Conclusion

In 2006 the European Commission issued a Recommendation on the efficacy of sunscreen products and the claims made relating thereto. It is not legally-binding but the authorities expect industry to comply with it.

The Recommendation sets out:

  • claims which should not be made in relation to sunscreen products;
  • precautions to be observed including application instructions;
  • the minimum efficacy standard for sunscreen products in order to ensure a high level of protection of public health;
  • simple, understandable labelling to assist in choosing the appropriate product.

The Recommendation only covers sunscreen products whose primary function is sun protection i.e. 'beach products’.

It is acceptable to claim an SPF on a product such as a face moisturiser or foundation etc. but the main function of the product must be clear so that it cannot be confused with a sun protection product.

The European Commission has a dedicated webpage on sunscreen products. CTPA also provides a guidance note on durability claims for sunscreens.