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A significant shift across the Tasman
The New Zealand Government has confirmed that sunscreens will be regulated under the Medical Products Bill as "boundary products", and that the Sunscreen (Product Safety Standard) regime will be repealed once regulatory responsibility transfers. The Bill is not expected to be introduced to Parliament until 2027, so this is a change to plan for rather than react to — but its implications are worth understanding early.
For any brand supplying sunscreens into both Australia and New Zealand, this is the most consequential development in NZ sunscreen regulation in years.
Why "boundary products" matters
The term is doing a lot of work. A boundary product sits at the edge between categories — in this case, between a cosmetic and a therapeutic/medical product. How New Zealand chooses to implement that mechanism in regulations will determine what sponsors actually have to do: what evidence is required, what testing is accepted, what the labelling obligations are, and whether any pre-market step applies.
At this stage, those details aren't settled. The framework has been announced; the regulations that give it practical effect have not.
The question trans-Tasman brands will be asking
The obvious commercial question is this: will a sunscreen that meets Australian TGA requirements automatically satisfy New Zealand's new regime?
Right now, the honest answer is that nobody knows. New Zealand's approach appears likely to diverge from Australia's current framework, and whether the two align in practice will depend entirely on how the boundary products mechanism is implemented.
That uncertainty matters because the two markets have historically been managed together by many brands — a single formulation, a single testing package, closely related artwork. If the regimes diverge, that efficiency is at risk, and dual-market compliance could mean genuinely separate work streams.
Add the Australian picture and the timing gets interesting
This lands alongside Australia's own transition to AS/NZS 2604:2021, where existing ARTG-listed sunscreens face testing deadlines later this decade. So brands with SPF products across both markets are facing:
- An Australian testing transition already underway
- A New Zealand regime being rebuilt on a different legislative footing
- A window in which decisions made for one market may or may not serve the other
Making testing and reformulation decisions without a view of both is how brands end up paying twice.
What to do now
- Map your NZ-supplied sunscreen range — know exactly which products are exposed to the change.
- Don't lock in long-term testing or artwork strategy on the assumption that TGA compliance will carry across.
- Watch for the draft regulations, which is where the practical requirements will appear — the Bill itself won't answer the operational questions.
- Plan Australian and New Zealand work together, not sequentially.
How Engel Hellyer & Partners can help
Sunscreen regulation is one of our deepest specialisms — including the Australian standards work that underpins it — and we advise across both Australian and New Zealand requirements. As New Zealand's framework takes shape, we can help you assess which products are affected, avoid decisions that only work for one market, and sequence any testing or labelling changes sensibly across both.
If you supply sunscreens on both sides of the Tasman and want to get ahead of this, we're happy to take a look.
This article is general information only and does not constitute regulatory advice for any specific product. The New Zealand framework is still developing; confirm the current position before acting.
Further reading
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