US, European and Asian sunscreens compared: SPF, broad spectrum, PA ratings and UV filters
Pick up a US sunscreen and an Asian one and the labels hardly look like the same product. One says "Broad Spectrum SPF 50, water resistant (80 minutes)" in a Drug Facts box; the other says "SPF50+ PA++++" in large letters. Both describe protection against two kinds of ultraviolet light, measured in different ways under different rules. Understanding the codes makes it easier to choose, and to compare a product bought at home with one bought abroad.
- SPF measures protection mainly against UVB, the rays that cause sunburn. It is tested the same basic way worldwide.
- UVA protection is labelled differently: "broad spectrum" (US, pass or fail), a UVA logo (EU, at least one third of the SPF), or a PA rating from PA+ to PA++++ (Japan, Korea and much of Asia).
- In the US, sunscreens are OTC drugs with a short filter list; in the EU, Korea, Japan and ASEAN countries including Malaysia, they are cosmetics or functional cosmetics with longer lists.
- Whatever the label, the dermatologists' advice is the same: broad-spectrum SPF 30 or higher, applied generously and reapplied.
UVB, UVA and what SPF measures
UVB rays are the main cause of sunburn and contribute to skin cancer. UVA rays penetrate deeper, pass through windows and clouds, and contribute to skin aging, pigmentation and skin cancer too. SPF, the sun protection factor, is measured by comparing how much UV it takes to redden protected and unprotected skin under a standard lamp. It therefore mostly reflects UVB protection. SPF tests use a thick layer of 2 milligrams per square centimetre; most people apply far less, which our guide to how much sunscreen to use explains.
The United States
- Status: OTC drug, regulated through the FDA's sunscreen monograph. Labels have a Drug Facts box with active ingredients and percentages.
- Broad spectrum: a product passes the FDA's broad-spectrum test if its UVA protection is proportionate to its UVB protection. Only broad-spectrum sunscreens with SPF 15 or higher may claim to reduce the risk of skin cancer and early skin aging when used with other sun protection measures.
- Water resistance: "water resistant (40 minutes)" or "(80 minutes)". "Waterproof" and "sweatproof" are not allowed.
- Filters: in a 2019 proposal, the FDA said only zinc oxide and titanium dioxide had enough data to be considered generally recognized as safe and effective (GRASE), and asked for more data on twelve others, including avobenzone, octocrylene and oxybenzone, which remain on sale. PABA and trolamine salicylate were proposed as not GRASE. In 2026, the FDA added bemotrizinol (up to 6%), the first new sunscreen active in decades, a filter used in Europe and Asia for years.
The European Union
- Status: cosmetic, under Regulation (EC) No 1223/2009; permitted UV filters are listed in Annex VI with maximum concentrations.
- UVA: a European Commission recommendation (2006/647/EC) says UVA protection should be at least one third of the labelled SPF, with a critical wavelength of at least 370 nm. Products that meet it show a "UVA" in a circle.
- Labels: SPF categories from "low" to "very high" (50+).
- Filters: a longer list, including bemotrizinol (up to 10%) and other newer UVA filters not available in US products.
Japan, Korea and the PA rating
The PA rating, created in Japan and widely used in Korea and across Asia, expresses UVA protection measured by persistent pigment darkening (PPD): how much UVA it takes to tan protected skin compared with unprotected skin. The higher the number of plus signs, the higher the UVA protection, up to PA++++ for the highest band (a UVA protection factor of 16 or more). Japan's industry standard follows ISO 24442, updated in 2022.
In Korea, sunscreens are functional cosmetics reviewed by the MFDS, with SPF and PA backed by testing. In Japan, UV filters must be on a positive list in the Standards for Cosmetics. Both markets label very high protection as "SPF50+".
Malaysia and ASEAN
In Malaysia, sunscreens are cosmetics, notified to the NPRA like any other cosmetic. UV filters must appear on the ASEAN list (Annex VII of the ASEAN Cosmetic Directive) within their limits. The list changes: a 2024 circular revised the limit for homosalate, and a 2026 circular removed 4-methylbenzylidene camphor, with a transition period. Products from the US, Europe, Korea and Japan all appear on Malaysian shelves, so you will see all four labelling systems side by side.
| Market | Legal status | UVA label | Highest SPF on label |
|---|---|---|---|
| United States | OTC drug | "Broad spectrum" (pass/fail) | Numbers above 50 still appear; the FDA proposed a cap of "60+" in 2019 |
| European Union | Cosmetic | "UVA" in a circle (UVA ≥ 1/3 of SPF) | 50+ |
| Japan | Cosmetic or quasi-drug | PA+ to PA++++ | 50+ |
| Korea | Functional cosmetic | PA+ to PA++++ | 50+ |
| Malaysia (ASEAN) | Cosmetic (NPRA notification) | Varies with product origin | Varies |
Mineral, chemical and "hybrid"
Sunscreen filters are often described as mineral (zinc oxide, titanium dioxide) or chemical (organic) filters. Mineral filters are often better tolerated by sensitive skin and around the eyes, and zinc oxide gives broad UVA protection, but they can leave a white cast on deeper skin tones, especially in high amounts. Modern organic filters, especially the newer ones used in Europe and Asia, allow light, invisible textures with strong UVA protection. Many products combine both. The best sunscreen is the one you will apply generously every day.
How to choose, whatever the origin
- SPF 30 or higher, as the American Academy of Dermatology recommends.
- Strong UVA protection: "broad spectrum" (US), the UVA circle (EU) or PA+++ to PA++++ (Asia).
- Water resistance for swimming, sport or tropical commutes.
- A texture you like, so you use enough.
- An expiry date and a sealed, undamaged pack. In the US, a sunscreen without an expiry date is considered expired three years after purchase.
- Local legality if you buy abroad; our guide to cosmetics rules explains Malaysia's notification system.
For the bigger picture on why American and Asian products differ, see US and Asian skincare philosophies.
Sources
- US Food and Drug Administration, "Sunscreen: How to Help Protect Your Skin from the Sun", FDA, consulted October 2026.
- US Food and Drug Administration, proposed rule "Sunscreen Drug Products for Over-the-Counter Human Use", Federal Register, February 2019; and order adding bemotrizinol to the OTC sunscreen monograph, 2026.
- European Commission, Recommendation 2006/647/EC on the efficacy of sunscreen products and the claims made relating thereto, 2006.
- Regulation (EC) No 1223/2009 on cosmetic products, Annex VI (UV filters), Official Journal of the European Union.
- ISO 24442, Cosmetics – Sun protection test methods – In vivo determination of sunscreen UVA protection, 2011, revised 2022; Japan Cosmetic Industry Association standard.
- National Pharmaceutical Regulatory Agency (NPRA), Circulars on ASEAN Cosmetic Directive Annex VII (UV filters), 2024 and 2026.
- American Academy of Dermatology, "How to select a sunscreen", AAD, consulted October 2026.
US and Asian skincareHow much sunscreen to use
Half a teaspoon for the face, a shot glass for the body, every two hours: the numbers behind the advice.
US and Asian skincareCosmetics rules: US, Korea, Malaysia
Who checks a product before sale, what counts as a drug, and what a Malaysian notification number tells you.
US and Asian skincareUS and Asian skincare: two philosophies
Drug-category actives and dermatologist branding versus layering, textures and 'functional cosmetics': where the differences come from.