Avit, it is in China. The tests are not performed by Avon, but their products are legally required to be by Chinese law, therefore they are not cruelty free. To be claim to genuinely cruelty free they need to stop selling in China.
The following is an extract from Avon's own declaration on their website:
'If Avon doesn’t test on animals, why does PETA include Avon on a list of companies that test on animals?
Although Avon does not test on animals, PETA includes Avon on its list of companies that sell beauty products in China. China legally requires animal testing on products it designates as “special use” - such as sunscreens and deodorants - sold in China, as well as ordinary cosmetics imported into China. The Chinese government conducts the tests at laboratories accredited by the Chinese Food and Drug Administration.
Are any of the Avon products tested in China sold in countries other than China?
No Avon products that have been tested by China is sold by any Avon market in Europe, Middle East, Africa or Latin America. Our goal is for no Avon products that have been tested by China to be sold by any Avon market other than China by the end of 2019.'
So they appear to be heading in the right direction, but they still allow animal testing on their products by China. That does not make them cruelty free in my mind.