"To me, it's totally unnecessary to experiment on animals with party pills," SPCA national president Bob Kerridge said.
"There's absolutely no justification for it, no matter which way you look at it."
Mr Dunne said he had "a great deal of sympathy" for the view that it was sad to test legal highs on animals as opposed to testing necessary medicines.
"I understand that but I think we should see very different questions if we do not test these products and someone dies," he said.
Mr Dunne said the Ministry of Health was "actively working on finding alternatives to animal testing".
No decisions will be made without consulting with other ministries and ethics groups, Mr Dunne said.
He said criticism from the Greens about testing on animals was "ironic in the extreme".
"They need to take a long look at their own unrelenting pro-drug history," Mr Dunne said.