Strengthening SPF Governance After the 2025 CHOICE Investigation

February 26, 2026

In June 2025, the widely publicised sunscreen investigation by CHOICE placed renewed national focus on SPF testing in Australia. Given Australia’s world-leading skin cancer rates, scrutiny of sunscreen performance is both necessary and appropriate.

However, the investigation also highlighted long-standing scientific limitations associated with the current internationally recognised in vivo SPF testing method, ISO 24444.

At Wild Child Laboratories, we saw this as an important inflection point for the industry. Rather than treating it as a compliance event, we used it as an opportunity to strengthen our sunscreen governance framework, testing oversight and sponsor communication protocols.

A TGA-licensed facility: Specialising in sunscreen development and manufacturing in Australia, we recognise that SPF products are not cosmetic luxuries – they are regulated therapeutic goods and essential public health tools.
Beyond compliance: Our responsibility extends beyond minimum compliance to scientific leadership, transparency, and risk management.

Understanding SPF Variability in ISO 24444 Testing

To understand the events of 2025, it is important to understand SPF variability. The ISO 24444 in vivo method relies on human volunteers and visual assessment of erythema (skin reddening following UV exposure).

While this method is globally accepted, inter-laboratory variability – particularly at higher SPF levels – is well documented in scientific literature and internationally acknowledged by regulators including the Therapeutic Goods Administration. In practical terms:

Numerical differences: Small differences in erythema assessment can result in significant numerical SPF differences.
SPF 50+ challenges: Variability increases at SPF 50+ levels due to the compressed erythemal response range.
Safety vs. Numbers: A numerical difference does not automatically indicate product instability or safety risk.

How We Strengthened Our SPF Governance Framework

Following a comprehensive internal technical review of our SPF testing and regulatory systems, Wild Child Laboratories implemented enhancements across five key pillars.

1. Expanded Confirmatory SPF Testing Pathways

We strengthened our approach to confirmatory SPF testing to ensure statistical robustness and regulatory defensibility. Where appropriate, we incorporate independent laboratory verification and cross-laboratory comparison. This reduces reliance on a single in vivo data set and aligns with best practice expectations for TGA sunscreen compliance.

2. Enhanced Laboratory Selection and Oversight

Robust governance begins with laboratory selection. We enhanced due diligence processes including:

Verification of ISO accreditation
Technical capability assessments
Method alignment review (including ISO 24444 compliance)
Calibration and procedural oversight

3. Cross-Functional Technical Review

SPF reports now undergo deeper internal review involving regulatory, quality, and formulation specialists prior to finalisation. Each result is assessed for statistical context, manufacturing consistency, and risk implications to strengthen documentation and sponsor confidence.

4. Conservative Risk Assessment Framework

Where SPF results sit near regulatory thresholds (e.g. SPF 50+ classification boundaries), we apply structured decision-making protocols that evaluate regulatory risk, commercial exposure, and consumer trust considerations.

5. Transparent Sponsor Communication

We implemented clearer communication pathways so sponsors understand expected SPF variability ranges, confirmatory testing options, and forward strategy scenarios. Clear technical communication is essential in modern sunscreen manufacturing in Australia.

Why This Matters for Brands Developing SPF Products

The SPF landscape in Australia has changed. Governance expectations are higher, retail scrutiny has increased, and consumers are more informed. Wild Child Laboratories has invested significantly in providing regulatory intelligence and audit-ready documentation.

For brands seeking reliable SPF testing Australia expertise combined with compliant sunscreen manufacturing Australia capability, governance strength is now as important as formulation innovation. Reach out to Wild Child today to ensure your next product launch is backed by scientific leadership.

Frequently Asked Questions

Yes, our minimum order quantities (MOQs) are a function of the calibrated weights of our mixing vessel and the capacity of our filling lines. Depending on the unit size of the final product the MOQ will typically be around 10,000 units.

We do not have a product catalogue. Products will be suggested by our Product Development team based on the information you provide through the new product enquiry form.

Yes, with a better understanding of your product requirements we will develop a lab sample(s) for your review and ultimate approval. Depending on level of customisation or development required, this service may incur a fee.

Typically, 12 – 14 weeks from the placement of purchase order and payment of the deposit. Please note, the manufacturing lead time is dependent on the availability of the raw materials and packaging components, which can be confirmed prior to the placement of your order.

No, all our pricing is EX WORKS. Whilst we do not provide freight and distribution services, we can assist with the freight quotation and booking from our Facility.

Upon placement of purchase order, a 50% deposit is required, and balance is due prior to the release of the finished goods.

Yes, we can provide packaging options based on formulation compatibility and compliance standards. Alternatively, clients can provide their own packaging with the understanding that it must be compatible with our equipment and meet compliance standards.