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Why Korean Sunscreens Can’t Be Sold In Australia

February 07, 2025

Why Korean Sunscreens can't be sold in Australia

Australian sunscreen regulation explained

Why Korean Sunscreens Can’t Be Sold in Australia

The cosmetic “loophole” does not apply to products whose primary purpose is UV protection. Here is what Australian consumers, retailers and beauty brands need to understand.

Every few months, confusion spreads online about why Korean and other Asian sunscreens cannot simply be imported and sold in Australia. Some people claim smaller retailers can rely on a cosmetic sunscreen loophole, or avoid the rules by removing SPF claims.

The short answer is that there is no general loophole. If a product is primarily intended to protect the skin from UV radiation, Australia treats it as a "therapeutic good". As such, it must meet the applicable Therapeutic Goods Administration requirements and be included in the Australian Register of Therapeutic Goods (ARTG) before being supplied or marketed to Australians.

Why Korean Sunscreens Are So Popular

Korean sunscreens are loved for their elegant textures, modern UV filters and weightless finishes under makeup. They are widely discussed and purchased online, but many of the viral formulas are absent from legitimate Australian retail.

You may still see them in smaller stores or on online marketplaces. Their visibility does not mean they have been approved for lawful supply in Australia. There's a pretty quick and easy way to tell too: 1) is the product listed on the ARTG and 2) does it have an AUST-L number printed on it. 

What Counts as a Sunscreen?

Sunscreens protect the skin by absorbing, reflecting or scattering UV radiation. Because Australia has exceptionally high UV exposure, sunscreen is regulated as a public-health product rather than an ordinary cosmetic.

The TGA regulates matters including formulation, permitted ingredients, manufacture, testing, labelling, advertising and supply. Products represented primarily as providing UV protection generally fall within the therapeutic-goods framework.

How Sunscreens Are Regulated in Australia

A product primarily used to protect the skin from UV radiation and carrying SPF claims is generally regulated as a therapeutic sunscreen. This can also capture moisturisers with higher SPF claims.

Some products can be excluded from therapeutic-goods regulation under the Excluded Goods Determination. Examples may include certain tinted make-up products or low-SPF moisturisers where UV protection is secondary to the product’s cosmetic purpose and all relevant conditions are met.

However, if UV protection is the product’s primary purpose, changing the product description or avoiding a particular word (i.e sun cream vs sunscreen etc) does not magically transform it into a cosmetic.

The “Cosmetic Sunscreen” Myth

Let's get one thing out of the way: the cosmetic exclusion is narrow. Depending on the product category, relevant considerations include whether:

  • The product’s main purpose is cosmetic rather than UV protection (i.e. a foundation); 
  • The SPF remains within the limit applicable to that excluded category; 
  • The product is presented and promoted consistently with its cosmetic purpose; 
  • Its ingredients and claims satisfy all other applicable requirements

The Korean sunscreens trending on social media are ordinarily marketed as primary sunscreens and commonly carry SPF 50+ and PA claims. Removing SPF language from a retailer’s listing does not change the product’s inherent purpose, presentation or overseas labelling. If it is a therapeutic good, it must follow the Australian regulatory pathway.

What Australian Sunscreen Compliance Involves

Depending on the product and pathway, an Australian sunscreen may need to:

  • Be manufactured in a TGA-licensed facility or one with appropriate TGA-recognised GMP clearance
  • Use UV filters and other ingredients permitted for the intended product
  • Hold appropriate SPF, broad-spectrum, stability and, where claimed, water-resistance evidence
  • Meet applicable requirements under AS/NZS 2604:2021
  • Comply with Australian labelling, advertising and sponsor obligations
  • Be included in the ARTG before supply, unless a specific exclusion or exemption applies

For an SPF 50+ claim, the tested result must meet the threshold required by the Australian Standard. Broad-spectrum performance is also assessed under Australian requirements; the Korean PA rating system is not a substitute for the Australian pathway.

Why Korean Sunscreens Are Not Approved Here

Australian market entry requires far more than importing a finished Korean formula. A brand may need an Australian sponsor, suitable manufacturing evidence, compliant ingredients, local-standard testing, supporting technical documentation and an ARTG listing.

Some Korean and European formulas use UV filters or combinations that may not be available for the intended use in Australia. Even where each active ingredient is permitted, the finished product still requires its own evidence and regulatory pathway. This can involve substantial time, specialist input and investment.

Examples of UV Filters Used in Australia

The current Therapeutic Goods (Permissible Ingredients) Determination contains the ingredients that may be used in listed medicines, subject to their individual conditions. Sunscreen actives commonly encountered in Australia include:

  • Bemotrizinol
  • Diethylamino Hydroxybenzoyl Hexyl Benzoate
  • Butyl Methoxydibenzoylmethane
  • Octocrylene
  • Ethylhexyl Triazone
  • Titanium Dioxide
  • Zinc Oxide
  • Homosalate
  • Phenylbenzimidazole Sulfonic Acid
  • Tris-Biphenyl Triazine

Permission to use an individual active does not amount to approval of a finished sunscreen. Concentration limits, ingredient conditions, testing, manufacture, evidence and the product’s ARTG status must all be considered.

Korean Testing and Everyday Use

Many Korean sunscreens are designed around comfortable daily wear: light textures, easy layering and an elegant finish. Water resistance is not a priority as Koreans spend very little time in the surf comparative to Australians.

Similarly, Korea is a market in which sun parasols, large hats, UV face masks and other forms of sun protection (i.e. stick-on sun patches covering the face) are widely used. 

This differs from both Australia’s standards and Australian consumer's expectations, which both account for the way Australians use sunscreen. In contrast to Koreans, many of whom purposely avoid the sun, many Australians find themselves outside during periods of intense UV exposure, sport, swimming and prolonged outdoor use. This does not  mean that every Korean sunscreen is ineffective but overseas test results and claims can't automatically be substituted for the evidence Australia requires. 

Why Major Australian Retailers Do Not Stock the Viral Formulas

Major Australian retailers already stock extensive Korean skincare ranges. If popular Korean sunscreens could be supplied through a simple cosmetic workaround, they would be an obvious commercial opportunity.

The barrier is regulatory.

Supplying or advertising an unapproved therapeutic good can breach Australian law and expose the supplier to enforcement action. Consumers can check a product’s status through the Australian Register of Therapeutic Goods.

What Consumers Should Do

For reliable daily protection in Australia, choose a sunscreen included in the ARTG and follow its application and reapplication instructions. A product’s popularity overseas, its PA rating or its availability through a marketplace is not evidence that it has completed the Australian process.

For more on the Korean sunscreen testing controversy involving several well-known brands, listen to The Korean Beauty Show Podcast, Episode 54.

For beauty founders and international brands

Developing in Korea or considering the Australian market?

Before committing to formulation, production or launch, STYLE STORY can help you understand the commercial and manufacturing realities of your project and identify the specialist support you may need.

  • Assess whether your manufacturing plan is commercially realistic
  • Identify likely formulation, testing and claims considerations
  • Navigate Korean manufacturers, MOQs and development timelines
  • Avoid preventable mistakes before sampling or production
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"Sunscreen is the number one anti-aging product you can use"

- Dr Davin Lim

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