Sunscreen products are not cosmetics like any other. Because of the essential protection they provide against the damaging effects of UV rays on the skin, they can be considered as real health products. Their effectiveness, in addition to their safety, must be guaranteed. Formulation, labelling: the 2006 European Commission Recommendation sets the framework.
In Europe, the reference text for the development and labelling of sunscreen products is the Commission Recommendation of 22 September 2006 on the efficacy of sunscreen products and the claims made relating thereto.
The framework of the Recommendation
The 2006 Recommendation was developed, in the words of the text itself, “in order to contribute to a high level of health protection.” It addresses both “the minimum efficacy of a sunscreen product in order to ensure a high level of protection of public health” and “how the labelling of sunscreen products can be kept simple and comprehensible in order to assist the consumer in choosing the appropriate product.”
It concerns all sun protection products, namely : “any preparation (such as creams, oils, gels, sprays) intended to be placed in contact with the human skin with a view exclusively or mainly to protecting it from UV radiation by absorbing, scattering or reflecting radiation.”
The reference to “exclusively or mainly to protecting […] from UV radiation” excludes from the scope of the text make-up or skincare products with SPF, and therefore only concerns sunscreen products as such.
Minimum efficacy
Sun radiation, explains the text of the Recommendation in its preamble, “consists inter alia …