My Worst Nightmare Is Coming True: People Are Giving Up on Sunscreen

When CHOICE and Consumer NZ released their recent report showing 16 out of 20 sunscreens failed SPF testing, my stomach sank.

Not because I was shocked, a few years ago, a Consumer NZ investigation revealed that 4 out of 5 SPF products in New Zealand didn’t meet label claims (Consumer NZ, 2019).

But what I didn’t expect was what followed:

A tidal wave of fear, frustration and confusion. DMs. TikToks. Friends calling me asking, “I’m throwing out all these sunscreens.”

As the founder of a sunscreen brand that’s been four years in the making, I can say this with certainty:

The real problem is trust. And the consequences of losing it could be far worse than a failed SPF claim.

SPF Testing Isn’t Straightforward

Here’s what most headlines don’t explain:

SPF testing is done on real people, under controlled UV lamps. Skin with and without product is compared to see how long it takes to burn. But this process is highly sensitive. Every detail matters:

• The thickness of application
• The substrate it’s applied to
• The UV intensity
• The way the formula has been stored or packaged

With GLOWGUARD, we chose opaque glass to protect the formula from UV degradation and preserve shelf life and SPF efficacy.

We also tested consumer behaviour and found people were far more likely to reseal a twist-close pipette than a pump. A small detail, but one that significantly reduces exposure to air and light.

We designed our pipette to take the guesswork out of application. One full pipette = one full face dosage. Because most research shows most people apply half as much SPF as they should. So even the best formulation won’t protect you if it’s used wrong.

That single packaging decision on which material was used could mean the difference between pass and fail. In fact, we watched six versions fail before arriving at the final, independently validated formulation, twenty iterations later.

Why Did So Many Fail? The Experts Weigh In

According to Dr Michelle Wong, many of the sunscreens that scored lowest were mineral-based. These tend to be more unstable over time, especially if the formulation isn’t optimised or the storage conditions aren’t controlled.

The TGA, Australia’s sunscreen regulator, has acknowledged the complexity and is actively investigating the CHOICE findings. They’ve also confirmed that sunscreen testing on humans involves variability and inconsistencies across labs.

➡ Read the full TGA response here

That matters. Because under current rules, most sunscreens are tested once before approval. After that, brands only monitor for texture, colour, or pH — not SPF integrity.

Not All SPF Products Are Regulated the Same

In Australia, SPF products fall into two categories:

1. Primary sunscreens (e.g. SPF50, used to prevent sunburn)

• Testing to AS/NZS 2604:2021
• AUST L number
• GMP-compliant manufacturing
• Label and ingredient approval

(TGA, 2023; “Sunscreens – Cosmetic or Medicine?”)

2. Secondary sunscreens (e.g. tinted moisturiser SPF15)

• Treated as cosmetics under AICIS
• No independent testing required
• Claims can be brand-declared without oversight

The result? Many beauty-adjacent SPF products on shelves haven’t been independently verified.

Navigating SPF Standards: Melitta Skin Approach

SPF regulation is complex, especially across different markets, and behind the scenes, there’s a lot most people never see. Here’s how we approached it.

To formulate GLOWGUARD, we partnered with a world-leading Korean lab with over 30 years of R&D in sun care and more than 9,000 licensed functional cosmetic products. Known for setting the gold standard in sunscreen innovation, they specialise in broad-spectrum protection, photostability, and makeup-compatible textures.

Their facilities are certified to the highest global standards:

• ISO 22716 – Cosmetic Good Manufacturing Practice
• ISO 17025 – Accredited SPF and UVA testing laboratory
• ISO 9001 – Quality Management
• ISO 45001 – Occupational Health and Safety

These certifications are internationally recognised and rigorously audited, ensuring GLOWGUARD is made with the same precision and integrity trusted by the world’s top skincare brands.

Locally, we also took extra steps to ensure compliance in Aotearoa:

• Reviewed Commerce Commission guidance with our branding agency
• Consulted SmartReg NZ for SPF-specific regulatory alignment
• Completed training via Regulatory Training Direct
• Conducted multiple rounds of independent lab testing to validate our SPF and UVA claims

We’ve also aligned with two emerging international SPF standards and recommend other brands do the same:

• ISO 23698:2024 – Regular revalidation of SPF and UVA protection
• ISO 23675:2025 – Post-market surveillance to ensure claims hold up over time

This wasn’t about ticking boxes. It was about building a sunscreen people could genuinely trust.

The Real Risk: Giving Up on Sunscreen Altogether

This is my nightmare.

Because when trust erodes, people don’t just delay reapplying — they stop wearing sunscreen altogether.

In Australia and New Zealand, two of the most UV-intense regions in the world, that’s a public health disaster.

And the worst part? It doesn’t have to be this way.

One of the most important sunscreen studies ever conducted, the Nambour Trial—tracked over 1,600 people for 15 years. The results were astonishing:

• 73% reduction in invasive melanoma
• Tumour thickness halved
• 22% fewer precancerous lesions in 2 years
• 24% less visible ageing
• No acceleration of skin ageing after 4.5 years of daily use

This isn’t theory. These are statistically significant human outcomes.

What Needs to Change

Here’s what we’re calling for as a brand and as believers in better sun care:

• Mandatory independent testing for all SPF products (not just those regulated as medicines)
• Clearer education for consumers around application, reapplication on labelling
• Better brand accountability when it comes to claims, packaging, and testing transparency
• Public awareness of sun protection as a layered approach — from hats to shade to sun avoidance

Let’s Rebuild Trust, Together

This moment has cracked open a necessary conversation.

Let’s not waste it.

Sincerely,

Melitta