Why sunscreens should be regulated
Hot from the lab: our latest sunscreen test results.
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Seven sunscreens in our latest test didn’t provide their claimed SPF protection, including products marketed as “natural”. Three of the seven sunscreens also failed to meet their broad-spectrum claims.
Slopping on sunscreen can help protect you from the harsh summer sun. The sun exposes you to two types of UV rays – UVA and UVB. UVA penetrates deeply into the skin and can cause wrinkles and age spots. UVB causes skin reddening and is the main cause of sunburn. Both rays can cause skin cancer.
In our latest round of testing, we checked 12 sunscreens to assess whether they met their SPF (sun protection factor) and broad-spectrum protection claims.
Five of the 12 sunscreens we tested met their SPF label claim and the requirements for broad-spectrum protection:
Natural Instinct Invisible Natural Sunscreen SPF30 and Sukin Suncare Sheer Touch Facial Sunscreen Untinted SPF30 only provided moderate protection, not the high protection claimed.
When we asked the companies for evidence to back their label claims, Natural Instinct provided a lab report that concluded it was “highly unlikely” the formula would not meet an SPF30 label claim.
This conclusion was based on a 2012 test by US lab AMA (see “AMA Labs’ false test results”). The test was of a formula with the same percentage of zinc oxide (the active ingredient) as the sunscreen we tested but wasn’t the same product. In 2015, an additional test was done (also by AMA) of a product with a similar base. However, the test only involved three people, not the 10 required by the sunscreen standard.
Sukin provided a report that concluded its product “should comply” with the sunscreen standard. This was based on a 2011 AMA 20-person test of a formula with the same level of zinc oxide. The product we tested had a different preservative. Sukin advised the sunscreen was sent for retesting earlier this year and said the product meets the SPF label claim. Test results have not been provided to us.
Banana Boat Daily Protect Sunscreen Lotion SPF50+ got a result of 40.4 (high protection) in our test. Its distributor provided us with 10-person test results. However, the results were from an unidentified lab and didn’t have the test date. When we asked for this information, the company declined to provide it.
Le Tan Coconut Lotion SPF50+ and Ecosol Water Shield Sunscreen SPF50+ also didn’t meet the very high protection claims on their labels. In addition, both products failed to meet the requirements for making a broad-spectrum claim.
This is the second time Le Tan hasn’t met its label claim in our testing. When we tested the sunscreen in 2018, it got an SPF of 44 (this time it was 42.7).
In response to this year’s results, the distributors of Le Tan provided a 10-person test report from Australian lab Eurofins Dermatest. However, the results were from a batch tested over 2013 and 2014. Based on our results, the company said it would retest the product.
Ecosol managed an SPF result of 30.4 in our test. The company provided us with a 10-person test report. However, it was from 2015 and had been conducted at AMA. The New Zealand distributor advised us it would relabel the product as SPF30.
Hamilton Active Family Sunscreen SPF50+ returned an SPF of 50. This is below the SPF60 required to make a 50+ claim. We tested another bottle of this sunscreen at a second lab, where it also failed to meet its label claim. The sunscreen provides high protection but not the SPF50+ claimed.
Key Pharmaceuticals, which owns the Hamilton brand, provided us with 2018 test results from a US lab to support its SPF50+ claim. The company said it had “no reason to doubt the integrity” of the results.
Neutrogena Beach Defence Water + Sun Barrier Lotion Sunscreen SPF50 returned an SPF of 36.5. It also failed to meet the requirements needed to make a broad-spectrum claim.
We tested another bottle of this sunscreen at a second lab, which also found it failed to meet its SPF50 claim. Of the 20 people this product was tested on across both labs, the SPF rating was below 50 in 17 cases.
Johnson & Johnson Pacific, which markets Neutrogena, said its sunscreens complied with the Australian and New Zealand sunscreen standard. The company provided 2012 test reports to support its SPF and broad-spectrum claims.
The company questioned our decision to send products to the labs “blind” – that is, decanted into unbranded containers. We stand by our decision and don’t believe our process raises any valid concerns.
It’s not the first time Neutrogena sunscreens have failed to meet SPF claims in our tests. We’ve previously lodged a complaint with the Commerce Commission as a result of our findings.
In December 2017, Johnson & Johnson New Zealand signed court-enforceable undertakings with the commission, agreeing that its sunscreens sold here would meet the standard.
In September 2016, the commission told the company to stop supplying its Neutrogena Sensitive Skin SPF60+ after testing found the product didn’t meet its SPF claim. Our testing also found this sunscreen failed to provide the claimed protection. Johnson & Johnson said it decided to discontinue the product in April 2016 for independent commercial reasons.
The owner of US lab AMA Laboratories has pleaded guilty to falsifying test results. A statement issued on 4 May 2021 by the US Attorney’s Office in the Southern District of New York said AMA owner Gabriel Letizia Jr had “schemed for decades to defraud customers”.
From 1987 to April 2017, Letizia and senior staff defrauded customers of more than $63 million ($US46m). Letizia is facing up to seven years in prison. Four former AMA employees have previously pleaded guilty in connection with the fraud.
In June 2020, the Therapeutic Goods Administration (the government agency that regulates sunscreens in Australia) stated sunscreen companies are required to provide adequate justification for their products that have been tested by AMA. The administration said it will contact affected companies to request this information.
Sunscreen manufacturers don’t have to regularly test their products but we think they should to ensure different batches meet label claims. We don’t think it’s acceptable to rely on test results that, in some cases, are more than five years old.
We get similar results every year:
We’ve been campaigning for a mandatory sunscreen standard for many years. In a country with one of the highest rates of skin cancer and melanoma in the world, it’s not good enough sunscreens aren’t regulated.
Last year, we made a submission to the Ministry of Health on the Therapeutic Products Regulatory Scheme. We strongly supported sunscreens being required to comply with the Australian and New Zealand sunscreen standard.
The sunscreen standard is mandatory in Australia but voluntary here (where sunscreens are classified as cosmetics). This means products sold in our market could meet other standards, such as those in the US or EU, or may not have been tested at all.
We also asked for regulations to specify how often sunscreens must be tested and requirements for test labs. In addition, monitoring and independent testing of sunscreens must be done to ensure label claims are truthful.
Remember, a sunscreen is only one part of your defence against UV radiation. You should also cover up with suitable clothing, a broad-brimmed hat and UV-protective sunglasses, and seek shade . When the sun’s rays are most intense (between 10am and 4pm September to April or when the ultraviolet index (UVI) is greater than three), limit your time outside.
"SPF" stands for "sun protection factor". It's a measure of protection against mainly UVB rays, the ones that cause sunburn. The higher the SPF number, the greater the protection - up to 50+.
Above SPF 50+ the additional protection is very small. In fact, high SPF values are a problem. Studies have shown that people use them to stay out longer in the sun, using sunburn as a warning to take cover. During this time you can receive large doses of UVA radiation.
The Australian/New Zealand standard limits SPF claims to 50+ in line with other international standards.
For more information, see “What do the SPF numbers mean?”
An SPF15 sunscreen that's properly applied is meant to give you 15 times the protection you'd get with unprotected skin. So if you were outside in the sort of sun that burns unprotected skin in 10 minutes, then SPF15 would give you 150 minutes of protection. For SPF30 sunscreen, that time would extend out to 300 minutes and for SPF50 it would be 500 minutes (see our Graph).
That’s the theory. These times will vary from person to person because of skin type, activities (such as heavy exercise or swimming) and how well the sunscreen is applied. No matter how high the SPF, any sunscreen should be reapplied regularly – every two hours you’re in the sun.
No sunscreen blocks 100 percent of UV rays: SPF15 blocks 93 percent of UVB, SPF30 blocks 97 percent, and SPF50 blocks 98 percent.
Broad spectrum sunscreens protect against UVA and UVB radiation. Both contribute to premature skin ageing, damage to the immune system and skin cancer.
UVA radiation penetrates deep into the skin layer; it's dangerous because there's no immediate warning sign (such as the sunburn caused by UVB rays).
No - sunscreen can be sweated, washed or rubbed off, the chemicals may break down over time, and people simply don't apply enough (see "Sun safety tips" above). You should reapply sunscreen every 2 hours.
No. A tan is a sign that skin damage has already started. Any further UV radiation will only add to the damage, resulting in wrinkled leathery skin and possibly skin cancer later in life.
Proper protection from the sun is more important during childhood than at any other time in life. Childhood and teenage sunburn is a high-risk factor for developing melanoma.
Sunscreens that are specially formulated for children have a mild base designed especially for their sensitive skin. But there's no reason why children shouldn't use the family sunscreen, provided it doesn't irritate their skin. Test a small amount on the inside of their forearm first.
According to Professor Marius Rademaker, from the Dermatology Unit at the Waikato District Health Board, you don’t need a special sunscreen for kids. He told us there was little evidence to suggest there was a safety issue with using the active ingredients of adult sunscreens on children.
Professor Rademaker told us it was important to remember that sunscreens were just one component of keeping safe in the sun. “As well as wearing sunscreen, children should wear protective clothing and sunglasses, and parents should plan outdoor activities for early in the morning or later in the afternoon.”
Keep babies and toddlers out of the sun as much as possible. The best protection for them is staying in the shade and using cover-up clothing - as it is for everybody.
Certain ingredients in sunscreens can irritate some people. This may be due to sensitive skin or a reaction to one of the ingredients (a chemical, preservative or fragrance).
The active ingredients in sunscreens must be listed on the label. However, unlike other cosmetics, sunscreens are exempt from having to list all ingredients if they comply with the Australian requirements.
You can check the active ingredients and preservatives of our tested sunscreen here.
Sunscreen active ingredients can be divided into two groups – physical blockers and chemical absorbers.
Physical blockers (zinc oxide and titanium dioxide) work by reflecting or scattering UV radiation and are effective at protecting against both UVA and UVB radiation. A downside is they leave white marks on the skin, although some products now use nanoparticles – tiny molecules with one or more dimension less than 100 nanometres (nm) – which makes the sunscreen transparent.
Chemical absorbers (such as octinoxate or oxybenzone) work by absorbing UV radiation and can be further differentiated by the type of radiation they absorb – UVA or UVB. These sunscreens often have a combination of ingredients to protect against UVA and UVB.
Some people choose to avoid sunscreens with chemical absorbers because of potential health risks. In 2019, a study by US Food and Drug Administration (FDA) researchers found four chemicals (avobenzone, oxybenzone, octocrylene and ecamsule) may be absorbed through the skin at levels higher than previously believed.
In January 2020, a follow-up study by the same researchers on six sunscreen ingredients (avobenzone, oxybenzone, octocrylene, homosalate, octisalate and octinoxate), backed up these findings.
The FDA has asked the sunscreen industry to provide additional safety information on 12 chemical sunscreen ingredients to validate their safety and effectiveness.
The European Commission is also investigating whether some sunscreen chemicals have endocrine-disrupting properties. Last year, the commission asked for scientific data on 14 chemicals including homosalate and octocrylene.
Some ingredients, in particular oxybenzone (also called benzophenone-3) and octinoxate (aka octyl methoxycinnamate) are also emerging as an environmental concern, especially in beach regions where they get washed off.
Due to the evidence showing these ingredients adversely affect marine life, the New Zealand Dermatological Society recommends using sunscreens without them. From 2021, sunscreens containing oxybenzone and octinoxate will be banned in Hawaii, except on prescription. The Republic of Palau has also banned these ingredients, as well as additional sunscreen chemicals.
To choose sunscreens without these chemicals, check the packaging – all active ingredients in sunscreens must be listed.
There is debate about the safety of nanoparticles and whether they can penetrate the outer layer of skin (which has been shown in lab studies) and damage living cells.
In 2017, the Australian Therapeutic Goods Administration concluded the majority of studies found nanoparticles didn’t penetrate “or minimally penetrated” the skin, suggesting “systemic absorption, hence toxicity, is highly unlikely”.
The European Commission (EC) concluded available evidence suggests zinc oxide and titanium dioxide nanoparticles can be considered safe for use on the skin as sunscreens up to a concentration of 25 percent. This does not apply to sprayable products, which might be inhaled.
With cosmetic products, which include sunscreens, nanoparticle ingredients are required to be labelled. The word “nano” must appear in brackets after the ingredient. However, if a sunscreen complies with Australian regulations, this isn’t required and products don’t need to declare the ingredients’ particle size.