How Beauty Can Navigate a Testing Confidence Crisis

From SPF scores to claims about everything from wrinkle appearance to hair volume, the results of third-party lab tests are a cornerstone of the modern beauty industry.

Legally required for safety and useful for efficacy-based marketing language, references to results of double-blind tests by independent labs are ubiquitous across skincare, hair care, makeup and more. But as common as it is to see a percentage of lash volume increase or redness reduction in a product listing, the name of the testing lab is almost never revealed. An ongoing Australian sunscreen efficacy scandal, however, is bringing an unprecedented level of scrutiny to the beauty lab-testing process, causing brands to rethink how they approach third-party testing.

On Sep. 29, Australia’s ongoing SPF efficacy crisis grew even larger when the country’s Therapeutic Goods Administration released a list of what is now 21 sunscreens it reports to have the same base formulation as Ultra Violette Lean Screen SPF 50+, which the brand voluntarily recalled in Australia after inconsistent SPF scores. The TGA also announced it is considering “regulatory action” regarding these sunscreens and would investigate Princeton Consumer Research, the testing firm that handled the efficacy tests for “many” of the brands on the list.

Media scrutiny has also grown. In an Oct. 1 Australian Broadcasting Corporation report, two former PCR employees who have since started their own competing firm, along with anonymous employees, spoke about issues they said they saw with testing at the company.

In a statement to The Business of Beauty, a representative of PCR stated that “the claims presented in those articles do not reflect how PCR operates. Our studies are conducted under controlled, documented procedures by trained professionals, and we stand by the integrity of our work.”

Shrouded in Secrecy

Product testing is a typical process for almost all beauty companies. Sunscreens, which are often regulated as drugs, require tests for their safety and efficacy, but formulas in skincare, makeup or nails often carry claims — for their performance or their benefits — that are supported by often-confidential third-party testing labs.

“Clinical labs are the best-kept secret in the industry,” said Brian Ecclefield, one of the whistleblowers and founder of Validated Claim Support, a testing firm he opened in 2018 after leaving a business development role at Princeton Consumer Research.

“People are very protective of their labs, their manufacturers, their testing facilities, because they don’t want competitors to know their secret sauce,” said cosmetic scientist Dr. Julian Sass. According to a cosmetic chemist, “part of it might be the lab requesting that they don’t have their name associated with the brand.” PCR shows up affiliated with only a few brands publicly — it’s cited in a Korean-language listing for a Shiseido foundation, as well as a published study with Amyris.

An effect of brands’ lab partner confidentiality often means no public affiliation if something goes awry. PCR isn’t the first testing lab to face scrutiny. Prior to PCR, Ecclefield was a sales representative at AMA Laboratories, which was previously one of the preeminent product testing firms for major international conglomerates including L’Oréal, Estée Lauder, Unilever and J&J. He said he began to notice irregularities in the testing data, and left AMA for PCR in 2017. In 2022, AMA Laboratories’ owner Gabriel Letizia, Jr. was sentenced to 60 months in prison and the forfeiture of over $46 million after being found guilty of fraud over fabricated test results.

New Scrutiny

The Australian SPF crisis that began this summer has brought an unprecedented level of transparency to the product testing process. After consumer watchdogs found lower-than-labelled SPF values on tests conducted at other labs, brands including Ultra Violette and Naked Sundays voluntarily pulled products from the market in Australia, with Ultra Violette recalling its Lean Screen and Naked Sundays pausing sales of its Collagen Glow sunscreen. Over the summer, more brands chose to recall or pause sales of products in Australia before the TGA published its most recent 21-brand list with products from Mcobeauty, New Day Skin and Ethical Zinc.

The notice also stated that the agency has “significant concerns about the reliability of SPF testing undertaken by Princeton Consumer Research Corp.”

Just two days before the TGA notice came out, Ecclefield, as well as Validated Claim Support director Jane Tervooren, who also formerly worked in business development at PCS, told Australian media that they had left PCR over concerns with the data they witnessed and testing processes.

In a statement to The Business of Beauty, a representative of PCR stated that Ecclefield and Tervooren’s statements are, in PCR’s view, “obviously an attempt to disrupt business for PCR as a competitor in the industry that has always performed better than them.”

PCR is led by reality show “Below Deck” star Barrie Drewitt and his ex-husband Tony Barlow, who previously launched a surrogacy service and are known as the first same-sex couple in the UK legally recognised as parents through surrogacy. The lab has many major multinational beauty brand clients that rely on its tests.

Currently, all but one of the sunscreens on the TGA list have either been voluntarily recalled or paused by the brands in Australia. The TGA also inspected Wild Child Laboratories, the manufacturer of the base formulation, and “did not identify any manufacturing issues.” Wild Child has stated it will no longer test with PCR.

An Ultra Violette representative said in a statement to The Business of Beauty that it is “ceased working with PCR earlier this year and is testing their products with a wide network of ISO-accredited [International Organization for Standardization] testing facilities around the world. They have since retested the entire Ultra Violette range at multiple independent labs and have consistently found SPF results of over 50.” It is also “engaging independent experts to vet their SPF reports.” Ultra Violette has publicly stated that going forward, it will test with a minimum of two different labs, with repeat testing every 18 months.

Naked Sundays, meanwhile, previously announced that it was working with the TGA on reforms to testing requirements as a member of the TGA’s consumer health advisory group. People4Ocean released a statement on its site that it has “established a new and wider network of testing partners that are independently vetted” and is “no longer working with the original testing laboratory.” Mcobeauty announced on its site that it is “conducting a thorough review of all relationships with manufacturing partners.”

Relying on multiple tests, as well as vetting testing facilities should become the norm rather than the exception for brands, recommended Sass. To analyse results that come in, brands should hire experts to analyse them.

Numbers on product tests can often have wide variation and outliers, and brands should have staff on hand to point out when results look too “perfect.” Right now, the issue is that many do not.

“The vast majority of brands do not have technical experts on staff, and the ones that do, it’s normally just a chemist,” said Sass. “When it comes to testing, that’s a whole other area of expertise, to be able to look at the data, know what the variability should be, and think, ‘numbers look too nice; this doesn’t look feasible to me.’”

The results of South Korea’s SPF testing crisis in 2020 may be a bellwether for the transparency that can be expected in the future. Many K-beauty brands now publish exact lab names and test results on their sites.

“In Korea specifically, everyone sort of knows who the labs are,” said a cosmetic chemist.

Beauty of Joseon’s sunscreen product listings, for example, cite exact SPF value findings for labs in Spain and Korea, as well as a separate waterproof test, naming the labs and study titles in full.

Experts predict that for brands outside Korea, it’s still unlikely that this situation will unleash a wave of releasing lab names with results. But brands may take more action internally.

“We’re going to have some more consultants to be able to vet all these numbers, to make sure that what they expect is what they’re getting,” said Sass.

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