MAC's public policy on animal testing says that the company "does not test on animals," does not ask other people to test for them, and only uses non-animal methods, such as human volunteer trials and in vitro testing.
But MAC also says that in some places, like mainland China, products that are brought in may have to be tested on animals before they can be approved.
Many cruelty-free groups, such as PETA and Ethical Elephant, don't think MAC is completely cruelty-free because it sells in places where animal testing is still required by law.
If your cruelty-free standard is "no testing on animals by anyone, anywhere, including governments," then MAC doesn't meet that standard.
If you accept "brand doesn't test directly but follows the law," then you might like their policy more.