The recent paper by Miura et al. (Photochem. Photobiol. 84, 1569–1575) offers a re-examination of extant in vitro methods for dynamically measuring sunscreen photodegradation under continuous irradiation in situ. We commend the authors’ efforts toward developing an improved system for accurate in vitro sunscreen assessment. This work describes an alternate derivative apparatus incorporating an improved detector which may prove an exceptionally valuable contribution toward that goal. Unfortunately their report suffers from insufficient detail in instrumentation description and lacks requisite calibration procedures. Their utilization of a solar simulator filtered for conventional in vivo sun protection factor (SPF) testing poses transmittance measurement limitations at short wavelengths that are not adequately addressed and is also deficient, relative to sunlight, in longer UVA wavelengths shown to contribute to sunscreen photoinstability. We concur that the in vitro sunscreen testing should utilize continuous or multiple irradiation doses and should ideally use the same 2 mg cm−2 product application amount as does the human SPF test. We encourage their proposal that methodology, which simultaneously measures sunscreen spectral transmittance and photodegradation under continuous irradiation to an accumulated erythemic endpoint, as we previously described, be developed into a consensus test standard.