Sunscreen products: better consumer information means better protection
The European Commission intends to revise the recommendations on safety and efficacy claims for sunscreen products it issued to industry in 2006. Its aim is to provide consumers with better guidance when choosing and using these products. ANSES has produced an opinion in support of this revision that calls for the recommendation to be made clearer and more restrictive, in order to provide better protection for users of sunscreen products.
Exposure to ultraviolet (UV) rays is the main risk factor for skin cancer. It also causes sunburn and premature ageing of the skin. Preventive measures can be taken to limit exposure at the source: seek shade, wear clothing that covers the body, limit the duration of exposure and avoid the time of day when UV radiation is most intense. Sunscreen products are an additional means of protecting parts of the body that remain exposed (face, hands, etc.). For optimal efficacy and safety, users need to be correctly informed in order to choose the right products and use them properly.
A sunscreen product must protect against both UVB and UVA rays
Ultraviolet A (UVA) rays penetrate deep into the skin and are responsible for its ageing;
Ultraviolet B (UVB) rays only penetrate the surface layer of the skin (epidermis). They are the main cause of sunburn and are a thousand times more powerful than UVA rays.
Although UVB rays are the main factor responsible for skin cancer, because they can directly alter DNA, UVA rays play a non-negligible role in its onset.
Aiming for clearer, more accurate information on the efficacy of sunscreen products
Sunscreen products are cosmetics, as defined in Article 2 of Regulation (EC) No 1223/2009. An annex to this regulation sets out the list of UV filters authorised by the European Commission. In addition, the European Commission's 2006 recommendation gives manufacturers guidance on information about the safety and efficacy of sunscreen products: claims about the efficacy of protection against UVA and UVB rays, precautions for use and usage instructions.
In June 2024, the European Commission launched a review of this recommendation. This led ANSES to provide expert advice on the changes to be incorporated in the revised recommendation. For the Agency, it should provide manufacturers with a clearer and more restrictive framework in terms of efficacy and claims for these sunscreen products.
Distinguishing between sunscreen products and cosmetic products containing a sun filter
In addition to sunscreens, cosmetics with a UV filter in their formulation, but whose main purpose is not to protect against UV radiation, are also available on the market. They include products such as day creams or make-up with a sun protection factor (SPF).
Consumers' behaviour regarding these products is not the same as when they use "sun care" products to specifically protect themselves from UV rays: the products are applied once a day, generally in the morning, and in smaller amounts (particularly in the case of powder make-up). Sunscreen products, on the other hand, need to be applied in sufficient quantity and then reapplied during the day to be fully effective.
These so-called "secondary sunscreen" products can cause confusion in terms of their level of protection from the risks of UV exposure. ANSES therefore recommends that these products should not be permitted to claim that they provide sun protection by displaying an SPF on the label.
Simplify product labelling to improve consumer understanding
ANSES insists that labelling should focus on essential information to enable consumers to better identify the level of sun protection provided. People need to be guided in their choices so that the products they buy are suited to their skin type and the intensity of their exposure to the sun.
In the interests of simplification, ANSES recommends that product labels should no longer display the sun protection factor (SPF) – the value relating to protection against UVB rays – or the UVA logo. It proposes keeping only the low, medium and high protection categories, which already include protection from both types of UV. The aim is to focus users' attention on overall protection performance, because the SPF has given rise to a biased consumer perception when comparing performance on protection against all UV rays, as it only reflects protection from UVBs.
Revise the protection level categories
ANSES recommends revising the correspondence between SPF values and the assigned categories. Currently, sunscreen products can have SPF values of between 6 and 50+. However, ANSES considers that:
- products with an SPF of 6 or 10 offer little protection against UVB rays, and even less against UVAs, since this protection equates to only a third of that offered against UVBs.
- "Very high protection" products, which have an SPF of 50+, offer no substantial increase in protection from UV radiation compared with products having an SPF of 50. This statement could nevertheless give the impression that they provide a level of protection enabling consumers to increase their exposure to the sun. For these reasons, the experts suggest abolishing the "very high protection" category.
The categories could be redefined according to three levels of protection:
- "Low protection": containing SPF 15 and 20,
- "Medium protection": containing SPF 25 and 30,
- "High protection", containing SPF 50 and 50+.
ANSES reiterates that babies and young children should not be exposed to the sun, as they are more vulnerable to the carcinogenic effects of UV rays. The Agency therefore considers that claims specifically targeting the protection of these sensitive populations should be prohibited. The use of a sunscreen product should remain a last resort, in addition to the preventive measures.
Furthermore, data on the use of these products show that the amounts actually applied by users are on average lower than those applied to achieve the indicated level of protection. It is therefore important that the amount of product to be applied is stated on the label, is easy to understand and is adapted to the product formulation: cream, spray, stick, oil, foam, etc. For example, with a lotion, six teaspoons (around 36 grams) should be applied to the entire body of an average adult.
What is the sun protection factor (SPF)?
The SPF reflects the level of protection against UVB rays provided by a sunscreen product. This is currently defined in the European recommendation as the ratio of minimum erythemal dose on skin protected by a sunscreen product to the minimum erythemal dose on the same unprotected skin.
Impact of sunscreen products on aquatic organisms
The current European recommendation only provides guidelines for human health. However, adverse effects of UV filters have been reported on various aquatic organisms. These issues should therefore be taken into account when updating the 2006 recommendation, considering not only the immediate impact on aquatic organisms, but also the longer-term impact on ecosystems.
In its expert appraisal on the risks of chemicals to coral reefs published in 2022, ANSES recommended relying on existing regulations to prohibit the claims and logos found on a number of sunscreen products stating that they respect the marine environment without having demonstrated that they are harmless. It also stressed the need for standardised methods for demonstrating the safety of UV filters to corals.
Over 80% of skin cancers are due to excessive exposure to the sun
ANSES stresses the need to raise public awareness of general preventive measures such as avoiding peak sunlight hours, wearing clothing that covers the body and is, if possible, anti-UV, and seeking shade, in order to better meet the public health challenge of protection from the risks of UV exposure. Read all the tips on sun protection.