Woolworths Kids Sunscreen Complaint Draws National Media Attention as ACCC Assesses Australian Sunscreen Council Referral
- Australian Sunscreen Council
- 15 hours ago
- 5 min read
The Australian Sunscreen Council has welcomed reporting by Inside FMCG and Retail World confirming that the Australian Competition and Consumer Commission is assessing the Council’s complaint about the marketing of Woolworths SPF50+ Kids Roll On Sunscreen.
The complaint was lodged by the Australian Sunscreen Council, Australia’s independent advisory and industry body dedicated to advancing the safety, efficacy and regulatory integrity of sun protection in Australia.
The Council has asked the ACCC to examine whether Woolworths holds adequate evidence to justify marketing the product specifically as “Kids” sunscreen.
The Australian Sunscreen Council has not alleged that Woolworths is failing to comply with current Therapeutic Goods Administration listing requirements.
The Council’s concern is different. It relates to consumer marketing, substantiation and transparency — specifically whether a major supermarket can substantiate the representation that this product is specially suitable for, or directed to, children.
As reported by Retail World, Woolworths responded:
“All sunscreen products in our Woolworths own brand range meet current regulatory requirements set out by the Therapeutic Goods Administration.”
The Australian Sunscreen Council acknowledges Woolworths’ response. The Council’s complaint does not ask the ACCC to determine whether the product is lawfully listed with the TGA. It asks whether the “Kids” representation is properly substantiated under Australian consumer law.
The question ASC has put to the ACCC
The Council’s complaint concerns the difference between Woolworths’ Kids SPF50+ Roll On sunscreen and Woolworths’ ordinary SPF50+ Everyday Lotion.
According to the Council’s review, the children’s product contains 4-Methylbenzylidene Camphor, known as 4-MBC, at 4%, while Woolworths’ ordinary everyday sunscreen does not.
That raises a direct consumer question:
If Woolworths includes 4-MBC in its kids’ sunscreen but leaves it out of its ordinary everyday sunscreen, what evidence does Woolworths hold to justify marketing the 4-MBC product specifically as “Kids” sunscreen?
Australian Sunscreen Council director Joseph Mizikovsky said the issue is not whether a sunscreen is currently permitted to be sold.
“This is about the claim being made to parents,” Mr Mizikovsky said.
“When a product is marketed specifically for children, parents are entitled to know what that claim is based on. If the meaningful difference is that the children’s product contains 4-MBC, then Woolworths should be able to explain why that supports the ‘Kids’ positioning.”
Why 4-MBC is under scrutiny
4-MBC is a legacy UV filter that has been the subject of significant international regulatory concern.
The Australian Sunscreen Council has previously published its analysis of the global regulatory position in The Global Consensus: A Worldwide Rejection of 4-MBC by 78 Nations, which explains that 4-MBC has been banned, restricted, removed or not approved across 78 nations and 31 overseas territories.
The European Union’s Scientific Committee on Consumer Safety has raised direct concerns about the ingredient. In its final opinion on 4-MBC, the SCCS stated:
“There is sufficient evidence that 4-MBC may act as an endocrine disruptor and has effects on both the thyroid and estrogen systems.”
The SCCS also concluded:
“The use of 4-MBC at the maximum concentration of 4% in cosmetic ingredients would not be safe.”
These findings are central to the Council’s public-interest concern. The Council says parents should not have to decode regulatory history, toxicology opinions and overseas bans to understand why a supermarket sunscreen containing 4-MBC is being marketed to children.
Recent peer-reviewed research adds to the concern
The Council says recent peer-reviewed research further supports the need for transparency around 4-MBC in consumer products.
A recent PubMed-indexed study, Environmental pollutants associated with blood glucose levels in healthy individuals, reported that environmental exposure substances including 4-Methylbenzylidene Camphor showed a significant positive correlation with increased blood glucose levels.
The Australian Sunscreen Council says this type of emerging research does not, by itself, determine the regulatory status of a sunscreen ingredient. However, it reinforces why parents should be given clear, evidence-based explanations when a product containing 4-MBC is marketed specifically as “Kids” sunscreen.
The Council says the issue is not simply whether 4-MBC is still permitted under Australia’s current sunscreen rules. The issue is whether major retailers should market products containing 4-MBC to children without being able to clearly justify that positioning.
National media attention
Following reporting by Inside FMCG and Retail World, the Australian Sunscreen Council has received enquiries from major Australian media outlets including Nine News, the Australian Financial Review and the Courier Mail.
The Council says this level of correspondence reflects growing public interest in sunscreen transparency, children’s product claims and whether large retailers can properly substantiate health-related marketing representations made to Australian families.
“This is exactly why the Australian Sunscreen Council exists,” Mr Mizikovsky said.
“Sunscreen is not just another grocery product. It is a public health product. When sunscreens are marketed to children, the evidence behind those claims should be clear, current and capable of withstanding scrutiny.”
A consumer law issue, not a TGA listing allegation
The Australian Sunscreen Council says it is important that the complaint is not misunderstood.
The Council has not alleged that Woolworths’ Kids sunscreen is unlawfully listed with the TGA.
The issue is whether Woolworths’ marketing of the product as “Kids” sunscreen is supported by evidence, particularly when the ingredient that appears to distinguish the children’s sunscreen from the ordinary everyday sunscreen is 4-MBC.
The Council says this is consistent with long-standing Australian consumer law principles: businesses should be able to substantiate claims they make to consumers, especially where those claims imply suitability for a particular group, use or benefit.
The Council has drawn comparison with previous ACCC action involving Nurofen Specific Pain products, where products were marketed for different pain types despite containing the same active ingredient. The Council says the same consumer protection principle is relevant here: a product should not be marketed as specially suited to a particular group unless the supplier holds evidence supporting that representation.
ASC awaiting further update from the ACCC
The ACCC has acknowledged the complaint and advised that it is assessing the matter.
The Australian Sunscreen Council is hoping for an update from the ACCC in the coming months and will continue to provide information to regulators, journalists, policymakers and the public as required.
“The Australian sunscreen sector needs more transparency, not less,” Mr Mizikovsky said.
“Parents deserve to know why a product is being marketed to their children. Major retailers should welcome the opportunity to show the evidence behind those claims.”
The Australian Sunscreen Council will continue to lead public discussion on sunscreen safety, efficacy, labelling and regulatory accountability in Australia.
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