TGA to overhaul sunscreen SPF testing after scandal — but gaps remain

A consumer investigation found last year that 16 of 20 popular Australian sunscreens failed to meet their SPF label claims. One product marketed as SPF 50+ returned a test result of SPF 4 — a 46-point gap between what was on the label and what was in the product. The TGA recalled that product, followed by 19 others sharing the same base formula.

The TGA has now released a consultation paper proposing mandatory new testing rules for Australian sunscreens — the most significant regulatory change to the sector in years.

If you have been buying SPF 50+ in good faith and wondering whether it is doing what it says: there is a documented answer now, and it is not reassuring about the framework — though the proposed changes move in the right direction.

What the Choice audit found — and what it exposed

The 2025 Consumer group Choice investigation tested 20 popular sunscreens and found 16 failed their SPF label claims. An ABC investigation found that more than half of the failing products had used an overseas testing laboratory whose methods experts questioned. The problem was compounded by the current regulatory structure: brands could list a therapeutic sunscreen using a base-formula test only, without testing the finished product as it sits on a pharmacy shelf.

TGA Chief Medical Advisor Dr Robyn Langham said: “Australians expect the SPF on the label to be backed by robust evidence.” The gap between that expectation and what the Choice audit found was substantial.

Two in three Australians will be diagnosed with skin cancer in their lifetime. About 2,000 Australians die from skin cancer each year. The degree to which SPF labelling accuracy matters is not trivial.

What the TGA is proposing

The consultation paper proposes several changes:

• Finished-product testing: brands would test the SPF of the final product — not just the base formula — multiple times before listing, providing results to the TGA on a confidential basis
• Shelf-life retesting: periodic retesting over the product’s shelf life
• Lab accreditation: stronger international accreditation requirements for SPF testing laboratories, which the TGA does not currently regulate
• In vitro testing: brands could use an in vitro test (on a plastic plate) instead of the in vivo test (on volunteers) for some formulations — with in vivo retained for specific cases including water-resistance testing
• Cosmetic vs therapeutic clarity: clearer distinction for products claiming SPF 50+ as a cosmetic versus therapeutic good
• Labelling review: SPF labelling changes are under consideration — a possible shift from numbers to a Low / Medium / High / Very High scale

These are meaningful reforms to a framework that clearly had gaps. Requiring finished-product testing directly addresses the mechanism behind most of the 2025 failures.

What they are not proposing

Two gaps stand out.

First, SPF test results will not be made public. The TGA considered public disclosure but cited concerns about commercial confidentiality, intellectual property, and the risk of misinterpretation of technical data. The practical consequence: consumers will still have no independent way to verify whether the product on the shelf tested what it claims. You will be relying on the regulatory framework to have worked — which is exactly what the Choice investigation revealed was not reliably the case.

Second, pre-market checking by the TGA is not proposed. The onus will remain on brands to test and internally report. The TGA will audit; it will not screen before products reach shelves.

The reforms are also at various stages — some “in the short term,” others requiring further consultation and possible legislative amendment. The SPF labelling change is still under consultation. The timeline for implementation is not fixed.

Both-and: what this fixes and what it leaves

The proposed changes address the root cause of the 2025 failures: brands testing base formulas via questionable overseas labs instead of finished products. That is a real improvement. Mandatory finished-product testing and stronger lab accreditation would make a repeat of the Choice findings substantially less likely.

The transparency gap is real. A system where test results are confidential and pre-market checking doesn’t happen still requires consumers to trust the regulatory backstop without the ability to verify it themselves. For a product whose primary function is cancer prevention, that is a legitimate ongoing concern.

The TGA’s consultation process is open. The proposals are not yet finalised.

2 cents: what to do now, before the changes land

Cancer Council’s five sun protections: clothing, sunglasses, hat, shade, and sunscreen — in that order. Sunscreen is one layer of five. The SPF failures don’t mean sunscreen doesn’t work — they mean the labelling system has not been reliable enough, and the proposed reforms address that.

For now: stick with established brands that have longer Australian market track records and better-accredited testing histories — Cancer Council brand sunscreen, Ego Sun Sense, La Roche-Posay, Neutrogena. Apply SPF 50+. Apply generously: Cancer Council recommends seven teaspoons for full-body coverage. Reapply every two hours and after swimming or sweating. SPF 20 filters about 95% of UVB; SPF 50 filters about 98% — the margin matters when exposure is long.

The reforms are coming. They will not reach shelves before summer.

Verdict: yes — the regulatory change is significant; the transparency gaps are worth tracking.

---

Sources cited

1. Tough new testing rules for Aussie sunscreens in the wake of SPF scandal — ABC Health, 27 October 2026
2. Cancer Council Australia — sun safety and sunscreen
3. TGA — sunscreen regulation