A sunscreen is the only product most beauty brands will ever sell where a journalist can buy it off a shelf, send it to a laboratory, and publish a number that contradicts the label. That is not a hypothetical. It happened across Australia through 2025, and the aftershocks are still moving through supplier conversations across the region. It arrived at exactly the moment the category was expanding in the other direction — away from ultraviolet filters alone and towards visible-light protection, antioxidant support, post-exposure recovery and textures people will actually reapply. Both things are true at once: sun care has become far more interesting, and far less forgiving. This piece is about what a brand is really buying when it commissions one.
Written and researched by Priya Nair, Indie Beauty Brand Strategist · Article type: Independent Editorial · Scope: commercial and sourcing implications of the “beyond UV filters” direction in sun care, with Malaysian, ASEAN and EU regulatory reference points · Research period: August 2026 · Last reviewed: August 2026 · Corrections: via the site contact page.
Quick answer: what is a brand actually buying in a sun care project?
A brand commissioning a sunscreen is buying a tested number and the evidence chain behind it, not a filter combination. The filters are the commodity part of the transaction; what varies between suppliers is whether the labelled SPF (Sun Protection Factor) was measured on the exact formula being filled, whether the UVA and water-resistance claims have their own test reports, and whether a change request triggers a re-test or a shrug. Before comparing quotations, ask each supplier which laboratory tested which version of the formula, and on what date.
Key takeaways
- The 2025 Australian episode reset expectations across the category. Consumer group CHOICE tested 20 sunscreens labelled SPF 50 or 50+ and reported that 16 did not meet their claim; the Therapeutic Goods Administration ran a review that saw products cancelled or withdrawn through late 2025.
- “Beyond UV filters” is a real technical direction, not a marketing slogan — visible light, which no SPF number measures, can induce pigmentation that is darker and longer-lasting than UVA-induced pigmentation in deeper skin phototypes.
- Every layer added beyond the filters has a distinct commercial cost, and the largest is usually not the ingredient. It is the re-testing that the addition triggers.
- Malaysia’s sunscreen guideline applies only to products whose primary function is UV protection, which is where SPF moisturisers and SPF foundations quietly sit in a different regulatory conversation.
- The Malaysian guideline sets no numeric UVA ratio; the European Union recommends a UVA protection factor of at least one third of the labelled SPF. A brand selling into both is designing to the stricter of the two, whether or not it has noticed.
- The cheapest sun care quotation is frequently the one that has not budgeted the testing. Compare quotations on tests included, not on unit price.
Who this is for
This is written for founders, private label buyers and category managers who are commissioning a sun care product from an external manufacturer — whether that is a first SPF product for an existing skincare line, or a sun care brand built from scratch. It is a commercial and sourcing view: what to specify, what to compare, and where budgets get destroyed. If you are still shortlisting partners rather than negotiating one, our guide to evaluating an OEM skincare manufacturer comes first, and our review of sunscreen and sun care manufacturers in Malaysia covers who works in this category locally.
Why did SPF stop being a number brands could take on trust?
Because in 2025 a consumer organisation demonstrated, publicly and repeatedly, that the number on the bottle and the number in the laboratory can be different. CHOICE, the Australian consumer group, sent 20 sunscreens labelled SPF 50 or SPF 50+ for testing and reported that 16 of them failed to meet the claim. Most of the failures still tested somewhere in the SPF 20–40 range, which is a meaningful product with a wrong label rather than a product that does nothing. One tested dramatically lower and was withdrawn by its own brand. Australia’s Therapeutic Goods Administration then ran a review of the affected products; through the closing months of 2025 a series of registrations were cancelled or voluntarily surrendered and a recall was issued.
The interesting part for a brand owner is not the scandal. It is the mechanism. Almost none of the affected brands manufactured their own products, and several were positioned at the premium, clean, dermatologist-adjacent end of the market — the end that assumes trust is a given. What failed was the chain between a test report and a carton: which formula was tested, at which laboratory, at what point in the development cycle, and whether anything changed afterwards.
Test variability between laboratories is a genuine and long-acknowledged problem in SPF measurement — the in-vivo method depends on human panels and human judgement of erythema, and results carry a spread. That is precisely why the chain matters more than any single certificate. A brand that holds one report from one laboratory for a formula it can no longer confidently identify is holding very little.
What does “beyond UV filters” actually mean commercially?
It means the product is being asked to do jobs that the SPF number does not measure, and each of those jobs is bought separately. The industry framing — that modern sun care goes beyond UV filters alone, and that consumers now expect it to be effortless, enjoyable and multifunctional — is accurate. It is also, read as a purchase order, a list of additional line items.
| Layer beyond the filters | What the consumer is promised | What it costs the brand | Evidence a buyer should hold |
|---|---|---|---|
| Tint / iron oxides (visible light) | No white cast; protection against light that SPF does not cover; often better for melasma and pigmentation concerns | Shade development, pigment dispersion, and usually a separate SPF test per shade | Test report per shade; a stated position on which shades were tested and which were bracketed |
| Antioxidants | Defence against oxidative stress that filters do not absorb | Stability and colour-drift risk; sometimes a packaging change to protect the antioxidant | Stability data on the finished pack, not on the bulk |
| Post-exposure / recovery actives | “Repair” and after-sun positioning | Crowds an already-loaded formula; frequently better sold as a second SKU | Substantiation for whatever the recovery claim actually says |
| Water resistance | Sport, beach, tropical daily wear | Film formers that change skin feel; a separate test protocol | Water-resistance test report stating the duration claimed |
| Sensory upgrade (light, invisible, layerable) | Something people will reapply | The most iterative and least visible cost — repeated formulation and testing rounds | The final SPF report on the final texture, not an earlier prototype |
Two commercial patterns are worth naming. First, the ingredient is rarely the expensive part; the testing the ingredient triggers is. A brand that adds an antioxidant after a passing SPF result has not added an ingredient — it has commissioned a new formula. Second, the sensory upgrade is the layer most likely to be under-budgeted and the one most likely to determine whether the product sells twice. Application thickness is the largest single gap between a labelled SPF and the protection someone actually gets, and thickness is a function of whether they enjoy wearing it.
Why the visible-light conversation matters more in this region
Because the population most affected by visible-light pigmentation is the population most Southeast Asian brands are formulating for. Dermatology research has consistently found that visible light induces pigmentation in deeper skin phototypes that is darker and more sustained than pigmentation from UVA1 exposure, and that iron oxide-containing tinted formulations are the practical route to reducing it — including in melasma, where tinted sunscreens are recommended over untinted ones for patients prone to hyperpigmentation.
That converts a technical finding into a positioning opportunity. In markets where the dominant sun care motivation is pigmentation and tone rather than sunburn, “protects against light your SPF does not measure” is a more relevant proposition than a higher SPF number — and it is defensible, because it is supported by published research rather than by adjectives. It also has an uncomfortable implication for shade strategy: a tinted sunscreen with three shades in a market with a wide range of skin tones is a product that fits some of its audience and visibly does not fit the rest.
The category economics support the effort. Sun care is one of the faster-growing segments in personal care, with market analyses placing the global category in the mid-to-high teens of billions of US dollars and forecasting mid-single-digit to high-single-digit annual growth over the next decade. Those figures vary substantially by source and definition, and should be treated as directional rather than precise.
What can the label actually say?
Less than most brand briefs assume, and the restrictions are specific rather than general. Malaysia’s NPRA guideline for sunscreen products and the European Union’s Commission Recommendation 2006/647/EC agree on more than they differ, but the differences are the ones that catch export plans.
| Point | Malaysia (NPRA guideline) | European Union (Recommendation 2006/647/EC) |
|---|---|---|
| Scope | Applies only to products whose primary function is UV protection — explicitly not to moisturisers or colour cosmetics carrying a secondary SPF claim | Applies to sunscreen products generally |
| Minimum for a UV claim | No UV protection claim below SPF 6 | Minimum SPF of 6 for the lowest labelled category |
| UVA requirement | States that sunscreen should protect against both UVB and UVA; sets no numeric ratio | UVA protection factor of at least one third of the labelled SPF, and a critical wavelength of at least 370 nm |
| Labelling ceiling | Above SPF 50 may only be labelled “SPF 50+” — an SPF 130 result still reads SPF 50+ | Four categories: low, medium, high and very high protection |
| Prohibited claims | 100 % protection, “sunblock”, “waterproof”, “sweatproof”, and any implication that reapplication is unnecessary | “Sunblock”, “total protection”, “100 % protection” and “all day prevention” |
| Substantiation | SPF must be substantiated by testing — ISO 24444, AS/NZS 2604:2012 or the FDA 2011 Final Rule are listed as acceptable | Testing against recognised methods; UVA claims require the stated ratio and critical wavelength |
The UVA row is the one to plan around. A product developed to satisfy a Malaysian notification can carry UVA filters, describe itself accurately, and still fall short of the European ratio — because Malaysia’s guideline asks for UVA protection without fixing a number to it. Retrofitting that ratio into a finished formula is a redevelopment, not an adjustment. Filter selection is separately constrained: only UV filters listed in Annex VII of the ASEAN Cosmetic Directive may be used, within their stated concentration limits, which is why a formula lifted from a European or Korean reference product sometimes cannot be made here as written.
The scope row matters commercially in a different way. A brand launching an “SPF 30 daily moisturiser” is not launching a sunscreen under the Malaysian guideline — and should be clear internally about which set of expectations its claim is being held to, and what evidence it holds either way. The general notification obligations still apply; our NPRA cosmetic notification checklist covers the baseline.
What should a brand ask before signing a sun care quotation?
Sun care rewards a narrower and more forensic set of questions than other categories, because most of the risk sits in documents rather than in samples. The following six get to it quickly.
- Which laboratory tested the SPF, using which method, and on which version of the formula? A supplier who cannot answer the third part of that question in one sentence is the answer.
- If I change the shade, the fragrance, the emollient or the pack, what happens? The correct answer involves a re-test and a cost. An answer that involves neither is a warning.
- Is the UVA claim tested or inferred? Containing UVA filters and meeting a defined UVA protection factor are different states, and only one of them is a claim.
- Which tests are inside this quotation and which are extra? Compare quotations on this line and the ranking often reverses.
- Are all the UV filters in this formula listed in ASEAN Annex VII, within limits, for my target markets? Ask for it in writing against the market list.
- What is the stability data on the finished pack? Tinted and antioxidant-containing sun care shows problems in the pack, in a tropical supply chain, long before it shows them in a beaker.
The red flags are the mirror images: a specification sheet offered in place of a test report; a filter list quoted as though it were a protection level; a shade range priced as though shades were free; and any supplier for whom a formula change is a small favour rather than a scheduled event. The same evidence-chain discipline applies to any claim carrying a substantiation burden — the parallel case is set out in our insight on sensitive-skin claims and what buyers must verify.
Frequently asked questions
Is a higher SPF worth the extra cost?
Usually less than the price difference implies. The additional ultraviolet filtration between SPF 30 and SPF 50 is real but incremental, while the gap between a generously applied product and a thinly applied one is large. For most daily-wear positioning, money spent on texture, finish and pack usability buys more real-world protection than money spent climbing the number. Beach, sport and outdoor-work products are the genuine exception.
Do we need a separate SPF test for every shade of a tinted sunscreen?
In most cases yes, because pigment load is part of the film being measured. Some suppliers will test the extremes of a shade range and bracket the ones in between; that can be a defensible approach, but it is a decision the brand should make knowingly and document, not one it should discover in an audit. Budget shade count as a testing multiplier from the first cost model.
Can a sunscreen claim protection against blue light or visible light?
It can describe a formulation approach, but not with an SPF-style number, because SPF and UVA protection factors measure ultraviolet only and there is no equivalent consumer-facing standard for visible light. Claims in this area should be tied to the specific evidence held — typically pigment-based attenuation supported by published research or product-specific testing — and phrased narrowly enough to match it.
Why is a sun care project quoted so much higher than a serum?
Because the substantiation is a large fixed cost that a serum does not carry. SPF testing, any UVA testing, water-resistance testing and the re-tests triggered by changes are booked external laboratory work with their own lead times. A sun care quotation that looks comparable to a serum quotation is usually one where those items have been left out of scope.
Our supplier says the formula is “based on” a tested reference. Is that acceptable?
Not as substantiation. “Based on” means the formula is not the tested formula, and the labelled number has to belong to the product being filled. Treat a reference-formula test report as background information about a supplier’s capability, then commission testing on the actual product.
Sources and evidence
- National Pharmaceutical Regulatory Agency (NPRA), Guidelines for Control of Cosmetic Products in Malaysia, Annex I Part 9(i) — Guideline for Sunscreen Product (scope, SPF classification, substantiation methods, prohibited claims, mandatory warning).
- Commission Recommendation 2006/647/EC on the efficacy of sunscreen products and the claims made relating thereto (UVA protection factor ratio, critical wavelength, protection categories, prohibited claims).
- ASEAN Cosmetic Directive, Annex VII — List of UV filters which cosmetic products may contain (release of 12 December 2025).
- CHOICE, “We tested the SPF claims of 20 sunscreens. 16 failed”, June 2025, and the Therapeutic Goods Administration’s consumer information on sunscreen SPF testing.
- Zhou et al., “Guide to tinted sunscreens in skin of color”, International Journal of Dermatology (2024) — visible light, pigmentation and iron oxides.
- Test method standards referenced: ISO 24444 (in-vivo SPF), ISO 24443 (in-vitro UVA protection factor) and ISO 23675:2024 (in-vitro SPF, double-plate method).
- Market sizing figures are drawn from commercial market-research summaries, which differ materially in scope and methodology; they are cited here as directional only.
Source / inspired by: the theme of this article — that modern sun care has moved beyond UV filters alone — is drawn from Azelis Personal Care’s inspiration material on sun care formulation. See the Azelis Personal Care inspiration hub and the Azelis sun care and self-tan overview. The research, regulatory analysis and commercial conclusions here are independent.
Further reading: for the manufacturing side of the same question — why adding to a sunscreen sends it back for testing — see Why Changing a Sunscreen Formula Means Testing the SPF Again, written from a contract manufacturer’s perspective.
Limitations and scope
This is a desk-based commercial analysis, not laboratory work. No sunscreen was tested for this article and no supplier’s documentation was audited; the CHOICE and regulator findings are reported as published by those organisations. Regulatory positions are summarised from the primary documents linked above and were current at the time of writing — sunscreen rules and permitted filter lists are amended regularly, and the ASEAN annexes in particular move on a recurring cycle. Cost and testing implications described here are general category patterns and will vary by product format, shade count, target markets and laboratory. Nothing here is regulatory or legal advice; verify claim wording and filter permissibility for your specific markets before committing to artwork.
Update history
| Date | Change |
|---|---|
| 13 August 2026 | First published. |
This article is independent editorial research written to help brand owners ask better questions of prospective manufacturers. It does not rank, endorse or recommend any specific supplier, and no product mentioned was tested by this publication. Verify test reports, filter permissibility and claim wording directly with your manufacturer and the relevant regulator for each market you sell in.