By Belinda Castles
Researcher | Kairangahau
Australia has proposed stricter sunscreen testing rules, and Consumer NZ believes New Zealand should follow suit. Our latest test found 7 out of 10 sunscreens didn’t meet the SPF claim on the label.
In October, Australia’s sunscreen regulator – the Therapeutic Goods Administration (TGA) – proposed reforms to improve how sunscreens are tested.
The reforms include making brands:
test the finished sunscreen rather than just the base formula
provide test results to the TGA before going to market
test periodically (the exact frequency hasn’t been announced) while a sunscreen is being sold – there are currently no requirements for how often products must be tested
It’s also proposing to strengthen accreditation of labs that carry out SPF tests.
New Zealand needs to implement the reforms too. At present, we’re in the same boat as Australia with regards to testing: brands can rely on results for the base formula, they don’t have to provide those results to the regulator (in our case the Commerce Commission), and they don’t have to test periodically. We’ve been campaigning for years about the fixes that would strengthen sunscreen regulation and better protect consumers.
What’s the problem?
Sunscreen is one part of your defence against damaging UV rays, so it’s important you can trust the claims on the label. But that’s not always the case. In our latest sunscreen test, we found 7 out of 10 products failed to meet the SPF claim on the label.
Our recent findings follow a 2025 Australian investigation that found 11 sunscreens available in New Zealand didn’t meet their SPF label claims.
Previous Consumer NZ investigations have also repeatedly identified problems with sunscreen SPF claims.
We’ve also been concerned about inconsistent results between testing labs when sunscreens have been tested the same way, which is why stronger lab accreditation matters. In 2025, we reported on concerns about sunscreen testing by Princeton Consumer Research (PCR). In 2021, we reported on a major sunscreen fraud by US-based AMA Laboratories.
Time to improve New Zealand regulations
Sunscreens are required to meet a mandatory sunscreen standard but, unlike Australia where they are regulated as a therapeutic product, here they are currently regulated as a cosmetic. We've been campaigning for them to be regulated as a therapeutic product for many years – this would give Medsafe stronger powers to request evidence and testing.
The New Zealand government is considering how sunscreens are regulated in Aotearoa. Under the proposal, sunscreens would be regulated as a “boundary product” under the Medical Products Bill. This recognises that sunscreens sit between a cosmetic and a medicine.
While this is a step in the right direction, we believe the stricter rules being proposed in Australia should be implemented here too.
We will continue to advocate for better sunscreen regulations. For a country with one of the highest melanoma rates in the world, the current environment and what’s being proposed just isn’t good enough.
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