Australia Plans Tougher Sunscreen Testing After SPF Failures Shake Consumer Trust

Finished products would face repeated SPF checks

Australian sunscreen suppliers would have to submit evidence supporting their protection claims before listing products for sale and repeat testing throughout their shelf life under reforms announced by the Therapeutic Goods Administration (TGA) on October 27, 2026.

The proposals follow consumer group CHOICE's June 2025 testing, which found that 16 of 20 sunscreens fell short of their advertised sun protection factor, or SPF. Ultra Violette's Lean Screen Skinscreen, labelled SPF 50+, returned a result of SPF 4 and was voluntarily recalled in 2025. Another 19 products sharing its base formula were subsequently recalled.

The TGA wants companies to test the finished sunscreen consumers buy, rather than relying on testing of its base formula. Laboratories would face stronger accreditation requirements, while some cosmetic products would face limits on the SPF claims they can make.

One central disagreement remains: companies would submit their results confidentially, and the regulator says it would not routinely check the data before products reach shelves. CHOICE wants public results, routine scrutiny and testing conducted by the regulator itself.

The TGA developed the proposals after a consultation running from March to May 2026 that attracted almost 120 responses from manufacturers, laboratories, health professionals, consumer groups, academics and other participants. Implementation would take place in stages, with some measures requiring further consultation or changes to legislation.

For shoppers, the intended change is straightforward: stronger evidence behind the number on the bottle. For suppliers, it means responsibility for checking the sunscreen as sold and maintaining evidence that it continues to perform during its shelf life.

What went wrong with sunscreen confidence?

CHOICE's testing found that 80 percent of the 20 products examined did not meet their SPF claims. Several were premium products, making the findings troubling for consumers who had paid more while expecting dependable protection.

SPF measures protection against the ultraviolet radiation that causes sunburn, mainly UVB. Under controlled testing conditions, a higher SPF means more protection. The rating depends on how the product performs when applied at the amount required by the test, rather than simply on which ingredients appear on its label.

The TGA's chief medical adviser, Professor Robyn Langham, said its investigation pointed to several possible contributors to low results:

Our investigation has identified multiple factors that could contribute to low SPF results — not a single cause.

The response has developed over more than a year:

• June 2025: CHOICE published testing showing that 16 of 20 sunscreens fell short of their labelled SPF.
• During 2025: Ultra Violette's Lean Screen Skinscreen was voluntarily recalled after returning SPF 4 despite an SPF 50+ label. Recalls extended to 19 products sharing its base formula.
• March to May 2026: The TGA sought public feedback on changes to sunscreen regulation.
• October 27, 2026: The regulator announced the reforms it would develop following almost 120 consultation responses.

The TGA has yet to publish the full findings of its investigation into the testing controversy. It has also not specified how every proposed requirement would apply to sunscreens already on sale or set a complete implementation timetable.

Why testing the finished sunscreen matters

A base formula is the underlying mixture from which a sunscreen product is developed. Testing the finished product means checking the formulation consumers actually purchase, including the ingredients present in that version.

Under the proposed rules, suppliers would have to provide SPF results when listing a sunscreen with the TGA. They would also need to test it periodically during its shelf life. At present, companies must provide SPF testing data only when the regulator requests it.

Repeated testing would address a different question from testing before sale: whether the product continues to deliver its claimed protection over time. A sunscreen needs to perform when a consumer uses it within its stated shelf life, not just when a formulation is first developed.

Langham described the intended purpose of the changes:

This is about making SPF claims more reliable, reinforcing suppliers' responsibility for their products and giving the TGA faster access to evidence when concerns arise.

Faster access would matter when a complaint or unexpected laboratory result triggers an investigation. The regulator would already hold the submitted evidence, rather than first having to request it from the supplier.

Who would check the results?

The TGA's proposal would require more information from suppliers, but it would retain a system in which companies carry substantial responsibility for the evidence behind their products. Submission of results would become a condition before market listing, while routine examination of those results before sale is not proposed.

Andy Kelly, CHOICE's director of consumer impact, welcomed requirements to test finished products and provide the results to the regulator. He said the remaining gap concerned what happens after companies hand over the data.

Kelly called for consumers and the regulator to have a more active role in scrutinising the evidence:

In the interest of transparency and public safety, we believe these results should be made available to everyone and that the TGA should routinely monitor test results, as well as conduct its own compliance testing program.

The TGA considered public disclosure but cited concerns about confidentiality, intellectual property and the potential for highly technical data to be misinterpreted. Its proposal would keep the results confidential.

Consumers would therefore still depend on suppliers to support their claims and on the regulator to investigate concerns. CHOICE's request for compliance testing would add checks initiated by the TGA, alongside the evidence that companies commission and submit themselves.

Plastic plates could join human testing

The TGA also proposes allowing a laboratory method known as in vitro testing alongside the existing in vivo method. These terms describe where the measurement takes place: outside a living body or on a living person.

Current in vivo testing involves applying sunscreen to volunteers and measuring protection under simulated sunlight containing ultraviolet radiation. The proposed in vitro approach would test sunscreen spread onto plastic plates, using instruments to assess its interaction with ultraviolet light.

The regulator cited substantial concerns about variability in results from human testing. Differences between test results can make it harder for manufacturers and regulators to determine a reliable SPF claim.

Professor Nial Wheate, a pharmaceutical chemistry specialist at Macquarie University, supports introducing in vitro spectroscopic testing to improve confidence in sunscreen performance. Spectroscopic testing uses measurements of light to examine how a sample behaves. He also recommends a phased introduction so the industry has time to adopt the new methods. Wheate disclosed that he is a cofounder and chief scientific officer of a skincare company with a sunscreen product.

Human testing would remain part of the system. The TGA says the plate method may not suit every formulation or testing of water resistance. Suppliers would need access to an appropriate method for the particular sunscreen and the claims made about it.

Laboratories would face stronger requirements

The TGA currently does not regulate or accredit laboratories conducting SPF tests. It proposes stronger international accreditation requirements for laboratories testing sunscreens supplied in Australia.

Accreditation is a formal assessment of whether a laboratory is competent to carry out particular tests. For sunscreen, it would provide an additional check on the testing operation that produces the evidence behind a label.

More than half of the sunscreens that failed to meet their claims in CHOICE's testing had used an overseas laboratory whose results came under scrutiny. The proposed accreditation requirements would apply to laboratories testing products for the Australian market.

The TGA acknowledges that stronger requirements could increase testing costs and make suitable laboratory services harder to access. More frequent product testing would also increase demand for those services.

Terry Slevin, chief executive of the Public Health Association of Australia, welcomed efforts to make testing consistent and reliable, while calling for changes that do not increase sunscreen prices. His concern places affordability alongside laboratory quality: families need access to sunscreen they can use regularly.

Cosmetics and primary sunscreens would be treated differently

Some cosmetics can currently claim protection as high as SPF 50+ without being listed as therapeutic goods. The TGA proposes limiting the SPF claims of cosmetic sunscreens to make their role clearer to shoppers.

A primary sunscreen is intended principally to protect against ultraviolet radiation. A cosmetic sunscreen has another main purpose, such as providing makeup coverage or moisturising skin, with sun protection as a secondary function.

Dr Hilary Bowman-Smart, a research fellow at Adelaide University, said the boundary between health products and skincare can leave consumers uncertain about what to buy. She called for clearer distinctions so shoppers can identify products intended to provide meaningful sun protection.

The regulator also plans to develop quality requirements for specific sunscreen ingredients. Its review will examine good manufacturing practice guidance, which sets expectations for how manufacturers consistently produce and control their products.

Ingredient standards and manufacturing guidance address stages before a finished sunscreen reaches the laboratory. Combined with product testing, they would place attention on how the sunscreen is made as well as how it performs.

SPF labels will undergo a later review

The TGA is keeping changes to SPF labelling for further review and consultation. Options discussed during consultation included replacing the current numerical approach with categories such as low, medium, high and very high.

No replacement labelling system has been adopted. The immediate reform programme focuses on testing, ingredient quality, manufacturing responsibilities and the boundary between cosmetic products and primary sunscreens.

Associate Professor Anna Wang said the amount applied and the frequency of reapplication can matter more than small differences in SPF readings. For consumers, the protection a product provides in daily use depends on both its tested performance and how it is used.

Changing a number to a category would alter how protection is communicated on packaging. The TGA plans to seek further views before deciding whether to proceed with such changes.

Public health leaders urge continued protection

Australia has the world's highest incidence of skin cancer, according to the TGA. CHOICE points to an estimated two in three Australians receiving a skin cancer diagnosis during their lifetime, making dependable sunscreen a substantial public health concern.

The burden also varies by location. Professor Leigh Kinsman highlighted melanoma rates in Victoria's Loddon Mallee region that are 63 percent above the state average. Reliable and affordable protection matters especially in communities carrying a heavier burden of disease.

Professor David Whiteman, a distinguished scientist in the Cancer Control Group at QIMR Berghofer, supports tougher testing and manufacturing scrutiny. He also said most Australian sunscreens remain highly effective at preventing sunburn and that daily use when the UV index is forecast to reach 3 or more reduces skin cancer risk.

Slevin urged Australians to keep using sunscreen as part of a wider set of protective measures. Those include seeking shade, wearing protective clothing and a hat, and using sunglasses. He also advised applying the correct amount of sunscreen to exposed skin 20 minutes before going outside.

The reforms seek to make protection claims more dependable while keeping this daily health measure accessible. The decisions still to come concern how quickly the new requirements begin, how laboratory capacity and costs are managed, and whether the TGA expands its own routine checks.

Key Points

• The TGA announced proposed sunscreen reforms on October 27, 2026, following almost 120 consultation responses.
• CHOICE's June 2025 testing found that 16 of 20 products fell short of their advertised SPF.
• Suppliers would test finished products, submit results before listing and repeat testing throughout shelf life.
• Results would remain confidential, and routine TGA checks before products reach shelves are not proposed.
• The regulator proposes additional testing methods, stronger laboratory accreditation and quality requirements for specific ingredients.
• Cosmetic SPF claims would face limits, while broader changes to SPF labels would undergo later consultation.
• Public health specialists urge continued sunscreen use alongside shade, protective clothing, hats and sunglasses.