Launching an SPF product introduces some considerations that brands may not encounter with a standard cosmetic product.
Before committing to a launch, brands need to understand the type of SPF product they want to create, the regulatory pathway that may apply, the claims they want to make and what will be involved in formulation, testing and commercial manufacturing.
Making these decisions early can give both the brand and manufacturing team a clearer direction for development.
This guide covers the key questions worth considering before starting an SPF project in Australia.
What Do Brands Need Before Launching Sunscreen?
A good SPF project starts with a clear brief and an understanding of what the brand wants to bring to market.
Before development begins, it helps to agree on the key commercial and product requirements so the formulation team has a clear starting point.
Brands should consider:
- The type of SPF product
- Target SPF
- Intended use and audience
- Desired texture and finish
- Intended claims
- Packaging direction
- Target cost
- Expected order volumes
- Intended launch timing
Not every detail needs to be finalised before speaking with a manufacturer. In fact, involving the formulation and manufacturing team early can help determine which parts of the original concept are practical and which may need further discussion.
How Are SPF Products Regulated in Australia?
In Australia, the regulatory pathway depends on the type of sunscreen, its intended purpose and how it is presented to consumers.
Primary sunscreens (products represented primarily as providing protection from UV radiation) are regulated by the Therapeutic Goods Administration (TGA) as therapeutic goods.
Some secondary sunscreen products are also regulated as therapeutic goods, while certain secondary sunscreens are excluded from therapeutic-goods legislation.
For a brand, understanding the likely pathway early is important because it can influence areas such as:
- Formulation
- Ingredients
- Testing
- Claims
- Labelling
- Manufacturing requirements
Brands should confirm the requirements that apply to their specific product rather than assuming all SPF products follow the same pathway.
Do All SPF Products Follow the Same Regulatory Pathway?
No. The regulatory pathway depends on how the product is intended to be used and marketed.
In Australia, primary sunscreens are regulated as therapeutic goods. Some secondary sunscreens are also regulated by the TGA, while certain secondary sunscreen products are excluded from therapeutic-goods legislation.
For example, the regulatory considerations for a product whose primary purpose is sun protection may differ from those for a cosmetic product that provides a secondary sunscreen benefit.
This is why brands should establish the intended use, SPF and claims early in development and confirm which requirements apply to the individual product.
What Testing Is Needed Before Selling Sunscreen?
The testing required will depend on the product, regulatory pathway and claims being made.
For SPF products, this may include testing to support the intended SPF and, where relevant, broad-spectrum or water-resistance claims.
Product development may also involve stability testing and, where relevant:
- Bacterial, yeast and mould testing
- Preservative efficacy testing
The appropriate testing pathway should be determined for the individual product rather than assuming every SPF product requires the same program.
Testing should also be allowed for in the development timeline, as results may identify that further formulation work is required.
The TGA specifically requires therapeutic sunscreen sponsors to hold evidence supporting their product and applicable claims.
Why Does SPF Need Its Own Development Process?
An SPF product needs to be developed with its intended protection, use and regulatory requirements in mind from the beginning.
The formulation team is not only considering how the product feels on the skin. They also need to work towards the intended SPF and other relevant product requirements while developing a formula that can progress through testing and commercial manufacturing.
For the brand, this can mean making trade-offs during development. A particular texture, finish, ingredient preference, claim or price point may need to be reconsidered as the formulation progresses.
This is why adding SPF to a range should be treated as its own product development project rather than simply adapting an existing skincare formula.
How Can Brands Differentiate an SPF Range?
Before developing an SPF product, brands should be clear on the role it will play within their range.
Differentiation does not necessarily need to come from adding more claims or ingredients. It may come from who the product is designed for, how it feels, when it is used or how it fits into the wider brand.
Brands might consider:
- Who the product is for
- Whether it is designed for face, body or a particular use
- Desired texture and finish
- Tinted or untinted formats
- How it fits into an existing skincare routine
- Price and retail positioning
- Packaging and overall brand experience
The key is to give the product a clear reason to exist while allowing the formulation team enough flexibility to develop it appropriately.
What Claims Should SPF Brands Be Careful With?
Claims should be considered early because they can affect both the product development and regulatory pathway.
For SPF products, particular care should be taken with claims relating to areas such as:
- SPF and UV protection
- Water resistance
- Duration of protection
- Intended users
- Product performance
- Therapeutic benefits
Brands should also avoid finalising packaging or campaign language before understanding what evidence may be required to support the claims being made.
Claims used across packaging, websites, advertising and retailer materials should accurately reflect the finished product and the evidence held to support it.
What Should Brands Plan for Before Manufacturing?
An approved formulation is not the final step before launch. Brands also need to plan for commercial production.
This can include:
- Raw material availability
- Packaging supply
- Order quantities
- Manufacturing lead times
- Filling requirements
- Production scheduling
- Finished goods and freight planning
These considerations become particularly important when a brand is working towards retailer deadlines or coordinating a product launch across marketing, warehousing and distribution.
Discussing commercial requirements with the manufacturer early gives the brand a more realistic view of what needs to happen before production can begin.
How Long Does an SPF Product Launch Take?
There is no single timeline for developing and launching an SPF product.
Timing can depend on:
- The formulation
- Regulatory pathway
- Required testing
- Packaging
- Availability of raw materials and components
- Manufacturing requirements
- Whether further development or testing is needed
For brands working towards a particular launch or retail date, these stages should be factored into planning before committing to campaign or stock deadlines.
It is also sensible to allow some flexibility in the timeline rather than assuming the first formulation or testing round will be the final one.
SPF Range Launch Checklist
A strong SPF launch plan should cover compliance, formulation, manufacturing, packaging and commercial readiness before production begins.
Before progressing with an SPF range, ask:
- Have we clearly defined the product?
- Do we understand the likely regulatory pathway?
- Are our intended claims clear?
- Have we allowed for the required testing?
- Have we involved our manufacturer early enough?
- Is our packaging direction suitable for the product?
- Is our target cost realistic?
- Have we considered production volumes and lead times?
- Is our launch timeline flexible enough to accommodate development?
- Does the product have a clear role within our range?
You don’t need to have every answer before approaching a manufacturer. These questions are intended to help identify what has been decided and where further guidance may be needed.
Decisions Worth Making Early
Some decisions become much harder or more expensive to change later in development.
Before committing to packaging, artwork or launch dates, it is useful to have clarity around:
- The intended product and claims
- The regulatory pathway
- What testing may be required
- Packaging direction
- Target cost and order volumes
- Manufacturing requirements
- A realistic development timeline
Not all of these decisions need to be made by the brand alone. An experienced formulation and manufacturing partner can help identify what needs to be decided early and what can remain flexible as the product develops.
How Delta Supports SPF Range Development
Delta works with skincare and personal care brands across SPF formulation development and commercial manufacturing.
Delta operates TGA-licensed manufacturing facilities in Australia, supporting the manufacture of sunscreen and SPF products within regulated manufacturing environments.
Depending on the project, Delta can support brands through formulation development and refinement, stability testing, planning for required SPF testing, manufacturing scale-up and commercial production.
Working with the manufacturing team early also means commercial considerations such as production volumes, packaging, timelines and future scale can be discussed while the product is still being developed.
FAQs About Launching an SPF Range
What Do Brands Need Before Launching Sunscreen?
A useful starting point is a clear product brief covering the type of SPF product, intended claims, desired product experience, packaging direction, commercial requirements and launch goals. The regulatory and testing pathway can then be determined as the project develops.
How Are SPF Products Regulated in Australia?
Primary sunscreens and some secondary sunscreens are regulated by the TGA as therapeutic goods. Certain secondary sunscreen products are excluded from therapeutic-goods legislation. The pathway depends on the individual product, its intended use and how it is presented.
What Testing Is Needed Before Selling Sunscreen?
Testing depends on the product and claims. It may include testing to support SPF, broad-spectrum or water-resistance claims where relevant, alongside stability and other product testing appropriate to the formulation.
Can an Existing Skincare Brand Add SPF to Its Range?
Yes. An existing skincare brand can develop an SPF product, but it should be treated as its own development project. The regulatory pathway, formulation, testing, claims and manufacturing requirements need to be considered for the individual product.
Why should brands allow flexibility in an SPF development timeline?
SPF development can involve formulation refinement, testing, regulatory requirements, packaging and manufacturing stages. If further formulation work or testing is needed, the original timeline may need to change.
What Should Brands Ask an SPF Manufacturer?
Ask about their experience with SPF products, formulation capabilities, manufacturing licences and quality systems, how required testing is coordinated, commercial production capability and when they recommend involving packaging.
Planning an SPF Range?
Launching an SPF product involves decisions across formulation, regulation, testing, packaging and commercial manufacturing.
Understanding these requirements early can help brands develop a clearer brief and make more informed decisions before committing to packaging, claims or launch timing.
Delta works with skincare and personal care brands across SPF formulation development and commercial manufacturing in Australia.
Planning an SPF product?
Speak to Delta about your product brief and the next steps towards commercial manufacturing.
