A comment on the 2024 EWG Sunscreen Guide; Is EWG actively harming safe consumer sun protection?
EWG recently put out their 2024 Sunscreen Guide. Just in time to scare consumers about their sunscreen choices for the summer. Should you as a consumer be worried? Does the EWG actually want to make sun protection in the USA safer? Or are they putting these guides out as a fear marketing campaign to promote the EWG seal program (which makes them money)? My pessimistic viewpoint; I think it’s the latter.
Sun protection from sunscreen hinges on people wearing enough, regularly, and that hinges on whether they actually like the products they’re using. What these guides are effectively doing is hurting the credibility of sunscreen and reinforcing the idea that these products are confusing, unapproachable, and scary. All while positioning themselves as bastions of moral superiority in the cosmetics sector. The end result? Consumers will be more likely, out of fear, to reach for products they either don’t enjoy as much, which will result in them being less likely to apply enough, or they’ll just avoid sunscreen products altogether.
The criteria set out by the EWG Sunscreen Guide recommendations are essentially limited to expensive mineral sunscreens. Lower income individuals will have a hard time accessing these products, and may be more likely to use less to prolong the time before their next purchase. The other side of this coin, however, is the high likelihood for many consumers to not like the products they are left with. Mineral sunscreen filters (Titanium dioxide and zinc oxide) inherently contribute to whitecast. For people with darker skin, particularly when applying appropriate amounts of sunscreen to get the desired SPF, the esthetics will be unacceptable. Often consumers will just use less product to contend with this, but that means they may not get the SPF they’re after. To further my point here, in a recent AAD poster presentation (Shyr et al., 2023), when consumers had the option between “mineral” and “chemical” sunscreens, when blinded, overwhelmingly they preferred the “chemical” sunscreen. The safest sunscreen for any individual is the one that they enjoy the most, because, as I keep repeating here, they’ll be more likely to wear enough of it, regularly.
Here’s a video of Esther Olu demonstrating the inherent white caste issues of mineral sunscreen.
The sun protection benefits of sunscreen (e.g. prevention of skin cancer, UV induced hyperpigmentation, painful sunburn, melasma, etc) far outweigh any potential risks.Sunscreens have a long track record of safety and still, despite some of the scary media reporting on the recent FDA studies, are overwhelmingly supported to be safe and effective. It’s true that in the USA, the UV filter options are limited and the FDA approval process for new filters is pretty draconian. But these EWG narratives aren't going to help get new ingredients approved. They really are just limiting consumer options IMO.
Okay, so what specifically is wrong with the 2024 EWG Sunscreen Guide? Here’s a short and by no means exhaustive list. But hopefully it gives you the gist of why it’s unreliable and why I’ve come to the conclusion that these guides are part of a greater marketing campaign by the EWG. There’s big money to be gained when you sufficiently scare the general public and legislators (who generally aren’t scientists). The EWG also raises money through personal and organizational donations, with messages like “help us make your family safer”.
You’re just going to have to trust the EWG is right on many of their assertions. For example, with their claims about ingredient stability where they comment that there are projected efficacy losses of 50/25/0%. How did they land there? This is troubling to me because sunscreen is a complicated space with many moving parts. Also, if they’re using this report to promote their seal program to companies, I think we need a bit more than a “just trust us”? It strikes me that the EWG is trying to scare consumers about their sunscreens so they can effectively hold the cosmetics industry hostage.
SPF testing results relevance? The EWG has a lot to say about how the FDA SPF testing methods are unreliable, but it’s really hard to rationalize their results and methods as reliable. SPF values on USA based products use SPF testing methods that are required by the FDA (so companies can’t just go out and make up a testing method to prove their SPF values, like EWG did here). So the EWG goes and uses different methods and sees that there is a difference in SPF values. Is this meaningful? It’s extremely difficult to know. Generally when you try to replicate results in studies, you use the same methods - Hopefully this is obvious, but different methods are likely to get different results. The EWG logic seems to be; we showed different results, therefore FDA methods are unreliable, and ours are more reliable. But why? Just because you get different results using different methods doesn’t mean those methods are better. Does this make sense to anyone?
Their comments to caution about SPFs higher than 50 is questionable. Especially in light of the recent FDA (2021) proposed SPF cap raise from 50 to SPF 60, which they even cite in the report. But selectively. They fail to mention the reasoning behind it. The FDA made this recommendation because of their review of the clinical data for higher SPF products. In this review, the FDA found that an increase from SPF 50 to 60 resulted in a greater benefit to consumers in terms of sun protection without an increase in risk. I guess this wouldn’t fit in the EWG narrative so they conveniently left it out? There’s a word for what they did there. It’s cherry picking data (which is a hallmark of pseudoscience).
The EWG stance for new SPF filters is confusing. On one hand, the EWG says that oxybenzone is a “specific ingredient of concern” and therefore doesn’t make their list of acceptable UV filters - which disclaimer, with the limited filters available in the USA, will essentially limit consumer choice to mineral filters. But then they go on to say “In 2019, our public comment letter to the FDA suggested the agency consider allowing the four promising sunscreen ingredients in the U.S. market while tests are still being conducted. The current data suggest these ingredients are as safe – if not more so – as those chemicals, like oxybenzone, that have been on the market for many years.” Er, what? So now we’re okay with less safety data over an ingredient that has more safety data? “These ingredients are as safe as oxybenzone” (an ingredient they say isn’t safe) - Wouldn’t this mean that, if the filters that the EWG is recommending were on the market, that they still wouldn’t recommend them?
So the 2024 EWG Sunscreen Guide; Is EWG actively harming safe consumer sun protection? I personally think so.
I was assisted with this commentary by an anonymous sunscreen researcher. Thank you so much for helping me on this!
References:
EWG. (2024). Sunscreen Guide.
FDA. (2021). Final Administrative Order, OTC Monograph: Sunscreen Drug Products for Over-the-Counter Human Use (Posted Sept 24, 2021)
FDA. (2012). Labeling and Effectiveness Testing: Sunscreen Drug Products for Over-the-Counter Human Use - Small Entity Compliance Guide.
Li, H., Colantonio, S., Dawson, A., Lin, X., & Beecker, J. (2019). Sunscreen application, safety, and sun protection: the evidence. Journal of cutaneous medicine and surgery, 23(4), 357-369.
Shyr, T., Sea, I., Benn, M., Vair, L., Lopez, D., Adenaike, G., Teh, S., & Williams., J. (2024). Exploring mineral sunscreens across diverse skin tones: a contemporaneous evaluation of likeability, usability, and efficacy. AAD research poster presentation.