How a Chemical Gets Added to the AICIS Inventory
Australia treats cosmetic ingredients as industrial chemicals. Here's the assess-then-list path a new substance follows onto the AICIS Inventory.
If you're used to Canada's per-product notification or the EU's CPNP portal, Australia's system feels like it's speaking a different language at first. AICIS, the Australian Industrial Chemicals Introduction Scheme, doesn't ask you to notify a finished cosmetic product at all. It regulates the chemicals themselves, as industrial chemicals, and cosmetics are just one use case for substances that sit on a shared inventory.
The core idea: ingredients, not products
Rather than filing "my lavender body lotion" as a product, AICIS cares about whether the chemical ingredients inside that lotion are already known, assessed, and listed on the Inventory. If every ingredient in your formula is already on the Inventory and you're using it within the categories that Inventory listing covers, there's often nothing further to introduce. If an ingredient isn't on the Inventory yet, that's when the introduction process, and potentially an assessment, comes into play.
This is a fundamentally different mental model from a per-product notification system. You're not asking "is my product approved." You're asking "is this ingredient already recognized, and if not, what category of introduction am I doing."
How a new chemical actually gets added
For a chemical that isn't already on the Inventory, getting it added generally follows an assess-then-list pattern:
- The introduction is categorized. AICIS uses a system of introduction categories based on factors like the chemical's hazard profile, the volume being introduced, and how it will be used. Lower-risk introductions can move through more efficient categories, while higher-risk or higher-volume introductions require more scrutiny.
- An assessment may be required. Depending on the category, the chemical may need to go through an actual risk assessment before it can be introduced, where AICIS reviews the hazard and exposure information available for that substance.
- Once introduced and assessed, it can be added to the Inventory. After a chemical has gone through an introduction (and any required assessment), it becomes eligible to be added to the Inventory, at which point future introductions of that same chemical by other parties can reference its already-established status rather than starting from scratch.
The practical effect is that the Inventory grows over time as new chemicals get introduced and assessed, and it becomes a shared reference point. A chemical that's brand new to the Australian market takes real work to bring in. A chemical that's already well established on the Inventory is a much lighter lift for the next person who wants to use it.
What this means day to day for a cosmetic maker
If you're formulating with common, well-established cosmetic ingredients, plant oils, standard emulsifiers, familiar preservatives, there's a good chance they're already sitting comfortably on the Inventory, and your job is mostly about confirming that and using them within the applicable categories. Where this gets more involved is with novel or unusual ingredients: a newly patented active, an ingredient not previously used in Australia, or something with a complex or poorly documented hazard profile. Those are the situations where you genuinely need to understand which introduction category applies and whether an assessment is triggered.
| Situation | What it generally means |
|---|---|
| Ingredient already on the Inventory, common use | Straightforward, existing status generally covers you |
| Novel ingredient, low hazard indicators | Lower-tier introduction category, lighter requirements |
| Novel ingredient, higher hazard or volume | May require a fuller risk assessment before introduction |
Why this trips up makers coming from other markets
Someone used to Health Canada's CNF or the EU's CPNP tends to look for an equivalent "submit the product" button in the Australian system and doesn't find one, because that's not how AICIS is structured. The unit of regulation is the chemical, not the finished cosmetic. That's a genuinely different compliance posture, and it means your homework in Australia is ingredient-level rather than formula-level, even though in practice you still need to know your full formula to check every ingredient against the Inventory.
Because AICIS categories and assessment requirements can shift and because a chemical's status (assessed, listed, subject to conditions) is specific and technical, this is one of those areas where it pays to check the current AICIS guidance directly for the exact ingredient you're working with, rather than relying on a general sense of "most things are fine." Cosmetic Comply is expanding into Australia as part of its market coverage, alongside the US and EU, with Canada live today, so if you're formulating across markets it's worth keeping an eye on that as a way to check ingredient status without hunting through the Inventory manually every time.
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Start a filingKeep reading
Why Australia Treats Your Cosmetics as Industrial Chemicals
The legal logic behind AICIS classifying cosmetic ingredients as industrial chemicals rather than regulating finished cosmetic products directly.
AICIS Rules for Research and Development Introductions
How Australia's AICIS treats small-quantity research and development introductions differently from a full commercial launch.
AICIS Recordkeeping: What to Keep and for How Long
The categorisation and introduction records AICIS expects an Australian cosmetic importer or manufacturer to hold, and for how long.
The AICIS Inventory Explained for Cosmetic Makers
Australia regulates cosmetic ingredients as industrial chemicals through AICIS, not per-product notification. Here is what that means in practice.