This is because tampons are subject to greater regulation by FDA than pads and liners. Pads and liners are low-risk FDA-regulated Class I medical devices, while tampons are moderate-risk FDA-regulated Class II devices. Higher class products are subject to more stringent safety and effectiveness standards, so as a general rule, the higher the Class number, the more testing data required to demonstrate consumer safety to the FDA and clear them for sale in the US.
For example, LOLA pads and liners (Class I medical devices) were developed and tested for safety without animal tests.
Conversely, before the launch of any new tampon (a Class II medical device), the FDA requires manufacturers to pass certain safety evaluation tests in accordance with the international consensus standard, ISO 10993 - parts of which require animal tests to demonstrate safety. All manufacturers have to pass ISO 10993 in order to obtain FDA 510(k) clearance, which is necessary for selling tampons in the US. Again, this testing standard applies to all tampon brands in sold the US.
We always prioritize using alternative non-animal testing methods, so we were thrilled when the FDA released a new guidance document on June 16, 2016 that allows companies to present alternative methods of evaluating the safety of Class II medical devices in certain circumstances. Since its release, we’ve required our manufacturers to use the new guidance to demonstrate the safety of any newly developed Class II medical device through permissible alternative, non-animal test data whenever possible.