The FDA finally made some changes to the labeling regulations of sun protection products. While I still feel there is work to be done in terms of regulating ingredients in terms of toxicity, I think that the new regulations are a huge step in the right direction.
I wrote the following article for Dermascope Magazine, which they published in their January 2012 issue and have given me permission to reprint for you here. Even though the magazine goes out to aestheticians and other professionals in the spa and wellness industries, the information is very important for all consumers to have since these changes will take effect this summer. See the original article here (you have to be a subscriber to read it in its entirety). I had the opportunity to speak with Timothy Turnham, Executive Director of the Melanoma Research Foundation, who provided me with the information and resources for this article. 

This information is very important for all consumers, since it affects everyone who purchases and uses sunscreen (which should be everyone, every day regardless of skin tone, ethnicity, or climate). Please read it and share it with your friends and family members. If you have any questions about the new regulatory guidelines, please ask here in the comments or email me at, and I will get back to you with the answers.

There is a great amount of confusion regarding the use of sunscreen. There is a myriad of different products on the market with SPF (sun protection factor) values ranging from 2 to over 100, products claiming that they are waterproof, that they offer protection from UVA and UVB rays; sprays, creams, powders, gels, etc. Furthermore, these products are available in many different price ranges in many different places from dollar stores, to drug stores, to department stores, to spas, and even in some physician’s offices. All of these factors make it difficult for consumers to know which sunscreen to buy, how much and how often to apply it, and how long they can stay out in the sun while wearing it. For example, is it better to buy the SPF 100+ waterproof broad spectrum product from the local pharmacy for $9.99? Or is it better to purchase the organic SPF 20 tinted moisturizer with antioxidants and peptides for $65 at the spa? Do higher SPFs mean better protection, or does a higher price tag from a trusted professional mean a higher quality and a more effective product? Along the same lines, how are aestheticians and spa owners supposed to make the decision which sun protection products to recommend to their clients and carry for retail sale?


New sunscreen testing and labeling regulations by the FDA will help clear this up.

On June 14, 2011 the U.S. Food and Drug Administration announced that starting in the summer of 2012, sunscreen products will have to undergo different tests to determine how they will be allowed to be labeled and marketed. Prior to this announcement, there had not been any parameters regarding what kind of claims manufacturers could make, what buzz words they could print on their labels, or how they could market their products in 33 years.

Think about that: 33 years ago, most people thought of “sun care” as oiling up with baby oil and using those wacky foil reflectors to get as tan as possible. Sunscreens, or “suntan lotions” only offered SPF (UVB) protection, because people wanted to tan, but did not want to burn. Even so, it was rare to see a sunscreen product with anything higher than an SPF 15. Between then and now, sunscreen manufacturers did not have many rules regarding marketing, labeling, and making certain claims about their products’ functionality and efficacy.

Times have changed.


We have now what we didn’t have back then: scientific evidence that overexposure to UVA and UVB rays causes skin cancer and is responsible for the majority of how the skin ages. The new FDA guidelines will make sure that the different claims made by manufacturers undergo thorough and standard tests, and that the products are labeled accordingly.

I recently had the opportunity to learn about these new guidelines during my interview with Timothy J. Turnham, the executive director of the Melanoma Research Foundation (MRF). Turnham is very pleased with the new guidelines, feels that they are solid, and that the laws are finally catching up to all of the information science has uncovered.

The most significant changes:


• There will be an established floor and ceiling for SPF with a minimum of 15 and a maximum of 50. Evidence has shown that only broad spectrum products that have an SPF of 15 or higher “have been shown to reduce the risk of skin cancer and early skin aging when used with other sun protection measures.”1 Therefore only broad spectrum sunscreens with an SPF of 15 or higher will be able to claim to reduce risk of skin cancer and early skin aging. Any product with an SPF lower than 15 will only be allowed to claim to “help prevent sunburn.” Conversely, there is no significant evidence supporting claims that SPFs higher than 50 offer more protection than an SPF 50. Therefore the highest SPF value on the new labels will be “SPF 50+”.

• In order to use the term “broad spectrum SPF” on a product, the amount of UVA protection must be proportional to the amount of UVB protection. When consumers see the term “broad spectrum SPF” they can be sure the product has passed the FDA’s tests to ensure equal protection from UVA and UVB rays. Prior to these rules, manufacturers did not have to disclose how much individual protection the product gave against UVA and UVB rays, and the products often did not give adequate UVA protection.

• There will be no more claims that a sunscreen is “waterproof” or “sweat proof”, because these claims make people believe that they can apply the product once, then be in and out of the water all day and not have to reapply. UV rays reflect off water and can cause severe burns once the “waterproof” product wears off. To remedy this, the FDA will now only allow products to claim that the product is “water resistant”. Manufacturers will also have to specify on the label how long the water resistance is good for, whether it is 40 minutes or 80 minutes while swimming or sweating. These times will be based on the results of standard testing. Sunscreens that have not gone through or passed these tests will not be able to claim any protection while swimming or sweating, and will have to state on the label that a water resistant product must be worn for adequate protection during these activities.

• There will be new application recommendations as well. People often and mistakenly believe that using a product containing a higher SPF means that they can stay out in the sun longer and not have to reapply as often as lower SPFs. This is not true. No sunscreen will be allowed to claim protection for longer than two hours. Turnham recommends that all sunscreens, regardless of SPF value, be reapplied at least every two hours, and after swimming or sweating.

• All over-the counter sunscreen products, even those used in skin care products and cosmetics, must be labeled as drug products and state the Drug Facts on the back or side of the package/product.

What about sprays?


Sprays have become the preferred delivery system of sunscreen by many people due to the convenience factor. However, current data questions whether or not this type of application is as effective as directly applied thicker creams and lotions. The FDA is requesting additional data on this topic before issuing specific guidelines for sprays.

The treatment room is the perfect place to educate consumers about sun safety.


The MRF has long considered aestheticians, cosmetologists, massage therapists, and other body workers to be crucial in educating clients about skin cancer prevention and early detection. We may have access to parts of the body, like the bottoms of the feet or the top of the scalp that the clients can’t easily see or wouldn’t necessarily think to check for suspicious lesions. While it is not our job to diagnose or give any medical advice, we have the opportunity to point out anything that does not seem normal and recommend that the client has it checked out. Clients are also typically more relaxed in the spa atmosphere and often really trust their providers and are more likely to ask about any concerns they may have before calling a dermatologist to get checked out.

One of the most important roles an aesthetician has is to educate their clients on how to take care of their skin. By informing clients about these new regulations, better purchasing decisions can be made. Turnham recommends that we in the aesthetics industry advise our clients to:

• Look for both UVA and UVB protection
• Not use anything less than SPF 15
• Not pay extra for anything higher than SPF 50+
• Reapply, reapply, reapply

Turnham also notes that along with the fact that most people do not reapply sunscreen as often as needed, most people also do not apply as much quantity of the sunscreen as is necessary. It is recommended that approximately one ounce (about a shot glass full) of sunscreen be used for each application. Clients should also be educated that along with proper and regular use of sunscreen, people should wear protective clothing and seek shade when outdoors; especially in peak hours between 10 am and 4 pm. Turnham also suggests that we remind clients that sunscreen should be worn whenever outdoors, regardless of the temperature. It’s not about how hot it is outside, the sun’s UV rays are there regardless and can reflect off snow and rain which can cause burns.

For more information, please check out the Melanoma Research Foundation’s sun safety tips on their website, and the FDA’s sunscreen info on their website.

Original article reference: 

Pontillo R. What aestheticians and clients need to know about the new FDA sunscreen guidelines. Dermascope 2012; (37)1: 64-72.

1. “Questions and Answers: FDA Announces New Requirements for Over-the-counter (OTC) Sunscreen Products Marketed in the U.S.” U S Food and Drug Administration Home Page. U.S. Department of Health & Human Services, 23 June 2011. Web. 14 Sept. 2011. .

Reprinted with permission from DERMASCOPE Magazine

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