The short answer: No, La Roche-Posay is not entirely cruelty free.
The long answer: Acquired by L’Oréal in 2018, La Roche-Posay is a dermocosmetic brand that is sold worldwide. It is highly recommended by dermatologists for people with sensitive skin. On its US website, La Roche-Posay shares its stance on animal testing. “La Roche-Posay does not test any of its products or any of its ingredients on animals, anywhere in the world nor does La Roche-Posay delegate this task to others. The only possible exception is if regulatory authorities required it for safety or regulatory purposes.” The last statement pertains to countries such as China, where La Roche-Posay (and other L’Oréal brands like Redken and Kiehl’s) is presently sold.
It is a known fact that imported beauty brands entering China need to undergo mandatory product testing, which are sadly done on animals. Aside from this, licensed third parties for the Chinese government may conduct random tests when the products are already on the shelves. Because of these facts, La Roche-Posay cannot claim to be cruelty free.