AICIS Categorisation Steps for a New Cosmetic Product

If you have only ever filed cosmetics in a market that works product by product, Australia will feel backwards at first. AICIS does not ask "is this lotion safe." It asks "is this chemical already known, and what category does introducing it fall into." Get the categorisation step wrong and everything downstream, your recordkeeping, your reporting obligations, your risk exposure, follows the wrong path.

Here is the order the decisions actually come in.

Step one: identify every ingredient as a distinct chemical

Before you can categorise anything, you need a clean ingredient list mapped to actual chemical identities, not trade names. A supplier blend sold under a brand name is not one chemical, it is several, and each needs to be traced back to what it really is. This is the same groundwork you would do for any market's filing, it just gets used differently here. Skip this step and every later decision is built on sand.

Step two: check the Inventory

Once you know what each ingredient actually is, check whether it is already listed on the Australian Inventory of Industrial Chemicals. Ingredients already on the Inventory are known quantities from a regulatory standpoint. Ingredients that are not listed are the ones that drive your categorisation toward higher scrutiny, because introducing something new to the Australian market carries more weight than introducing something already characterized.

Step three: work out exposure and volume

AICIS categorisation leans heavily on how people will actually encounter the chemical and how much of it is moving into the market. A leave-on facial product and a rinse-off body wash do not carry the same exposure profile even if they share an ingredient. Volume matters too. A small-batch soap maker introducing a few kilograms a year sits in a very different place than a manufacturer bringing in industrial quantities. Both exposure and volume are inputs AICIS expects you to have thought through before you assign a category, not details you fill in after the fact.

Step four: assign the introduction category

With chemical identity, Inventory status, exposure, and volume in hand, you land on one of the introduction categories. Lower categories generally suit ingredients that are already well characterized, used in ways that limit exposure, and introduced in modest volume. Higher categories apply as novelty, exposure, or volume increase. This is not a self-certification you can eyeball once and forget. If your formula or your volumes change meaningfully, the categorisation can change with them.

Step five: keep the paper trail

Whatever category you land on, AICIS expects you to be able to show your reasoning: what the chemical is, why you believe it sits on or off the Inventory, what exposure and volume assumptions you used. This record is what you would pull out if anyone ever asked you to justify the categorisation, so treat it as a living document, not a one-time form you file and forget.

Where soap and small-batch makers get tripped up

Two mistakes show up constantly with smaller operations:

• Treating a supplier's marketing name as the chemical identity, then miscategorising because the real components never got identified.
• Assuming a fragrance blend is a single low-exposure ingredient when it is actually a dozen components, some of which may not be on the Inventory at all.

Both mistakes come from doing categorisation before doing ingredient identification. Reverse that order and most of the risk disappears.

A quick reference table

Step	Question you're answering	Why it matters
Identify	What is this ingredient, chemically	You cannot categorise a trade name
Inventory check	Is it already listed	Known chemicals carry different weight than novel ones
Exposure	How will people encounter it	Leave-on versus rinse-off changes the picture
Volume	How much are you introducing	Small batches and industrial runs are not treated alike
Category assignment	Which introduction category fits	Determines your ongoing obligations
Recordkeeping	Can you justify the above	AICIS expects documented reasoning, not a guess

Australia's system is genuinely different enough from the notification-based markets that it is worth treating as its own project rather than an afterthought tacked onto a Canadian or EU filing. Cosmetic Comply is building out Australian support as part of expanding beyond Canada, precisely because this ingredient-first, chemical-identity-first workflow is where most of the actual labor lives, and it is the same groundwork, done properly, that makes every other market's filing faster too.