Consumer NZ’s latest lab test found seven of the 10 sunscreens it checked failed to meet the SPF printed on the bottle. The worst offender, Coola Zinc Oxide Sunscreen Lotion 50, sells for $69 to $76 per 100ml and tested at just SPF14. That is less than a third of its claim.
Most coverage has treated this as a summer health warning. For manufacturers, importers, pharmacies and retailers it is something more pointed. A label that overstates SPF is a misleading claim made in trade, and the legal machinery to punish it has existed since 2022.
Price bought nothing
The uncomfortable detail for premium brands is that cheap products did the job. Of the three sunscreens that met their claims, two cost less than $10 per 100ml or 100g, including the cheapest product tested, Smart365 Sun Sunscreen Lotion SPF50+, and Cancer Society Everyday Protection SPF50.
The health picture is less alarming than the headline suggests. Six of the seven failures still delivered SPF30+ protection, and all 10 met broad-spectrum requirements. But that is cold comfort to a brand charging a premium for a number it cannot hit. To legitimately claim SPF50+, a product must test at SPF60 or higher. The gap between label and lab is the legal problem, regardless of whether anyone got burnt.
“Consumers should be able to trust what’s printed on a product label,” Consumer NZ researcher Belinda Castles said.
The law has teeth nobody has used
The Sunscreen (Product Safety Standard) Act 2022 made the joint standard AS/NZS 2604:2012 mandatory and hooked enforcement into the Fair Trading Act. Breaches carry fines of up to $600,000.
On paper that is a serious regime. In practice it has a hole in the middle. The government’s own March 2026 Regulatory Impact Statement concedes there is “no requirement for ongoing testing after initial approval”, that labs need not be accredited to ISO standards, and that the system relies largely on complaints-based enforcement. A product can pass once, change supplier or formulation, and keep carrying the same claim for years.
The same document records that nearly 30 sunscreens using a common base formulation in Australia and New Zealand have been recalled, paused or reviewed over SPF reliability. Officials already know the scale of this. Consumer NZ’s October test simply put fresh brand names on it.
Third strike in five years
This is not a one-off. In 2025, Australian consumer group Choice found 16 of 20 sunscreens failed their SPF claims, including 11 products sold in New Zealand from household names such as Nivea, Banana Boat, Bondi Sands and Neutrogena. Consumer NZ’s own 2021 testing had flagged similar results.
The fallout in 2025 exposed how messy compliance gets. Ultra Violette recalled its Lean Screen product after retesting produced results ranging from SPF4 to SPF64 across labs, while some paused products stayed on shelves at stockists’ discretion. RNZ also reported that a Commerce Commission complaint required independent testing costing upwards of $5,000 per sunscreen, which goes a long way to explaining why enforcement waits on consumer groups.
Consumer NZ has again shared its findings with the Commerce Commission. Despite repeated rounds of damning results, none of the coverage reviewed points to a named company facing a fine or enforcement order.
Stockists should not wait for the regulator
The absence of a prosecution is not a safe harbour. It is a backlog. The Fair Trading Act bites on anyone in trade making misleading representations, and a pharmacy or retailer that keeps selling a product after a public test showing it delivers a fraction of its claim will struggle to argue it did not know.
The sensible response is unglamorous. Ask suppliers for current, accredited test reports rather than the ones that got the product listed. Build retesting and recall obligations into supply contracts. Have a refund policy ready before the next test lands, not after. For private-label sunscreen, the retailer is the brand, and the exposure is direct.
This is also one area where more regulation is hard to argue against. A Cabinet paper has floated treating sunscreen as a boundary product under the Medical Products Bill, which would mean a tighter pathway than the current honesty system. Businesses that can show their claims hold up should welcome it, because it stops honest products being undercut by labels that cost nothing to print.
The next summer is weeks away, and consumer testers keep finding the same problem. Sooner or later the Commerce Commission will pick a case to make an example of. Every brand and stockist should assume their bottle could be the one on the table.
Sources
- Scoop: Promised SPF50, Delivered SPF14: Consumer Test Exposes Sunscreen Shortfall (2026-10-30)
- Consumer NZ: SPF50 on the label, SPF14 in the lab: Sunscreen claims under scrutiny (2026-10-30)
- Regulation.govt.nz: The Regulation of sunscreen products RIS (2026-03-25)
- Consumer NZ: 11 sunscreens sold in New Zealand didn’t meet SPF claims, as revealed by an Australian test (2025-06-12)
- RNZ: A summer scandal on our shelves (2025-09-17)
- RNZ: Seven of 10 tested sunscreens fail to meet SPF label – Consumer NZ (2026-10-30)
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