However, as scientific emphasis on UVA‑induced photoaging and carcinogenesis continues to grow (4), the normative importance of balanced protection increases correspondingly. Where protection metrics directly influence behavioural exposure decisions, regulatory clarity becomes a matter of public health significance.

Annex VI of Regulation (EC) No 1223/2009 establishes a positive list of authorised UV filters (6), demonstrating that the EU legislator has not hesitated to impose binding harmonisation where safety considerations demand it. Protection metrics, which shape consumer reliance, merit comparable legal solidity.

SPF values are not merely technical descriptors. They operate as behavioural signals. Their regulatory treatment must reflect that normative weight.

In practice, market operators treat many of its provisions as normative benchmarks. Testing protocols and categorisation schemes are widely applied as if legally mandatory. This functional elevation of a Recommendation to quasi‑normative status raises a question of legal coherence.

Where compliance is effectively expected across the internal market, the absence of formal binding status may generate avoidable legal uncertainty. Divergent national interpretations remain possible, and enforcement intensity may vary.

Transforming essential sunscreen efficacy requirements into a directly applicable legislative instrument would enhance legal certainty, ensure uniform enforcement and reinforce consumer trust. Given the established public health relevance of UV protection (4, 5), binding harmonisation appears proportionate and justified.

In the field of sunscreen regulation, SPF categorisation and balanced UVA requirements are not peripheral technicalities. They form the backbone of consumer reliance and market comparability. Where such standards effectively operate as binding expectations, their continued location within non‑binding guidance may undermine transparency and democratic accountability.

The question is no longer whether soft law can influence behaviour – it clearly can. The more pressing issue is whether reliance on informal harmonisation remains appropriate once standards acquire structural significance for both public health protection and internal market functioning.

In this light, the transition from recommendation to binding legislation should not be viewed as regulatory expansion, but as regulatory clarification.

The logical next step in the maturation of EU sunscreen governance is therefore not further informal convergence, but legislative consolidation. Binding harmonisation would not merely codify existing practice; it would provide the appropriate legal framework to adapt protection standards to contemporary public health needs. In this sense, the future of EU sunscreen regulation lies not in incremental adjustment, but in structural clarification and calibrated reinforcement.