biomedical applications. In that sense, NCad’s advice is distinctive in combining a very broad scope with a system-level transition framework, but this also means that many of its recommendations remain high-level and their practical implications will depend on how they are translated into policy.