MEDIA STATEMENT: Scientific Invalidity of ABC Testing Claims & VeganicSKN’s Response
- Joseph Mizikovsky
- 1d
- 5 min read
Date: 4 December 2025
From: Joseph Mizikovsky, CEO, VeganicSKN
For Immediate Release
VeganicSKN has been made aware that the ABC (Australian Broadcasting Corporation) has circulated invalid and misleading testing regarding the SPF rating of our mineral sunscreen (AUST L 407959). We categorically reject these claims.
The results cited by the ABC are scientifically invalid, non-compliant with mandatory ISO 24444 standards, and—critically—were produced by a testing method structurally incapable of detecting SPF 50 by design. Furthermore, the laboratory in question has confirmed to us directly that their method did not meet the requirements of the ISO 24444 standard.
ABC decided to publish this story following our sustained advocacy to the TGA to ban 4-Methylbenzylidene Camphor (4-MBC)—a chemical hormone disruptor still permitted in Australia despite being banned in 28 countries including the EU, USA, and Japan—and our support for proposed restrictions on Homosalate and Oxybenzone.
1. The Laboratory Confirmed the Test Was Not ISO 24444 Compliant
In correspondence with VeganicSKN, the Manager of Eurofins Dermatest, Craig Dennyson,—the lab used for the ABC’s claims—confirmed that the preliminary test did not comply with ISO 24444.
Specifically, the laboratory confirmed they were unable to verify:
That the mandatory application rate of 2.0 mg/cm² was actually applied.
That finger-cots were weighed before and after application (a mandatory ISO step).
That the sunscreen film was uniform across the skin.
Instead, the lab performed only a "visual inspection." This is scientifically impossible for Zinc Oxide films, which are ~10 micrometers thick (1/10th the width of a human hair) and invisible to the naked eye. Without valid verification of film uniformity, the test is null and void.
2. Major Methodological Inconsistency: A 33% Variance
The unreliability of the ABC’s data is proven by the laboratory’s own internal variance. For the exact same formulation, Eurofins Dermatest reported:
SPF 18 in one preliminary run.
SPF 25 in another preliminary run.
This represents a 33% internal variance, which is far outside normal repeatability ranges. This indicates uncontrolled application variability and a method unable to produce reproducible results for zinc-only formulations. If the lab cannot replicate its own results, the data cannot be trusted.
3. Structural Flaws: The Test Was Designed to Fail
Beyond the sample size, the testing methodology contained fatal technical breaches that warrant automatic rejection under ISO 24444:2019:
Use of Incorrect Reference Standard (P2 vs P8): ISO 24444 requires the use of the P8 reference standard to validate high-SPF (SPF 50+) tests. The laboratory admitted to using the P2 standard, which is calibrated for low-SPF verification. By using the wrong standard, the test was structurally incapable of validating SPF 50.
Automatic Test Failure: The laboratory results showed the P2 reference standard was "out of range." ISO Section 8.2.2 explicitly states: "If the mean SPF of the reference standard does not fall within acceptance limits… the entire test shall be rejected." The lab should have discarded these results immediately.
Anchoring Bias: The lab set the "Nominated SPF" to 25. This artificially capped the UV dose ladder, making it mathematically impossible for the test to record an SPF 50 result, regardless of the product's actual efficacy.
4. Contravention of TGA Regulatory Guidelines
The ABC has attempted to claim that SPF 50 could "not be reached" based on small-sample screening tests (n=3 and n=5). This directly contradicts explicit TGA guidance on how SPF claims must be assessed.
According to the Australian Regulatory Guidelines for Sunscreens:
"It would be necessary to retest the product several times and obtain consistently low mean results before any conclusion could be drawn about the labelled SPF being unjustified."
The ABC relied on a 3-person test and a 5-person test. Under TGA rules, these sample sizes have no regulatory standing and cannot be used to question a compliant SPF label. ISO 24444 explicitly requires 10 valid subjects to generate a statistically valid SPF.
5. The Real Science: Validated SPF 54.3
While the ABC relies on flawed data, VeganicSKN have attached our full, independent, 10-person ISO 24444 in vivo test report conducted by Sunscreen Safety Testing Laboratory (SSTL) in May 2025.
Method: Strict adherence to ISO 24444:2020.
Sample Size: 10 Valid Subjects.
Result: Mean SPF of 54.3.
6. Clarification on "Regulatory Breaches"
The ABC has referenced TGA compliance documents to suggest VeganicSKN is in breach of regulations. It is vital to clarify that the TGA documents in question (Item 4.4, ComTech 11) relate to "Promotional Listed Sunscreens"—specifically, the practice of third parties (such as clinics or corporate events) placing their own logos on sunscreen bottles after product has been by the licensed manufacturer. Any reference to a "breach" in this context relates to unauthorised third-party labelling.
7. The Real Public Health Issue: Why We Cite the Science
Finally, the ABC raised an issue with our advertising where we simply refer to published scientific literature and independent consumer safety rating databases like The Yuka App.
We find it extraordinary that the national broadcaster is critical of a company sharing safety data, while the broadcaster itself effectively protects the market position of chemical sunscreens containing ingredients currently being reclassified by the TGA due to toxicity concerns. We believe the ABC’s resources should be directed toward investigating why Australians are still using chemicals like 4-MBC—which is banned in the majority of developed nations—rather than attacking the mineral alternatives replacing them.
We cite the science because the regulatory history of these chemicals is alarming. Internal TGA documents regarding the Draft Safety Review (Document 2 AR FOI 0104) explicitly state:
On Homosalate: “There are immediate systemic safety concerns with the use of this ingredient in sunscreens at 15% based on available information"
On Oxybenzone: “The potential photoallergic effects of oxybenzone at 10% concentration cannot be ruled out"
These findings indicate systemic safety concerns at currently permitted concentrations and confirm that core toxicological data were never independently reviewed—in direct contrast to the industry claim of “decades of safe use.”
The Risk to Children
Most alarmingly, the TGA’s draft review admits a total lack of safety data for children:
“No nonclinical information was available for the safety of these ingredients in the paediatric population… [children] may absorb a greater fraction of topically applied ingredients… putting them at risk of higher systemic levels and consequently, side effects and toxicities not seen in adults.”
VeganicSKN remains fully compliant with ARTG and AUST L obligations. We will not be intimidated by misleading reports derived from "designed-to-fail" testing. We stand by our rigorous 10-person clinical data, and we will continue our fight to remove unsafe legacy chemicals from the Australian sunscreen market.
Joseph Mizikovsky
CEO, VeganicSKN
Member, Standards Australia's CS-042 Sunscreen Agents Committee
Joseph Mizikovsky is a member of Standards Australia’s CS-042 Sunscreen Agents committee, the national, not-for-profit standards body that has been developing Australian standards for over 100 years since its establishment in 1922.
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