Existing sunbed regulation isn’t providing sufficient consumer protection.


In 2017 it became illegal for sunbed operators to allow an underage person to use a sunbed. Despite this, 2 operators in our latest mystery shopper survey let our under-18 shoppers have a sunbed session. And 6 operators let a person with fair skin, which burns easily, use a sunbed.

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Using a sunbed is a health risk to anyone. But for people under 18 or with fair skin, the potential for lasting and serious damage increases.

Underage shoppers

The more you use a sunbed and the younger you start, the higher your risk of getting skin cancer. According to the World Health Organization’s International Agency for Research on Cancer, using a tanning device before age 30 increases the risk of melanoma by 75%.

The Health Act bans operators from allowing under-18s to use a sunbed. Despite this, 2 of the 20 operators we visited were prepared to let our underage shoppers have a session. The shoppers didn’t use the sunbed but completed our survey form in the tanning cubicle.

At Fred & Gingers Hair & Beauty Salon in Invercargill, our 16-year-old shopper wasn’t asked his age, even though he was with his mother. Salon staff didn’t do a skin assessment or ask him to fill out a consent form. When he left, he was given a consent form to complete at home – a bit late when he’d already had the session!

Fred & Gingers’ owner Natasha King said the salon “will be immediately implementing stronger checks to ensure this doesn’t happen again”.

At Solaris Clinic in Auckland, our 15-year-old filled out a consent form, which included her age. However, the staff member still allowed her to have a session without checking the form. The session was cut short when the operator realised our shopper was underage.

Solaris Clinic owner Michael Wojcik said the staff member who allowed the sunbed was undergoing training and forgot to check the shopper’s age. “This goes against our operating procedures and disciplinary action, as well as further staff training, was undertaken.” As a result of our survey, Solaris has installed “R18” stickers in reception and highlighted the age restriction on new client forms.

Allowing underage shoppers to use a sunbed can result in a fine of up to $2000 for an individual, or up to $10,000 for a company. We’ve reported these operators to the Ministry of Health.

Operator Sunbed refused
Auckland region
Actuelle Beauty Therapy Clinic, Pakuranga Yes
Body Bronze, Manukau Yes
Essence of Beauty, Albany Yes
Eurotan, Royal Oak Yes
Fitness Plus, Manukau Yes
Headstart Total Body, Glen Eden Yes
MegaSun Suntanning Studios Central, Auckland Central Yes
MegaSun Suntanning Studios Ponsonby, Ponsonby Yes
Solaris Clinic, Botany NoA
Sunset Tan, Mt Eden Yes
SunWorld Takapuna, Takapuna Yes
Vibra-Train, Manukau Yes
Westgate Beauty Therapy Clinic, Massey Yes
Groom Laser & Skin Clinic Yes
Headway Design, Mosgiel Yes
Inspiring Women Yes
Bronze Connection Hair Mechanics Yes
Fred & Gingers Hair & Beauty Salon No
Surrender Hair Design & Make Up Artists Yes
Vertigo Urban Image Yes

GUIDE TO THE TABLE OUR MYSTERY SHOP took place in October 2017 and was funded by the Ministry of Health. OPERATORS have their location listed to clearly identify the business. SUNBED REFUSED Asunbed allowed but stopped early when operator realised age.

Fair skin shoppers

The voluntary sunbed standard, which the industry claims it complies with, recommends people with type 1 skin (fair skin that burns readily or never tans) shouldn’t use a sunbed.

In Wellington, our fair skin shopper was refused a sunbed at 6 premises. However, 3 operators didn’t turn her away. Classic Tan Solarium and Halo Hair let her have a sunbed despite her telling staff she burned easily. At Halo Hair she was told “if you feel like you’re burning, you probably are, so jump out”.

Hedz for Hair in Wainuiomata assessed our shopper as having type 1 skin but still let her have a sunbed. A staff member said “you aren’t going to burn”. The next day our shopper got a phone call from Hedz for Hair and was told she probably shouldn’t have used the sunbed and it would be best to avoid them in future.

It was a similar story in Christchurch. While 8 operators refused our shopper, 3 let her in. Finesse Fitness for Women Eastgate did a skin assessment and the staff member said they hadn’t had anyone with such a low skin assessment score (less than 6 points). She phoned the manager to check what to do and was advised to give her a 3-minute session.

Skin Deep Solariums didn’t do a skin assessment. The staff member told our shopper she would normally check her skin but as she was only having a 3-minute sunbed it wasn’t necessary.

The staff member at Sloanes Hair Design appeared to have no knowledge about how the sunbed worked or the requirements of the standard. Our shopper didn’t fill out a consent form or have a skin assessment and was initially offered a 30-minute session. Our shopper declined and said she’d come back when the manager was around.

Operator Sunbed refused
Amadeus Hair & Beauty, Newtown Yes
Classic Tan Solarium, Wellington No
Enhance Spa Beauty & Nails, Paraparaumu Yes
Halo Hair Company, Lower Hutt No
Hedz for Hair, Wainuiomata NoA
Revive Fitness, Lambton Quay Yes
Revive Fitness, Lower Hutt Yes
S & Co. Beauty and Wellbeing, Upper Hutt Yes
Sophora Skincare Shop and Beauty Salon, Paraparaumu Yes
Accent on Nouveau, Riccarton Yes
Body and Soul, Sydenham Yes
Carlton Hair Corp, Christchurch Central Yes
Finesse Fitness for Women, Eastgate NoB
Here for Hair, Redwood Yes
Hi Gorgeous, Rangiora Yes
Natural Lines Beauty Therapy, Linwood Yes
Riccarton House of Beauty, Riccarton Yes
Skin Deep Solariums, Shirley No
Sloanes Hair Design, Bryndwr No
Ziggs Hair & Body Shop, Woolston Yes

GUIDE TO THE TABLE OUR MYSTERY SHOP took place in October 2017 and was funded by the Ministry of Health. OPERATORS have their location listed to clearly identify the business. SUNBED REFUSED Ashopper was phoned the next day and advised they shouldn’t have another sunbed. Bsalon has now closed.

Standard checks

Our shoppers also checked 40 operators’ compliance with other key safety criteria in the voluntary sunbed standard. Disappointingly, we found little improvement in overall compliance since our last survey in 2015. Forty-five percent of operators failed to implement basic checks. Just 22 out of 40 met all 8 criteria we assessed.

Two Auckland operators – Fitness Plus in Manukau and Wolf’s Gym in Henderson – were among the worst performers. Neither provided a consent form and there was no eye protection available in the tanning cubicles.

Wolf’s Gym didn’t do any skin assessment although it did have recommended warnings on the wall. Fitness Plus checked our shopper’s complexion and asked about her tanning history, but didn’t display any warnings.

Both operators also told our mystery shoppers they could come in whenever they liked for their next session. The standard recommends at least 48 hours between sessions. Fitness Plus says it now provides eye protection and displays warning statements.

Although the sunbed standard is voluntary, Auckland Council implemented a bylaw in 2013, which requires sunbed operators to be licensed and comply with minimum standards. These include providing a consent form and conducting a skin assessment. We’ve passed on the details of these operators to the council.

Four other operators (Nelson Nails & Beauty Spa, Vamp Hair Studio in Blenheim, and Christchurch’s Riccarton House of Beauty and Sloanes Hair Design) also didn’t provide a consent form or do a skin assessment. Halo Hair in Lower Hutt provided the forms for our fair-skinned shopper, but not for our shopper who visited to check compliance with other safety criteria.

Compliance with safety criteria

Consent form
18feb sunbeds consent form

27 of 40 operators complied with this guideline (68%).

On a customer’s first visit, the standard states they should sign a consent form. The form should:

  • ask the customer’s age
  • explain the risks associated with sunbed use
  • define who’s high-risk
  • emphasise wearing goggles.

Skin assessment
18feb sunbeds skin assessment

32 of 40 operators complied with this guideline (80%).

Staff should assess a customer’s skin, as certain skin types are more susceptible to UV damage. Sunbeds should never be used by:

  • people with type 1 skin
  • people who’ve been sunburnt several times in childhood
  • those with numerous moles
  • people who’ve been treated for skin cancer or are taking certain medications.

Eye protection
18feb sunbeds eye protection

38 of 40 operators provided eye protection (95%).

UV rays can damage your eyes and increase your risk of getting cataracts. A sunbed operator should provide goggles that form a tight seal around the eyes. At Finesse Fitness for Women Eastgate and Classique Beauty Studio (both in Christchurch), our shoppers were required to buy goggles.

Warning notices
18feb sunbeds warning notices

34 of 40 operators displayed all warnings in either the reception area or tanning cubicle (85%). Some operators displayed warnings in both.

The standard asks for warning notices in the reception area and tanning cubicle. These notices should warn of the risks from UV light and state that people at greater risk (under 18, or with fair skin that burns easily) shouldn’t use a sunbed. There should also be reminders to use eye protection and to not use a sunbed again within 48 hours.

Operators Consent form Skin assessment Eye protection UV risks warning Fair skin warning Under 18s warning Eye protection warning Follow-up warning
Auckland region
Body Bronze, Manukau
Body Liqueur, Pukekohe
Essence of Beauty, Albany
Fitness Plus, Manukau
Headstart Total Body, Glen Eden
Hobby Hair, Hobsonville
JustWorkout, New Lynn
MegaSun Suntanning Studios, Central Auckland
Sunset Tan, Mt Eden
Vibra-Train, Pukekohe
Westgate Beauty Therapy Clinic, Massey
Wolfs Gym Limited, Henderson
Rotorua & Taupō
Forme Fitness & Body Therapy, Rotorua
Go 360, Rotorua
Mirror Image, Taupo
Deebiza Hair Studio, Hawera
Verve Hair, Waitara
Wellington region
Amadeus Hair & Beauty, Newtown
Classic Tan Solarium, Lambton Quay
Enhance Spa Beauty & Nails, Paraparaumu
Halo Hair Company, Lower Hutt
House of Beauty, Mana
Revive Fitness, Lower Hutt
S & Co. Beauty and Wellbeing, Upper Hutt
Sophora Skincare Shop and Beauty Salon, Paraparaumu
Studio 128, Johnsonville
Blenheim & Nelson
Nelson Nails & Beauty Spa, Nelson
Vamp Hair Studio, Blenheim
Classique Beauty Studio, Richmond A
Finesse Fitness for Women, Eastgate* A
Riccarton House of Beauty, Riccarton
Skin Deep Solariums, Shirley
Sloanes Hair Design, Bryndwr
Ziggs Hair & Body Shop, Woolston
Body Sanctum Queenstown Day Spa
Elysium Beauty
Bronze Connection Hair Mechanics
Surrender Hair Design & MakeUp Artists
Vertigo Urban Image
YMCA Invercargill

GUIDE TO THE TABLE OUR MYSTERY SHOP took place in October 2017 and was funded by the Ministry of Health. Our mystery shoppers checked whether operators followed key safety guidelines set out in the Australia/New Zealand standard AS/NZS 2635:2008. We did not assess compliance with all parts of the standard. OPERATORS have their location listed to clearly identify the business. *salon has now closed. EYE PROTECTION Ashopper required to purchase eye protection.

About our survey

Our mystery shoppers visited 40 sunbed operators. They included solariums (specialist sunbed establishments), fitness centres, hairdressers, beauty therapists and nail salons.

Each shopper booked a session, told the operator it was their first sunbed and carried out the assessment in the privacy of the tanning cubicle. They did not use the sunbed.

Each session was evaluated against key safety guidelines in the voluntary sunbed standard, AS/NZS 2635:2008 Solaria for cosmetic purposes.

The standard recommends people with type 1 skin (fair skin, often freckled, easily burns and never tans) shouldn’t be permitted to use a sunbed. We sent shoppers with type 1 skin, as assessed by a skin specialist, to 20 operators (9 in Wellington and 11 in Christchurch). The same shopper went to each operator in the same region.

We also sent underage shoppers to 20 sunbed operators (13 in Auckland, 3 in Dunedin and 4 in Invercargill). The Health Act restricts sunbed use to people aged 18 or over.

We say

  • Yet again our sunbed survey has highlighted the poor practices in this industry – in particular, operators allowing minors and people with fair skin to use a sunbed.

  • Existing regulation isn’t providing sufficient consumer protection. We’d like sunbeds banned. Sunbeds are already banned in most Australian states and Brazil, countries which also have high rates of skin cancer.

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