SPFictions - Inside the Systemic Failures of Sunscreen Regulation in Australia
By Stefanie Milla CEO – Aesthetic & Beauty Industry Council
The CHOICE article that shook the industry, didn’t tell my fellow formulators anything new. But it finally told the public.
CHOICE tested 20 sunscreens and found that 16 failed to meet their labelled SPF claims, the consumer watchdog did more than just cause controversy, it spotlighted deep, long-ignored flaws in Australia’s sunscreen regulation framework. Behind every underperforming sunscreen is a potential story of rushed development, inconsistent testing, and a regulatory body that too often trusts rather than verifies. And in a country where skin cancer rates remain among the highest globally, this is not just a cosmetic issue. It is a public health concern.
The TGA System: Rigorous in Theory, Fragile in Practice
On paper, Australia’s sunscreen regulations are among the world’s strictest. The Therapeutic Goods Administration (TGA) mandates adherence to AS/NZS 2604:2021, which uses validated in vitro methods to determine SPF and UVA performance. These methods avoid the ethical issues of in vivo testing, reduce variability, and offer reproducibility. However, this strength also masks a major weakness: the system depends almost entirely on the integrity of the sponsor’s data.
No routine, independent testing is performed by the TGA. Instead, the sponsor (brand or manufacturer) must hold testing data at the time of ARTG listing. After that, unless a complaint is lodged, the product may never be tested again. Essentially, it’s a high-stakes honour system with minimal oversight.
From a formulator’s perspective, the pressures to bring products to market quickly can clash with the need for rigour. Independent brands, constrained by budget and access, may rely on a single round of in vitro testing performed on lab samples rather than full production batches. Stability testing is often abbreviated. Batch-to-batch verification is rare. Shelf-life testing? Sometimes skipped altogether.
These shortcuts mean a product can enter the market with good intentions, yet fail consumers within months due to degradation, poor packaging compatibility, or subtle formulation drift. The TGA will only investigate if someone complains. But by then, how many Australians have suffered burns or put false trust in faulty protection?
Real Risks, Real Costs
Australia spends over $1 billion each year treating skin cancer. Shockingly, melanoma is the most common cancer for people aged 15 to 39. When sunscreens underperform, it’s not just about consumer choice and transparency right. It’s about increased exposure to UVA and UVB radiation, DNA damage, premature aging, and preventable cancers.
A single sunscreen testing below SPF30 when it claims SPF50+ may lead to thousands of users receiving one-quarter of the protection they believe they have. This is a failure of both science and policy.
Formulation Pressures: Cutting Corners, Losing Confidence
Small brands face enormous challenges. Testing each batch can cost thousands. Waiting for a lab slot during peak season delays launches. Add marketing pressure to slap an SPF50+ on the label, and the temptation to cut corners is real. This often leads to:
The reality is a consensus among many formulators, privately sharing that they’ve felt pressured by brands to approve borderline formulations with incomplete or inadequate testing, often due to commercial timelines or cost constraints. These are not rogue operators. They are brands trying to survive in a broken system.
No Watchdog Without a Whistle
The CHOICE report acted as a proxy regulator, doing what the TGA does not: independently testing sunscreens already on the market. It uncovered what insiders have long whispered about, that without random, ongoing auditing, non-compliant products will continue to circulate.
This absence of independent verification undermines consumer confidence, especially when companies respond with conflicting lab data. If one lab says SPF60 and another SPF20, who is right? Without a neutral third party retesting periodically, we will never know.
What Can Be Done: The ABIC Regulatory Committee's Push for Reform
The Aesthetic and Beauty Industry Council (ABIC) has launched a comprehensive investigation into these issues. Our draft report outlines systemic weaknesses and proposes the following:
These reforms would shift Australia from reactive to preventative regulation. They would elevate confidence, level the playing field for responsible brands, and protect the public.
Next Steps to Rebuilding Trust, One Test at a Time
The SPF number on a bottle should not be a gamble. It should be a promise backed by science, stability, and surveillance. The CHOICE article was a wake-up call. Now we must act.
ABIC invites all skincare professionals and brands to contribute to our regulatory reform and contribute in one the following ways:
