Comments for Public Consultation on Preliminary Opinion on Biological effects of ultraviolet radiation relevant to health with particular reference to sunbeds for cosmetic purposes

25 April 2016

The European Academy of Dermatology and Venereology (EADV), the European EUROMELANOMA campaign, the European Dermatology Forum (EDF) and the European Association of Dermato-Oncology  (EADO) have studied the SCENIHR report on the primary biological effects of ultraviolet radiation relevant to health, with particular reference to sunbeds for cosmetic purposes.

The goal of this report was to update the scientific and medical evidence to ensure sufficient levels of protection for the health and safety of users. A further objective of this report was to answer the question whether a wavelength for which the total irradiance is negligible and thus minimises the risks of developing skin cancer through the use of sunbeds.

The aforementioned stakeholders have carefully read the report’s content about the exposure, the cancer and non-cancer health effects, the mechanistic studies and the risk characterisation.

We approve the scientific content and the methodology used to make the report.

We fully support the report’s proposed conclusions:

  • Ultraviolet (UV) radiation is a complete carcinogen, acting both as an initiator, through genotoxicity, and as a promoter, through immunosuppression.
  • Sunbed use increases the risk of skin melanoma, squamous cell carcinoma and, to a lesser extent, basal cell carcinoma, especially when first exposure takes place at a young age. There is moderate evidence that sunbed exposure may also cause ocular melanoma.
  • Early-onset melanomas (melanomas occurring before the age of 30) are particularly associated with sunbed use.
  • The potentially beneficial effects of sunbed use are more than outweighed by the many severe adverse effects. There is no need to use sunbeds to boost vitamin D synthesis; and UV overexposure may in fact reduce vitamin D levels.
  • There is no safe limit for sunbed use. Not only is sunbed use carcinogenic, there is no evidence of a threshold for skin cancer induction related to UV-irradiance and UV-dose.


On behalf of:


The European Academy of Dermatology and Venereology

Prof. Dr. Erwin Tschachler – President


The European Dermatology Forum

Prof. Dr. Lars French – President


The European Association of Dermato-Oncology

Prof. Dr. Claus Garbe - President



Prof. Dr. Veronique del Marmol – Chair


About EADV

Founded in 1987, EADV is a non-profit association whose vision is to be the premier European Dermato-Venereology Society, with the key aims of improving the quality of patient care, providing continuing medical education (CME) for all Dermato-Venereologists in Europe and advocacy on behalf of the specialty and patients.

The membership concept has been broadened to include all areas of Europe and elsewhere, and the development of alliances and affiliations with other organisations. EADV currently represents approximately 5,000 members. 

About EDF

Founded in 1997, EDF is a non-profit professional organisation dedicated to improving the healthcare needs of dermatology patients in Europe. EDF’s mission is to implement actions aimed at preventing skin diseases and improving the quality of health care for dermatologic & and venereologic patients in Europe. The EDF represents approximately 200 active members consisting of heads of academic departments and key opinion leaders in dermato-venereology across Europe. 

About EADO

EADO is an independent non-profit organization dedicated to promote, coordinate and improve clinical and laboratory research activities in the field of skin cancer including primary and secondary prevention, early detection, clinical diagnosis and clinical and experimental research. The EADO community currently counts over 400 eminent members from more than 40 countries, representing a variety of disciplines -- dermatologists, oncologists and clinical as well as basic research scientists interested in the field of Dermato Oncology.

About Euromelanoma

Established in 1999, Euromelanoma is a pan-European skin cancer campaign, active in 33 countries. Euromelanoma exists to promote and share information on skin cancer prevention, early diagnosis and treatment and is led by a network of European dermatologists. Euromelanoma’s activities are focused on reaching three key audiences; the general public; the scientific community; and European and national policy makers.