Sunscreen Products: UV Filter List and SPF Labelling (Malaysia)

For a sunscreen product to be compliant, two gates are indispensable: the UV filters used must be compliant, and the SPF stated must have a basis. The former governs "can you put in this sun-protection ingredient, and how much"; the latter governs "has the sun-protection factor you state actually been tested". If either gate fails — using a non-permitted filter, or labelling SPF arbitrarily — it counts as non-compliant. This article helps you understand the core ingredient and labelling rules for sunscreens. (For the full overview, see the Malaysia Cosmetic Regulations and Labelling Guide.)

UV filters: only the permitted list may be used

Sunscreens may only use the UV filters permitted in Annex VII of the ASEAN Cosmetic Directive (ACD), and must be within the concentration limit for each ingredient. Using a filter not on the list, or exceeding the concentration limit, is non-compliant.

This shares its logic with restricted ingredients: it is not that "any sun-protection ingredient can be added", but that "only those on the list, within the prescribed concentration, may be added" (see further Cosmetic Restricted Ingredients and Concentration Limits). Two common pitfalls in practice: one, a UV filter in an imported formula is legal in the country of origin but is not on the ACD permitted list; two, a filter is overdosed to push up the SPF. Both cause problems during inspection.

It is worth noting that sun-protection ingredient rules vary from place to place: a filter that is a common ingredient in Europe or the US may not be on the permitted list under the ASEAN Cosmetic Directive, or may have a different concentration limit. So the only basis for judging whether a sunscreen formula can be sold in Malaysia is ACD Annex VII, not the permission of the country of origin or a supplier's verbal assurance. Checking every UV filter against the permitted list and its concentration limit is a basic step that cannot be skipped before a sunscreen goes to market.

SPF / PA labelling must have a basis

The labelling of sun-protection performance is not marketing copy but a claim with test substantiation:

• Claims such as SPF, PA and broad spectrum must all have a test basis (e.g. the corresponding SPF test method).
• It must not be exaggerated: for example, labelling an SPF far higher than the measured value.
• This test basis should be built into the claim substantiation in the PIF (see Cosmetic PIF and Safety Assessment), and be producible during a spot check.

Put simply, every sun-protection figure on the label must be backed by a test behind it. Stating an SPF without a test is a false claim.

Why is sunscreen labelling scrutinised so strictly? Because consumers rely on the SPF figure to decide how long to stay in the sun and whether to reapply; inflating the figure makes people think they are protected when in fact the sunburn risk is higher. This is not just marketing exaggeration — it directly concerns users' health. That is also why the test basis is not "enough that one was done": it must correspond to the actual formula you are selling. Change the formula or the ratio of filters, and the original test may no longer hold, so the SPF may need retesting. A common wishful attitude among brands is "reuse the same SPF report across a range", but as long as there is a substantive difference in formula, that report may not hold up under a spot check.

Sunscreen must not stray into "medicine" territory

Sunscreen is a claim within the scope of cosmetics — "care and prevention" levels such as protecting the skin, preventing tanning and preventing sunburn are acceptable; but once you claim to "treat sunburn or treat skin disease", you cross into the territory of medicinal efficacy claims and can no longer be sold as a cosmetic (for the boundary, see Cosmetic Claims Red Lines). This is where sunscreens most easily cross the line by accident: write the copy too "therapeutically", and the product is reclassified from a cosmetic into a medicinal-claim violation.

Common mistakes

• Using a non-permitted UV filter, or a permitted filter over its concentration limit.
• SPF with no test basis or exaggerated labelling.
• Turning sunscreen into a medical claim (treating sunburn, treating skin disease).
• Using an adult formula for children's / infants' sunscreen, ignoring stricter ingredient and safety requirements.

Pre-market self-check checklist

• [ ] All UV filters are on the ACD Annex VII permitted list.
• [ ] The concentration of every filter is within its limit.
• [ ] SPF / PA / broad-spectrum claims all have a corresponding test basis and are not exaggerated.
• [ ] Test substantiation is built into the PIF.
• [ ] The copy contains no medicinal-efficacy wording such as "treat".
• [ ] Children's / infants' products have been checked for ingredients and warnings under the stricter requirements.

Frequently asked questions (FAQ)

Q: Can I label the SPF myself? It must have a test basis; labelling SPF without a basis is a false claim, and being unable to produce a test during a spot check will be judged a violation.

Q: Are there extra requirements for infant sunscreens? The ingredient and safety requirements for children's / infants' products are stricter, so you must pay particular attention to restricted ingredients and warnings, and cannot simply reuse an adult formula.

Q: Does labelling "broad spectrum" also require testing? Yes. Sun-protection performance claims such as broad spectrum and PA likewise require corresponding test substantiation.

Q: Can a sunscreen say "repairs sunburnt skin"? "Repair / treat sunburn" leans towards an efficacy claim and easily crosses into medicine territory; sunscreen should focus on cosmetic-level claims such as protection and prevention.

Conclusion

The three essentials of sunscreen compliance: permitted UV filters (within concentration) + SPF labelling with a basis + no medicalised claims. Ingredients must be on the list, figures must be backed by testing, and copy must not touch efficacy. Want to check whether your sunscreen labelling is in place? Run a free label check now.

This article is compiled from official NPRA guidelines and is for reference only; actual compliance is subject to the latest official text and review by the competent authority.