Group Transition period less than Transition period longer product life (no than product life cycle transition period or previous (revised Option 2A Option 2A period of 2 years) transition period of 5 years, or Option 2B open transition period) 1 (introducing new $300 in re-testing costs $300 in extra re-testing costs product anyway) Group 2 (remarketing an $3300 in retesting and $300 in retesting costs – existing product with relabelling relabelling costs will be performance that complies expended when business with the 2012 Standard) reformulates of its own accord 3 (complete redesign of $300-26,475 in retesting, $300 in extra retesting costs existing product as relabelling and reformulating relabelling and – performance does not costs reformulation costs will be comply with 2012 Sunscreen expended when business Standard) reformulates of its own accord However, it is again noted that: regardless of transitional arrangements, adoption of the revised Sunscreen Standard would likely present some reformulation challenges to maintain the cosmetic aesthetics of the product, with extra costs likely to be between $300 and around $26,475, depending on the extent to which the product would have been reformulated anyway. regardless of transitional arrangements, the few companies who chose not to incorporate broad spectrum performance in their cosmetic sunscreen products under the 1998 Sunscreen Standard, will incur a once-off cost of around $26,475 per product line to reformulate against the mandatory broad spectrum performance requirements imposed by the 2012 Sunscreen Standard; adoption of a five year closed transition period will provide a level playing field whereby all businesses must comply with the 2012 Sunscreen Standard by the same date, thereby ensuring costs to industry are on a competitive footing; adoption of the five year closed and of the transition period will both ensure that product-lines will reach the end of their natural life cycle and so will be reformulated anyway before compliance with the 2012 Sunscreen Standard becomes mandatory. This will minimise write-off of old stock.
Group Transition period less than product life (no transition period or previous Option 2A period of 2 years) Transition period longer than product life cycle (revised Option 2A transition period of 5 years, or Option 2B open transition period) 1 (introducing new product anyway) $300 in re-testing costs $300 in extra re-testing costs Group 2 (remarketing an existing product with performance that complies with the 2012 Standard) $3300 in retesting and relabelling $300 in retesting costs – relabelling costs will be expended when business reformulates of its own accord 3 (complete redesign of existing product as performance does not comply with 2012 Sunscreen Standard) $300-26,475 in retesting, relabelling and reformulating costs $300 in extra retesting costs – relabelling and reformulation costs will be expended when business reformulates of its own accord However, it is again noted that: regardless of transitional arrangements, adoption of the revised Sunscreen Standard would likely present some reformulation challenges to maintain the cosmetic aesthetics of the product, with extra costs likely to be between $300 and around $26,475, depending on the extent to which the product would have been reformulated anyway. regardless of transitional arrangements, the few companies who chose not to incorporate broad spectrum performance in their cosmetic sunscreen products under the 1998 Sunscreen Standard, will incur a once-off cost of around $26,475 per product line to reformulate against the mandatory broad spectrum performance requirements imposed by the 2012 Sunscreen Standard; adoption of a five year closed transition period will provide a level playing field whereby all businesses must comply with the 2012 Sunscreen Standard by the same date, thereby ensuring costs to industry are on a competitive footing; adoption of the five year closed and of the transition period will both ensure that product-lines will reach the end of their natural life cycle and so will be reformulated anyway before compliance with the 2012 Sunscreen Standard becomes mandatory. This will minimise write-off of old stock.
RIS-Sunscreen-Standard.docx