TGA sunscreen recalls: protecting your skincare brand when contract manufacturing.

The recent wave of sunscreen recalls in Australia, all tied back to the same manufacturer, has sparked plenty of conversation across the beauty industry. For professional brands—especially those in their early years of trading—it raises an important reminder: manufacturing skincare isn’t a “set and forget” process.

The notorious base formulation

I have seen some confusion around the use of a base formulation so to clear that up; base or chassis formulations—are widely used in the industry to have speed to market advantage. Its a vary standard practice. Can changing a base ultimately change the SPF outcome? Not likely because sunscreens are built around calculated inputs of sunscreen filters giving us SPF units that remain unchanged in the formulation. These units are lipid soluble and form the core of the product. Even if some extracts or actives are updated or substituted, the calculated SPF units don’t change. This base formulation sold on to brands would've had appropriate testing on the theoretical SPF units rendering a SPF 50. But here’s where it becomes critical: the responsibility for retesting and ensuring compliance always falls back on the brand. At the end of the day, it will be the brand reputation that suffers.

So where did it all go so wrong?

After the initial review, the manufacturer has done it's due diligence and re tested their base. It was discovered that the base itself fell short under investigation. From here, I'd be looking to in house quality control. Did raw material suppliers change? Were there machinery updates or scaling adjustments that introduced inconsistencies? If a manufacturer’s processes are rendering stable results, then attention turns to testing facilities. And if test results appeared satisfactory at the time, yet were later found lacking, which is what we know now. How could the manufacturer—or the brands relying on them—have known? In cases like this, no one wins.

Where to next?

The TGA has already moved to strengthen requirements in response, and it’s likely more changes are on the horizon. For brand owners, the lesson is clear: launching a skincare product is never a one-time exercise. Each time you change scale, packaging, raw material suppliers, or manufacturing methods your product will inevitably shift in small ways. Without consistent checks, validation, and thorough operating procedures, those small shifts can snowball into costly problems.

Final words of wisdom

This recall is a timely reminder that your brand’s reputation rests not just on your formulations, but on the systems behind them. A proactive approach to quality assurance is what shields businesses from the kind of headaches we’re seeing play out now. And if you're unsure where to go, I'd love to be there to help you navigate that process. Let's Chat

-The Clinics Formulator