Xenotransplantation offers a new solution to the crisis of organ shortage, with genetically edited pigs becoming key donor animals. However, this technology has transformed the role of donor animals from traditional experimental subjects to living organ bioreactors, raising multiple ethical challenges across species, genetic intervention, and public health that mark a shift in the ethical review of laboratory animals from management of usage to governance at the source. Based on the dual perspectives of laboratory animal science and ethical review, this article systematically analyzes the core dimensions of ethical review for xenotransplantation donor pigs, including animal status, risk attributes, technical uncertainty, and ethical conflicts. By reviewing the ethical review concepts and practices regarding cross-species transplantation both domestically and internationally, it reveals the structural dilemmas in the current ethical review in terms of standards, capabilities, and collaborative mechanisms. Suggestions are proposed for constructing an animal xenotransplantation ethical review system in China, integrating substantive ethical assessment and cross-sectoral collaboration, aiming to promote ethical review from formal compliance to substantive governance and providing ethical support for the healthy development of cross-species organ transplantation in China.