By Stefanie Milla, CEO of the Aesthetic & Beauty Industry Council (ABIC) & Director at Dermalist Skincare
Australia’s sunscreen industry is facing serious scrutiny, this time from inside and out. When CHOICE went public with its recent sunscreen investigation, showing that 16 out of 20 sunscreens did not meet their SPF label claims, some by shocking margins, it didn’t just spark consumer and industry concern. It ignited long-overdue industry introspection.
As a formulator and CEO of the Aesthetic & Beauty Industry Council (ABIC), I have been a long-time advocate for integrity in skincare, so I wasn’t surprised. I was relieved. Finally, a public spotlight on a problem formulators have known for years: sunscreen SPF is fragile. What you see on the label isn’t always what ends up on the skin.
This article lifts the lid on why SPF variability is so prevalent, what’s broken in our current system, and what the beauty industry can do to reform it, together.
How Sunscreen SPF is Determined in Australia
Australia is unique in its regulatory approach. Unlike the US and EU, which primarily use in vivo (human) testing, the TGA mandates in vitro testing, lab-based simulations using substrates like PMMA plates. This decision was made to avoid ethical concerns around sunburn testing on humans and improve consistency across brands.
Under AS/NZS 2604:2021, products must be tested in accredited labs to confirm:
- SPF value using spectrophotometric UVB absorption testing
- Broad-spectrum protection using critical wavelength (≥370 nm)
- Water resistance, where claimed, through validated immersion testing
Yet even with these robust standards, the system breaks down in practice.
Where It All Falls Apart: The Real-World SPF Challenges
SPF doesn’t just depend on the lab test. Between formulation, manufacturing, packaging, and shelf-life, dozens of variables can erode performance. Here’s where it goes wrong:
1. Formulation Stability & Photostability
- UV filters must be uniformly dispersed and stable under heat, light, and oxygen
- Some filters (like avobenzone) degrade under sunlight unless stabilised
- Inorganic filters can trigger degradation if uncoated
2. Packaging and Shelf-Life
- Sustainable packaging may lack the barrier properties needed to prevent oxidation
- Heat exposure in transport or storage can denature actives
- Without stress testing, SPF might decline well before the expiry date
3. Manufacturing & Batch Variability
- Even minor inconsistencies in mixing, dispersion, or raw ingredient quality can impact the final SPF
- Most brands don’t re-test every batch due to cost or lab capacity constraints
4. Reformulations Without Re-Validation
- A simple preservative swap or supplier change can affect SPF
- Without re-testing, products may no longer match their original claims.
This Isn’t About Finger-Pointing
Let me be clear: the issue here isn’t just about manufacturer or brand ethics. Yes, it’s the primary target of the current spotlight, but we must also understand the complexity involved. Manufacturers are often operating with limited budgets, high consumer expectations, and logistical constraints. SPF testing is expensive, time-consuming, potentially inaccurate and not always accessible.
Unfortunately, our current system relies too heavily on trust. Brands must hold evidence at the time of ARTG listing, but there’s no requirement for re-validation unless prompted by a complaint. Without routine independent re-testing, underperforming products can go undetected for years.
The CHOICE report acted as an unofficial audit, and the results were alarming.
“SPF testing is expensive, time-consuming, potentially inaccurate and not always accessible.”
Restoring Trust: Practical, Industry-Led Solutions
That’s why ABIC has drafted a comprehensive report outlining practical reforms. Our goal is to support brands in delivering safe, effective sunscreens that meet consumer expectations, and advise the TGA and regulators of the challenges involved.
Key recommendations include:
- Periodic Independent Testing
Annual, random SPF testing by accredited labs to confirm real-world performance - Shelf-Life Validation
Require photostability testing after accelerated aging to prove the SPF holds near expiry - Testing Subsidies for Small Brands
Establish a national sunscreen testing facility or grant program to reduce cost barriers - Improved Label Transparency
Allow brands to state the tested SPF range and batch test dates to build consumer trust - Routine Auditing & Penalties
Strengthen TGA and ACCC enforcement mechanisms to deter misleading claims.
What It Means for Therapists and Practitioners
As professionals trusted with skin health, beauty therapists need clarity. If a product says SPF50+, it should perform as SPF50+, not SPF22 or worse. Knowing the systemic challenges helps you educate your clients, choose products wisely, and demand higher standards from suppliers.
Help Shape the Future of SPF Standards
ABIC is now inviting formulators, brands, and industry professionals to review our draft report and help refine our recommendations. Your input ensures this proposal reflects both scientific rigour and real-world feasibility.
The ABIC Draft Report on SPF Accuracy and Reform is now open for industry review.
Download HERE – https://theabic.org.au/abic-in-action-shaping-our-industry
ABIC’s Regulatory Committee and help shape the future of sunscreen reform.
Join HERE – https://theabic.org.au/abic-self-regulation-committee
To contribute, contact stefmilla@theabic.org.au
Follow the conversation on Instagram @aestheticbeautycouncil and @thestefmilla.
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