Most sold in NZ meet international standards, says interest group.
In this opinion piece, New Zealand Suncare Initiative spokesperson and Cosmetics NZ General Manager, Lyndal O’Toole, describes how most sunscreens found in New Zealand are tested – and says that this testing is rigorous.
The NZ Suncare Initiative is a special interest group established by Cosmetics New Zealand, the industry body representing cosmetic, toiletry and fragrance businesses in New Zealand, which includes sunscreen companies.
More than anything, the NZ Suncare Initiative* aims to bring balance and diversity to the conversation around sunscreen. As a common voice for sunscreen brands, we want better outcomes for Kiwis when it comes to sun safety by providing balanced, informative, helpful perspectives.
As Kiwis embrace the long days of summer, sunscreen is one of the essential ways to stay safe as we enjoy our beloved beaches, back yards and barbecues – but how is it made and why should we care?
Most sunscreen brands go to great lengths to make sure their products comply with the standards required and, in our view, must meet some of the strictest regulations in the world before finding their way onto New Zealand supermarket and pharmacy shelves.
In New Zealand, any SPF claim is already regulated by the Fair Trading Act and Cosmetics Products Group Standard. However, New Zealand is one of the few first world countries where sunscreen does not have one consistent mandatory sunscreen standard.
The joint Australia/New Zealand 2604 Standard is currently voluntary in this country. Reassuringly, most major brands are sold in both markets so they already meet this joint standard, enforced in Australia by the Therapeutic Goods Administration.
Cosmetics New Zealand, on behalf of the sunscreen industry here, has been instrumental over the past decade in supporting the joint Australia/New Zealand 2604 Standard through funding and serving on the Standards Committee to ensure New Zealand has had a voluntary standard to test against, while working towards making the standard mandatory.
The NZ Suncare Initiative, all 15 brands involved, and Cosmetics NZ strongly supports appropriate regulation of sunscreen in this country, and the mandating of the current AS/NZ 2604 Standard, just as Consumer NZ does – even if sunscreens remain classified as cosmetics in NZ.
We also fully support the Sunscreen (Product Safety Standard) Bill that will make the joint standard mandatory and give shoppers confidence that all sunscreens will be tested to the same standard for New Zealand as well as Australia.
Consumer NZ says the standard is not mandatory in New Zealand – but should be. They say products sold in New Zealand could meet other standards, such as those in the US or EU, or may not have been tested at all. In 2020, more than half the sunscreens they tested failed to meet their SPF claims.
In the first of their 2021 summer sunscreen tests of nine sunscreens in December, Consumer NZ's testing found three did not meet SPF protection claims and two of those also did not meet broad spectrum requirements. But it's important to note that those three sunscreens Consumer NZ identified are Australian brands that are registered with the Therapeutic Goods Administration and have been tested against the mandatory AS/NZ 2604 Standard.
Between 2017-2021, a small number of NZ Suncare Initiative brands have had products identified by Consumer NZ in its testing as not meeting SPF or broad spectrum protection claims alongside other major sunscreen brands which are not part of the Initiative.
However, the majority of the sunscreens Consumer NZ tests are sold internationally, where sunscreens are highly regulated, so these products have already met international standards and are, in our opinion, proven safe when used properly, despite Consumer NZ's findings. Because the Standard is not mandatory in New Zealand, there is no requirement for sunscreen packaging to carry any special labelling that signals it is tested to the AS/NZS 2604 Standard – though all brands in the NZ Suncare Initiative already meet that standard.
In our view, the Consumer NZ testing also highlights the subjectivity and variability that exists when testing SPF products; one-off, isolated SPF testing can produce mixed results. The AS/NZ 2604 Standard references variability in testing and, in our view, this variation is not unusual and does not invalidate on-pack SPF claims. Consumer NZ even reference on their own website that, as SPF testing is conducted on humans, there will always be some variability.
Consumer NZ has previously asked the Ministry of Health for regulations to specify how often sunscreens must be tested and requirements for test labs; plus monitoring and independent testing of sunscreens to ensure label claims are truthful.
We share common ground with Consumer NZ in that a primary goal for both is to improve outcomes for Kiwis when it comes to avoiding potential sun-related harm.
Creating sunscreen is a long, robust process often taking years to bring to market. Scientists with expert suncare knowledge take the lead in formulating the product, including selecting the ingredients and UV filters needed to meet the SPF claim, followed by extensive research and development where numerous variations are tested and eliminated to find the perfect formulation.
To find out how the product will work on people with all sorts of skin types, a sunscreen is typically tested on a group of 10 volunteers, using the same amount of product, and the same amount of exposure to UV rays. The reaction of their skin is analysed and confirms the finalised SPF number for the labelling and evidence required by the Fair Trading Act.
The New Zealand Cancer Society, on their sunscreen.org.nz website, says that when people follow the instructions on the label, SPF30 filters 96.7 per cent of UVB radiation and SPF50 filters 98 per cent of UVB radiation, meaning both levels (and everywhere in between) provide excellent protection from UV rays when applied properly and regularly.
So, in our opinion, NZ consumers can have the confidence that their sunscreens, including all 15 brands in the NZ Suncare Initiative, are backed by evidence of testing against internationally-recognised standards, to give extra reassurance that the product is effective.
* The NZ Suncare Initiative is also supported by Consumer Healthcare Products NZ and NZ Food & Grocery Council. The purpose of the NZ Suncare Initiative is to present a united voice; all involved brands are well respected, familiar brands that can be found in supermarkets and pharmacies across the country such as Hawaiian Tropic, Neutrogena, Skinnies and La Roche Posay.