Learning from the UK: what Switzerland can learn from UK’s new 3R strategy

Compared to earlier international initiatives, the UK’s policy paper “Replacing animals in science: A strategy to support the development, validation and uptake of alternative methods” that was published in November 2025 stands out for its scope, level of detail, and its strong focus on scientific innovation and regulatory acceptance of alternative methods. What does this mean for ongoing discussions around the 3R principles and the potential transition in Switzerland? To explore these questions, Nico Müller shares his assessment of the UK approach, its strengths and limitations, and its relevance from a Swiss perspective.

What is your overall assessment of the new UK strategy to replace animals in science?

Compared to previous strategy papers from other countries, the UK strategy is among the most comprehensive and detailed so far. Unlike the EU’s animal experimentation reduction roadmap, which focuses mainly on reducing animal testing for regulatory purposes, the UK strategy addresses scientific research more broadly, while keeping regulatory acceptance in mind. It is also more specific on how it will increase support for replacements than, for example, the transition strategy commissioned in 2015 by the Dutch government or the – still unpublished – German draft reduction plan.

Which elements of the UK strategy do you consider particularly strong or innovative?

Although the strategy focuses on supporting the innovation, validation, and utilisation of alternatives, it also states a commitment to invest in data-driven biology. The hope is that using existing data in new ways – sometimes with the help of artificial intelligence – can enable breakthroughs, for instance in drug discovery. This is noteworthy because it is not just about replacing one material model, the animal, with another, the Novel Alternative Method, but about asking questions that do not require the direct use of material models in the first place. The US National Institutes of Health have mentioned a similar approach in recent communications.

From a Swiss perspective, which aspects of the UK’s approach could be most relevant or transferable to Switzerland? In which areas could Switzerland realistically learn from or build on the UK model?

In Switzerland, a major concern is that a transition strategy would effectively amount to a gradual ban on animal experimentation. This fuels fears that research freedom would be restricted, innovation slowed down, or animal experiments simply moved abroad. The UK strategy indicates that it is possible to promote a transition away from animal experimentation largely without introducing new restrictive regulations. Instead, it focuses on funding, building infrastructure, and creating or adapting institutions. If Switzerland were to adopt a transition strategy in the future, it would likely need to follow a similar approach—what could be described as ‘planning without banning’.

What is your view on the balance struck in the UK strategy between promoting alternatives and acknowledging that some animal research will continue?

The strategy divides animal experiments into three categories. The first includes experiments that can already be replaced, the second those for which alternatives exist but still need validation, and the third those for which no replacement methods are currently available. The strategy is most concrete for the first two categories. For example, it aims to end the use of the Rabbit Pyrogen Test in the UK by 2026, and to reduce the use of dogs and non-human primates in certain pharmacokinetic studies by 35 percent by 2030. The third category, however, is the largest and most challenging. Here, the strategy mainly relies on increased support for bottom-up innovation but avoids setting very specific targets. Overall, this shows a cautious approach that avoids making promises that cannot yet be kept.

Is it scientifically realistic to expect that most animal experiments can be replaced in the near future by alternative methods?

The UK strategy itself does not claim that most animal experiments can be replaced in the near future. Still, the question is important. One fundamental challenge is that new animal experiments are constantly being developed, especially in basic research. Advances such as genetic modification, new imaging techniques, or the use of previously uncommon animal species continuously create new applications that then take a lot of work to replace. I discuss this dynamic in an article in the European Journal for the Philosophy of Science, where I refer to it as ‘Lane-Petter’s Pipeline’. The concept, first described in 1961 by the scientists of that name, suggests that a true transition requires not only replacement methods, but also a shift in what kinds of models are being innovated in the first place.

The European Union is also moving towards a coordinated strategy on alternative methods and the 3Rs. How important is international alignment in this field, and what risks do you foresee if countries move at different speed?

To some extent, the UK strategy recreates structures that were lost through Brexit. For example, a new validation institute for alternatives will be created, called UKCVAM, because the country is no longer a member of the European equivalent, EVCAM. This may be the best solution under the circumstances, but cooperation across borders remains essential, especially in the validation of alternatives for regulatory purposes. When it comes to science policy, however, some diversity in approaches might be useful. If different countries test different policy mixes, it increases the chances that effective solutions emerge. Switzerland could adopt a wait-and-see approach, but this is difficult to reconcile with its self-image as a leader in animal protection. It may also mean missing out on potential economic advantages as an early mover.