Japanese sunscreens have a strong reputation abroad, and many brands arrive with a single line in the brief: “SPF50+ PA++++, light, no white cast”. That line hides most of the work. The UV filters have to be on Japan’s positive list and acceptable in every market you sell in, the SPF and PA numbers have to be measured on the final formula, and the way they appear on the label follows an industry standard rather than a law. This guide sets out the order in which those decisions are made, so the number on your box is one the test supports.
💬 Sunsho Trade manages Japan-made own-brand cosmetics projects in English, sunscreens included. Send us your target SPF, PA, format and markets and we will tell you what the factory needs to quote.
Decide five things before the factory quotes
Before a Japanese factory can quote a sunscreen, it needs your target SPF and PA, the format, whether you want a water-resistance claim, every market you will sell in, and any filters you want to avoid.
A sunscreen is designed backwards from its claims. The filters, their combination and the base all depend on the protection level, and the testing plan depends on where the product will be sold. These are the inputs that matter:
| Decision | Why the factory needs it early |
|---|---|
| Target SPF and PA grade | Sets the filter system and how much of it the base must carry |
| Format (milk, gel, cream, stick, spray) | Changes the base, the container and, for sprays, the shipping class |
| Water-resistance claim, yes or no | Adds a separate test and label method |
| Every destination market | Filter acceptance and test-method acceptance differ by market |
| Filters or ingredients to avoid | Narrows the filter options and may limit the reachable SPF |
| Texture and finish reference | Filter load shapes feel, so the reference matters more than for skincare |
“Light, no white cast” is a texture brief, not a specification. Send a reference product and describe what it should do on the skin. High protection levels and very light textures can pull in different directions, and the factory will tell you where the trade-off sits for your chosen filters.
How much of this you start from the factory’s existing base, and who then owns the formula, is covered in stock base or custom formula.
UV filters come from a positive list
In Japan, any substance used specifically to absorb UV and protect skin or hair must be on Appendix 4 of the Standards for Cosmetics, within the limit for that product type — a filter allowed elsewhere is not automatically allowed in Japan.
Japan’s Standards for Cosmetics (化粧品基準), Ministry of Health and Welfare Notification No. 331 of 2000, applied from April 2001, treat UV filters the way they treat preservatives: as a positive list. Only listed substances may be used, and their limits can differ by product type. Preservatives in the same sunscreen must come from Appendix 3.
For an export sunscreen the check runs in two directions. Japan’s list decides what the factory can put in. Your destination market’s list decides what you can sell. A filter system has to pass both. That is why the factory asks for every market at the start: changing a filter after SPF testing means the product you tested is no longer the product you sell. The general method is in checking a formula against Japan’s Standards.
For spray sunscreens, note that the Standards’ restricted list (Appendix 2) does not permit zirconium in aerosols, and aerosols raise shipping questions covered below.
How SPF and PA are measured
SPF is measured in vivo under ISO 24444 and UVA protection (shown as PA) in vivo under ISO 24442; Japan’s industry association sets how those results appear on the label, as a voluntary standard rather than a national one.
The two ISO methods were published from discussions in which the Japan Cosmetic Industry Association’s (JCIA, 日本化粧品工業会) own methods were the basis. JCIA has kept its standards in step with ISO:
- an SPF lower limit in a voluntary standard of 20 January 2015;
- an SPF method standard on 21 February 2020, with a supplement on 3 June 2022;
- an updated UVA (PA) method standard on 1 September 2022, following the 2022 revision of ISO 24442;
- a water-resistance test standard based on ISO 18861 on 15 October 2021, with its own labelling method.
A review in the Journal of the Society of Cosmetic Chemists of Japan in 2013 described SPF and PA as industry standards rather than national standards. PA grades run from PA+ to PA++++; the same review described PA++++ as being introduced in 2013 as the highest UVA grade.
There is also an in vitro method, ISO 23675:2024 (double-plate in vitro SPF). Before you plan around it, check whether your destination market and the JCIA standard accept it. Do not assume.
Checked against the published texts of the Ministry of Health, Labour and Welfare, the Japan Cosmetic Industry Association and the Journal of the Society of Cosmetic Chemists of Japan on 17 October 2026.
💬 Unsure which tests your markets will accept for SPF, PA or water resistance? Tell us the markets and we will work out the test plan with the factory before formula work starts.
Test the final formula in the final format
Run SPF, PA and water-resistance tests on the formula you will actually produce, and treat any later change to filters or base as a reason to ask whether the tests must be repeated.
The measured value belongs to the formula that was tested. If the brand changes the fragrance, swaps an emollient for feel or moves to a different filter after the test, ask the factory whether the result still stands. This is the most common way a sunscreen project loses time: the test is run early on a near-final sample, then the “small” texture change follows.
A workable order is:
- Agree filters against Japan’s list and your markets’ lists.
- Iterate texture until you approve a sample by its code.
- Freeze the formula and the container.
- Run the protection tests on that frozen formula.
- Design the label around the measured results.
Stability work runs alongside. The factory designs the programme — typically temperature, light, cycling and container contact — and there is no single Japanese statutory protocol for it. Ask what was observed, especially changes in appearance or separation. See stability and compatibility testing.
How the numbers appear on a Japanese label
Japanese practice under the JCIA standard displays SPF values above 50 as “SPF50+” and shows UVA protection as PA+ to PA++++ — confirm the current standard text before you finalise artwork.
Because the display is a JCIA voluntary standard, the factory will expect the Japanese label to follow it. A water-resistance claim must follow the JCIA’s labelling method for the ISO 18861-based test. If you sell in other markets, their display rules may be different; your importer will know which format the destination authority expects.
Plan the label space early. A sunscreen label may need the SPF and PA display, directions for use, the full ingredient list and any destination-specific wording. On small tubes, space runs out quickly. Containers and packaging covers multi-language label space.
What the label may claim
As a cosmetic, a sunscreen may claim “prevents sunburn” and “prevents spots and freckles caused by sunburn” from Japan’s 56-item range; a whitening claim in the melanin sense makes it a quasi-drug.
Japan’s efficacy range for cosmetics (化粧品の効能の範囲) contains two items written for sun products: “prevents sunburn” and “prevents spots and freckles caused by sunburn”. Other skincare items, such as “moisturises the skin” or “prevents dryness of the skin”, may also apply if they are true of the product. Makeup effects, such as a tone-up from a tinted base, may be stated if they are true and do not guarantee a result.
The boundary to watch is whitening. In Japan’s quasi-drug wording, whitening means suppressing melanin production to prevent spots and freckles. That is a quasi-drug (医薬部外品) claim needing an approved active ingredient and product-by-product approval. “Prevents spots and freckles caused by sunburn” is the cosmetic item, and it is a different claim. Do not let the two merge on the artwork. See cosmetic or quasi-drug for the decision and the 56-item efficacy range for the full list.
| Draft wording | Where it sits in Japan |
|---|---|
| ”Prevents sunburn” | Within the cosmetic efficacy range |
| ”Prevents spots and freckles caused by sunburn” | Within the cosmetic efficacy range |
| ”SPF50+ PA++++“ | Display under the JCIA voluntary standard, backed by test results |
| Water-resistance wording | JCIA labelling method for the ISO 18861-based test |
| ”Whitening” in the melanin sense | Quasi-drug category |
Ingredient list, shipping and documents
The full ingredient list is produced in Japanese labelling names and must be converted to INCI for export; sprays and alcohol-rich sunscreens need a transport classification from the SDS before you book freight.
All cosmetics in Japan list every ingredient using the Japan Cosmetic Industry Association’s labelling names, in descending order, with those at 1% or less and colourants in any order among themselves. Fragrance may be listed collectively as “fragrance” (香料). Converting that list to INCI for export labels is a separate, checked step; see full ingredient labelling and INCI.
Aerosol sprays and alcohol-rich formulas may be classed as dangerous goods for air and sea transport. Section 14 of the safety data sheet (SDS) states the transport classification, and the carrier decides how it ships. Ask for the SDS before you plan freight. The full sequence is in the export shipping flow.
If the sunscreen carries export-only labels, the work counts as manufacturing: the factory side needs a cosmetics manufacturing licence and an export manufacturing notification (輸出用化粧品製造届) filed before manufacture starts. Your importer files the destination notification. We prepare the Japan-side set, described in export documents and certificates. For Vietnam, see Vietnam’s cosmetics import notification.
💬 Planning a Japan-made sunscreen? See our cosmetics OEM service, the Japan cosmetics OEM guide, or send us your target SPF and PA.
Frequently asked questions
1. Is SPF in Japan set by law?
No. SPF and PA are industry standards. The measurement methods are ISO 24444 for SPF and ISO 24442 for UVA protection, and the way results appear on Japanese labels follows the Japan Cosmetic Industry Association’s voluntary standard.
2. Can I use the same UV filters I use in another market?
Only if they are on Appendix 4 of Japan’s Standards for Cosmetics, within the limit for that product type. A filter allowed elsewhere may not be on Japan’s list, and your destination market’s own list must also accept it.
3. Why does the label say SPF50+ instead of a higher number?
Japanese practice under the JCIA standard displays SPF values above 50 as SPF50+. Confirm the current standard text before you finalise artwork, and check what format your destination market expects.
4. Can I use an in vitro SPF test instead of testing on people?
ISO 23675:2024 sets a double-plate in vitro SPF method. Whether it is accepted depends on your destination market and on the JCIA standard, so check both before you plan around it.
5. Can a sunscreen say it prevents dark spots?
As a cosmetic, it may use the item “prevents spots and freckles caused by sunburn”. A whitening claim in the sense of suppressing melanin production belongs to the quasi-drug category and needs an approved active ingredient and product approval.