The TGA wants to overhaul sunscreen labels. Will scrapping SPFs work?

On Thursday, Australia’s Therapeutic Goods Administration (TGA) released a raft of proposed changes to improve how sunscreens are tested and sold, including simplifying sun protection factor (SPF) labelling.

In its statement, the TGA highlighted the recent blow to consumer confidence in sunscreens, after a series of investigations last year by consumer group Choice and the ABC found many products were not offering the SPF protection they advertised, leading to product recalls.

Read more: Worried after sunscreen recalls? Here’s how to choose a safe one

Since then, many Australians have been left confused about how SPF testing works and what information to trust.

The TGA aims to address these concerns by reforming labelling. One option is to add more detail to the SPF label. Another is to remove the numbers – such as SPF15+ or SPF50 – altogether. In this case, visual categories would indicate low, medium, high, and very high sun protection.

But Choice, which commissioned the original investigation, issued a statement on Thursday saying it did not support replacing the SPF numbering system. However Choice commended the TGA for other proposed changes, such as improving sunscreen testing, accreditation of testing labs, and greater transparency.

So, is simplifying the labelling a good idea? And what are the potential downsides? Let’s take look.

3 different options for SPF labelling

The TGA’s consultation report says there is a general lack of understanding about how the SPF rating system works and what it actually means for people applying sunscreen. SPF testing has also exposed too many products not meeting Australian standards.

So the TGA outlines three options for SPF labelling, as well as potential advantages and downsides.

1. Stay the same

The first option is the “status quo” – keeping the current SPF system.

This sets standards for what can be sold in Australia. Anything below 4 is not allowed, and SPF between 4–14 is considered “low” and sold as cosmetics.

The advantages of maintaining this system are that it’s already known as the benchmark for sun protection, is consistent worldwide, and wouldn’t require manufacturers to change their packaging.

But leaving the system untouched will not address the issues that have been identified, including ambiguity about how a product’s SPF has been tested and whether it meets the standards.

2. Add more detail

Option two is providing extra information, in addition to current SPF numbers. For example, “SPF30 filters 97% of UVB rays”.

This may increase consumer trust in scientific accuracy and transparency, without replacing the entire system.

But as the TGA points out, labels are already crowded. People may still misunderstand how the numbers relate to how much sunscreen they should apply and how often. So significant public education campaigns would still be needed.

3. Simplify

Option three is the most drastic – to replace the current SPF rating system with words: low, medium, high and very high. The words could be used by themselves, or with a graphic.

The TGA says this kind of labelling is best practice for conveying complex scientific data to the public, and could make it easier for people – especially those with low health literacy – to quickly understand a product’s protection level and whether it offers what they need.

But this would be a major overhaul, involving changes to legislation and packaging redesign. A new system could also confuse consumers. There is a risk symbols or bars could be too simple and mislead people about the level of protection. So a widespread education campaign would be essential.

This change would also mean Australia would be out of step with other countries.

Some other pros and cons

Overall, reforming and simplifying the SPF labelling is a good idea. The recent confusion and variability in protection exposed by SPF testing shows the current system isn’t working.

Under the proposed word categories, what is currently labelled SPF30 or SPF50 would be considered “high”. This is an excellent sunscreen that would suit most people’s needs, and include sunscreens that use mineral filters such as zinc as their main UV-blocking ingredient.

However, most mineral sunscreens would not meet the requirements for the “very high” protection category, which covers products currently labelled SPF60 and over.

This is because it’s very hard to make mineral sunscreens with SPF higher than 50 – a very high amount of the mineral filter (up to 30% of the product’s ingredient) is needed.

At these high concentrations, the aesthetic feel of the sunscreen is compromised and stability across time and temperature can also be low.

This means the “very high” category would be predominantly chemical sunscreens.

Many people may think they need the highest protection.

However, there are some concerns about chemical active ingredients if used in high concentrations, over large areas and for an extended period of time. In contrast, mineral sunscreen types are generally regarded as safe and effective.

So an education campaign would also need to explain that “very high” sunscreens may not be suited for day-to-day use for everyone.

Editor’s note: This article was updated after publication to reflect the author’s position as a scientific advisor with the Australian Sunscreen Council, an industry body representing zinc and mineral sunscreen and raw ingredient manufacturers.

The TGA’s consultation is open for public submissions until May 23.