Categorising Carrier Oils and Butters Under AICIS

Shea butter, jojoba oil, sweet almond oil, none of these sound like "industrial chemicals" to the average soap maker. But that's exactly the bucket Australia puts them in, and understanding why changes how you prepare a formula for that market.

AICIS doesn't work like a cosmetic notification

Australia doesn't run a per-product cosmetic notification system the way Canada does. Instead, AICIS, the Australian Industrial Chemicals Introduction Scheme, regulates the individual chemicals that go into your formula, including your base oils and butters, as industrial chemicals. Every ingredient gets evaluated against the Australian Inventory of Industrial Chemicals and assigned to an introduction category based on factors like hazard profile and volume.

This means your compliance work in Australia happens at the ingredient level, not the finished-product level. You're not filing "my body butter recipe," you're confirming that each chemical in it, including your carrier oils, is already listed on the Inventory or properly introduced under a category that fits your situation.

Why carrier oils count as industrial chemicals at all

It sounds strange until you remember that AICIS categorizes by chemical identity and use, not by how "natural" or food-grade an ingredient feels to the end user. Cold-pressed jojoba oil is still, chemically, a defined substance with a CAS number and a known composition. Whether it ends up in a lotion or a lubricant, from a regulatory standpoint it's an industrial chemical being introduced into Australian commerce.

The practical upshot for makers: most common carrier oils and butters used in soap and skincare, shea butter, cocoa butter, coconut oil, olive oil, argan oil, and similar, are already on the Australian Inventory because they've been imported and used for decades. That's good news. It typically means your introduction category work is lighter than you'd expect for well-established botanicals.

Where it gets more involved

Problems tend to show up with:

• Novel or exotic extracts that haven't been introduced into Australia before, these may need a more involved categorization process
• Refined or modified oils where processing changes the chemical identity enough that it's treated as a distinct substance from the crude oil
• Blends and derivatives, since a supplier's proprietary butter blend may include a component that isn't separately listed

A rough framework for checking your formula

1. List every base oil and butter by both trade name and INCI name
2. Confirm the CAS number for each, since the Inventory is organized around chemical identity
3. Check whether each substance already appears on the Australian Inventory
4. For anything not listed, determine which introduction category applies based on your volume and use pattern
5. Keep records of this categorization work, since AICIS operates more on a self-assessment and record-keeping model than a submit-and-wait notification

Ingredient type	Typical AICIS status	What to double check
Common carrier oils (olive, coconut, sweet almond)	Usually already listed	Confirm CAS matches supplier spec
Common butters (shea, cocoa, mango)	Usually already listed	Check for refined vs. unrefined identity
Novel botanical extracts	May not be listed	May require introduction category assessment
Modified or esterified oils	Possibly a distinct substance	Confirm identity with supplier documentation

Why this matters more than it looks like it should

A lot of small brands assume that because a base oil is edible or "GRAS" in a food context, it's automatically fine everywhere. AICIS doesn't work off food-safety logic, it works off industrial chemical introduction logic. That disconnect is where brands get caught off guard when they expand into Australia for the first time.

It's also worth remembering AICIS categorization sits alongside, not instead of, your general labeling and safety obligations for cosmetics sold in Australia. Getting the chemical introduction status right is necessary, but it's one piece of a larger compliance picture.

If you're formulating for multiple markets at once, this is one more reason to keep a clean internal ledger of every ingredient's INCI name, CAS number, and supplier documentation from day one, rather than reconstructing it later when a new market's rules ask a slightly different question of the same formula. Cosmetic Comply already does exactly this kind of ingredient-level matching and screening for Canadian filings, and Australia is on its roadmap, so it's a natural place to keep that ingredient record organized as you plan ahead.