How Did This Happen? Manufacturing and Testing
- Dr Brad
- Feb 22
- 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:
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:
2. Therapeutic Goods Administration. Sunscreen SPF testing – information for consumers:
3. Australian Beauty Industry Council (ABIC). Ensuring Sunscreens Meet SPF Claims: An Industry Draft Report. 2025.
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This article raises important questions about sunscreen efficacy and the integrity of testing standards. The fact that many products labeled as SPF 50+ fall short indicates potential quality control failures. Thepokies analogy comes to mind; just as certain games can be rigged, the sunscreen industry appears to have vulnerabilities that may compromise consumer safety. Ongoing scrutiny is essential.
This article raises important concerns about sunscreen efficacy and regulatory oversight. While it's commendable that the Therapeutic Goods Administration follows strict SPF testing protocols, the reliance on manufacturers to ensure batch consistency seems flawed. Instances like those involving Johnny Kash highlight potential lapses in quality control that could endanger consumers. Continuous independent testing might be necessary to uphold safety.
The discrepancies in sunscreen SPF ratings raise crucial questions about quality control and consumer safety. The role of manufacturers in maintaining consistency post-approval cannot be overlooked. As noted, significant deviations like those found in the CHOICE study should prompt a reevaluation of standards. It is essential that regulatory bodies like the TGA and entities such as Royal Reels enforce stricter oversight to restore consumer trust.
I can confirm that the conclusions are proportional to the evidence presented. Proportional attention to verifiable indicators is maintained. The website enriches the reader's understanding of the subject matter. Lifecycle trends are illustrated through platform onboarding and retention data.