How Did This Happen? Manufacturing and Testing

13 hours ago

2 min read

In the first post, I outlined what the CHOICE testing showed.

The next obvious question is how so many of the sunscreens tested were found to provide protection well below their advertised SPF 50+ rating.

In Australia, sunscreens are regulated by the Therapeutic Goods Administration (TGA). To be labelled SPF 50+, a product must test at SPF 60 or higher under Australian standards.

So how did independent testing show different results?

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Manufacturing and batch consistency

When a sunscreen is first approved in Australia, it must meet SPF testing requirements. After approval, manufacturers are responsible for ensuring that ongoing production batches match the tested formulation. There is no requirement for further independent SPF testing once a rating is achieved.

Sunscreens are made in large volumes. This involves mixing active UV filters with other ingredients using industrial equipment. Changes in ingredient supply, production scale or manufacturing processes can affect the final product.

If a product’s performance changes between batches and this is not detected internally, it may only become apparent when independent testing is carried out.

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Stability and packaging

Sunscreens are tested for stability before approval. In everyday use, they are often exposed to heat — left in cars, taken to the beach or stored in warm bathrooms. Heat, light and air exposure can affect how stable ingredients remain over time.

Packaging also plays an important role in protecting the formula. Biodegradable packaging can sometimes offer less long-term protection against light and oxygen compared with traditional packaging, which may make maintaining stability more challenging.

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Lab testing vs real world variability

The CHOICE study used human volunteers in their sunscreen study. In Australia, SPF is mainly measured using laboratory testing. The sunscreen is applied to a testing surface and exposed to UV light to see how much is blocked.

In everyday use, factors like skin texture, sweating, movement and how thickly it is applied can all affect performance. Because of this, laboratory results do not always match perfectly with results from human testing.

Australia updated its sunscreen standards in recent years, with further improvements being introduced to make testing more consistent between laboratories and better reflect real-world use.

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In summary

Some differences in SPF results can be explained by manufacturing variation, batch consistency, storage conditions and differences in testing methods. Small shifts in SPF ratings are not unexpected in a complex product tested under different conditions.

However, very large discrepancies — such as results reported as low as SPF 5 for a product labelled SPF 50+ — are not easily explained by normal variation alone. These cases suggest a more significant breakdown somewhere in formulation, quality control, testing or oversight, and remain under investigation.

For now, the Therapeutic Goods Administration (TGA) has recalled sunscreens from the manufacturer involved. Patients can read the official recall notice here:

[https://www.tga.gov.au/safety/recall-actions](https://www.tga.gov.au/safety/recall-actions)

In the next post, I’ll explain what SPF actually means and the practical difference between those sunscreens that tested at SPF 30 vs the few that tested at SPF 50.

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References

1. Therapeutic Goods Administration. Recall actions and safety alerts:

https://www.tga.gov.au/safety/recall-actions

2. Therapeutic Goods Administration. Sunscreen SPF testing – information for consumers:

https://www.tga.gov.au/resources/explore-topic/sunscreens/sunscreen-spf-testing-information-consumers

3. Australian Beauty Industry Council (ABIC). Ensuring Sunscreens Meet SPF Claims: An Industry Draft Report. 2025.