AICIS Treatment of Colourants and Pigments in Makeup

Colourants are one of the more interesting categories to think through under AICIS, because makeup pigments sit at an intersection of several things regulators care about: they're often inorganic (iron oxides, mica, titanium dioxide), they're used at meaningful concentrations, and they end up on skin, lips, and sometimes very close to the eyes. That combination shapes how they get treated.

Colourants are still industrial chemicals under AICIS

Same starting point as any other cosmetic ingredient in Australia: AICIS regulates the introduction of industrial chemicals, and cosmetic colourants and pigments fall under that scheme rather than a separate cosmetics-specific colour list, which is the model people coming from other markets sometimes expect. The EU, for instance, maintains its own list of permitted cosmetic colourants with specific conditions attached. Australia's framework works through the Inventory and introduction categories instead.

What makes pigments a distinct case within that framework

Well-established pigments have long histories

Iron oxides, titanium dioxide, mica, and ultramarines are some of the most extensively used and well-characterized substances in cosmetics globally, going back decades in eyeshadow, foundation, blush, and lip products. This kind of substance, widely used, well-studied, low novel-hazard profile, is exactly the situation where you'd expect Inventory listing status to already be established and categorisation to land in a lower-scrutiny bracket, though as always, checking the Inventory for the actual substance is the reliable move rather than assuming based on how common an ingredient is elsewhere.

Particle size can matter

Pigments processed to very fine or nano-scale particle sizes can present different considerations than their conventional counterparts, since particle size affects things like potential for penetration and overall hazard characterization. If you're sourcing a "nano" grade of an otherwise conventional pigment, mica or titanium dioxide processed to a finer particle size, treat that as a distinct categorisation question rather than assuming it inherits the same status as the standard-grade version of the same named substance.

Organic and synthetic colourants vary more

Synthetic organic pigments and dyes used in lip and eye products cover a much wider range of chemical structures than the common inorganic pigments, and their categorisation is going to depend on the specific substance's own Inventory status and hazard profile rather than a general assumption that "colourants are fine." Some synthetic dyes carry their own specific use restrictions in various markets, particularly around eye-area and lip products, given the proximity to mucous membranes.

Where listing conditions come in

This is the part of AICIS that's easy to underappreciate if you're mentally modeling it as a simple pass-fail Inventory check. Even where a colourant is Inventory-listed, its listing can carry specific conditions attached, conditions that might govern things like permitted concentration, intended use, or handling requirements. A pigment might be Inventory-listed generally but have listing conditions that constrain the context you're allowed to introduce it in. This is exactly the kind of detail that requires checking the actual current Inventory entry for the specific substance, not just confirming it appears on the list at all.

A practical categorisation walkthrough for an eyeshadow palette

Say you're formulating a six-pan eyeshadow palette using a mix of iron oxides, mica, and a couple of synthetic organic pigments for more vivid shades.

1. List every colourant by its actual INCI or chemical identity, not the shade name on your inspiration mood board.
2. Check each one's Inventory status individually, since a palette mixing eight or nine different colourants means eight or nine separate checks, not one check for "the palette."
3. For inorganic pigments (iron oxides, mica, titanium dioxide), confirm whether any are processed to a nano or unusually fine particle size, which may shift categorisation.
4. For synthetic organic pigments, check both Inventory status and any listing conditions tied to eye-area use specifically, since eyeshadow is about as close to the eye as a cosmetic gets.
5. Document what you checked, including the Inventory entries and any conditions attached, so the categorisation work is traceable if the formula or an ingredient's status changes later.

The bigger pattern

Colourants are a good illustration of why AICIS categorisation isn't a single yes-or-no gate. It's a substance-by-substance exercise where common, well-established pigments are usually the easy part and the real work is in newer synthetic colours, unusual particle sizes, and checking listing conditions rather than just Inventory presence.

Cosmetic Comply currently handles ingredient-to-INCI mapping and restricted-list screening for Canada's CNF process, with Australian AICIS support coming. The discipline that AICIS categorisation demands, real substance identity for every named ingredient rather than a trade or shade name, is the same discipline that makes any market's filing go smoothly.