Sunscreen is not treated as ordinary skincare in New Zealand or Australia. In NZ it must meet a mandatory product safety standard enforced by the Commerce Commission. In Australia, most sunscreens are therapeutic goods that must be listed on the ARTG before sale. That means human SPF testing, a five-figure testing budget, and a longer runway than a serum or moisturiser.
"Can you make me a sunscreen?" is one of the most common questions we get from indie founders in New Zealand and Australia. The honest answer is that sunscreen sits in a different regulatory category from the rest of your range — and knowing that early saves months and a lot of money.
Why is sunscreen regulated differently from other skincare?
Every other product in your range is a cosmetic, assessed on ingredients and manufacturing quality. Sunscreen makes a health protection claim: "SPF 50+" is a measurable promise about how much UV a consumer will be shielded from, and regulators in both countries treat it as such. You cannot calculate SPF on paper or borrow a number from your UV filter supplier — it must be measured on human skin, on your finished formula, in your final packaging.
How is sunscreen regulated in New Zealand?
Since 8 March 2022, sunscreen sold in New Zealand has had to comply with a mandatory product safety standard — AS/NZS 2604 Sunscreen products: Evaluation and classification — under the Sunscreen (Product Safety Standard) Act, enforced by the Commerce Commission. It captures more products than founders expect:
- Primary sunscreens (products whose main purpose is UV protection)
- Insect repellents with a labelled SPF of 4 or more
- Skincare products — moisturisers, oils, creams, gels — with a labelled SPF greater than 15
The standard sets out testing methods for SPF, broad spectrum and water resistance, plus labelling rules. The Fair Trading Act applies on top — any SPF you advertise must be protection your product actually delivers. The practical takeaway: an SPF 15 day cream and an SPF 50+ sunscreen are very different projects, and crossing the SPF 15 threshold changes your obligations.
How is sunscreen regulated in Australia?
Australia splits sunscreen between two regulators, depending on the product's purpose and SPF.
Therapeutic sunscreens — primary sunscreens with an SPF of 4 or more, and secondary sunscreens such as moisturisers with an SPF above 15 — are regulated by the Therapeutic Goods Administration (TGA). They must be included in the Australian Register of Therapeutic Goods (ARTG) before they can legally be supplied, currently via the listed medicines pathway, and must comply with the Australian Regulatory Guidelines for Sunscreens.
Cosmetic sunscreens that fall outside the therapeutic definition are excluded from therapeutic goods legislation and sit with AICIS (the Australian Industrial Chemicals Introduction Scheme) instead — but you still need to register your business with AICIS before introducing the product.
Worth watching: in March 2026 the TGA opened a consultation on improving sunscreen regulation in Australia. If you are planning a 2027 launch, allow for requirements shifting.
What does SPF testing actually involve, and what does it cost?
SPF is determined in vivo under ISO 24444 — a panel of ten to twenty human volunteers, controlled UV exposure, measured on your finished product. Broad spectrum and water resistance are separate tests again. Realistic expectations for an indie brand:
- Cost: a full SPF, broad spectrum and water resistance panel typically runs into five figures per formula — before manufacturing
- Retesting: change the formula, the pack or the filter supplier and you may need to test again
- Timeline: testing labs book out months ahead, particularly heading into the southern summer
- Batching: you cannot spread that cost over 100 units the way you can with a serum
That last point decides most projects. Our low-MOQ model — 100 units on Ready-to-Go formulations, 500 on fully custom work — exists so indie brands can launch without gambling their savings. Sunscreen resists that logic, because the testing cost is fixed no matter how many units you make.
Can an indie brand realistically launch a sunscreen?
Yes — but treat it as a stage-two product, not a launch product. Before committing, answer three questions: is your SPF claim commercially essential or just nice to have; can you fund testing without starving the rest of your range; and can you order enough volume to make the per-unit maths work? If the answer to any is no, build revenue with a core range first.
What are the smarter alternatives while you build?
Most brands that come to us for sunscreen actually want the outcome behind it — a product that supports skin exposed to harsh NZ and Australian UV. That is achievable without an SPF claim: antioxidant day serums worn under a sunscreen, after-sun and barrier repair formulas, or post-exposure recovery products using local actives.
These fit standard cosmetic pathways: The Accelerator (4–6 months, starting from around $2,000) for a semi-custom route to shelf, or The Visionary (9–12 months, starting from around $4,000) for a bespoke formula with full IP transferred to you before manufacturing. Both include compliance documentation for New Zealand, Australia, the EU and the US, and both can be developed cruelty-free, vegan and fragrance-free.
Frequently asked questions
Do I need to test SPF in New Zealand if my product is already tested overseas?
Testing done to the recognised ISO methods is generally accepted, but the test must be on your finished formula in your final packaging. A certificate for a supplier's base, or for a similar-but-not-identical formula, will not satisfy the standard.
Can I sell a moisturiser with SPF 15 without therapeutic approval in Australia?
A secondary sunscreen at SPF 15 or below may fall outside the TGA's therapeutic definition and sit with AICIS instead. Above SPF 15, it is generally a therapeutic good requiring ARTG listing. Confirm your specific product with a regulatory adviser before you print labels.
How long does it take to bring a sunscreen to market in NZ or Australia?
Plan for 12 to 18 months. Formulation and stability work is comparable to any other emulsion, but SPF testing queues, retesting after any change, and ARTG listing in Australia add substantial time that a standard skincare launch does not carry.
Is SPF testing cheaper if I use a pre-tested base?
It can be, and some brands go this route. The trade-off is that you inherit someone else's formula and cannot change it meaningfully without invalidating the test data — so you lose the differentiation and IP ownership that custom formulation gives you.
What SPF-adjacent products can I launch with a low MOQ?
Antioxidant serums, after-sun gels, barrier creams and post-exposure recovery products all sit in standard cosmetic pathways, so you can start from 100 units on a Ready-to-Go base or 500 units on a fully custom formula. If you are unsure, a 30-minute Ask The Chemist consult ($150) is the fastest way to get a straight answer before you spend anything on development.
The honest summary
Sunscreen is one of the few categories where we will often tell a brand to wait — not because it cannot be done here, but because the testing economics punish small volumes, and an indie brand's first product should build momentum rather than consume it. Not sure which side of that line you are on? Talk to us — we would rather give you a clear no than an expensive maybe — or compare the routes to shelf on our services overview.
