Categorising a Face Serum Step by Step Under AICIS

Let's build a face serum and walk it through AICIS the way you'd actually do it, ingredient by ingredient, rather than talking about the system in the abstract.

The formula

Say your serum looks like this:

INCI name	Function	% in formula
Aqua	Solvent	70.0%
Glycerin	Humectant	10.0%
Niacinamide	Active	5.0%
Propanediol	Humectant	5.0%
Sodium Hyaluronate	Active	1.0%
Phenoxyethanol	Preservative	0.8%
Xanthan Gum	Thickener	0.3%
Fragrance (Parfum)	Fragrance	0.2%
Citric Acid	pH adjuster	0.2%

Nine ingredients, nothing exotic. This is a good stand-in for the kind of serum a lot of independent makers are formulating right now.

Step 1: Remember AICIS regulates ingredients, not the finished product

This is the part that trips people up coming from Canada or the EU. Health Canada's CNF and the EU's CPNP both work at the finished product level. You notify a product, list its ingredients by INCI name, and get a number back. AICIS works differently. It's Australia's scheme for industrial chemicals, and cosmetic ingredients fall under it as industrial chemicals. So the categorisation exercise isn't "is this serum compliant," it's "what does the introduction of each ingredient into Australia require."

Step 2: Check each ingredient against the AICIS Inventory

The Inventory is the master list of chemicals already assessed and permitted for introduction in Australia. For each of the nine ingredients above, the first question is whether it's already listed there.

• Aqua, Glycerin, Propanediol, Xanthan Gum, Citric Acid: these are common, well-characterized chemicals with long histories of use. They're the kind of ingredient you'd expect to find on the Inventory already.
• Niacinamide, Sodium Hyaluronate, Phenoxyethanol: also widely used and likely to have existing Inventory records, but this is exactly the kind of thing you verify rather than assume, since Inventory status is specific to the actual substance and its identity details.
• Fragrance (Parfum): this is a supplier blend, not a single substance, so it needs to be broken into its actual components before you can check anything. A parfum blend might contain a dozen individual chemicals, and each one needs its own Inventory check.

Step 3: Break down the fragrance blend

This step gets skipped constantly and it shouldn't. A supplier's parfum blend is a mixture of individual chemicals at various concentrations within that blend. If your 0.2% Parfum addition is, say, 15% Limonene by weight inside the blend, then Limonene's actual concentration in your finished serum is 0.2% times 15%, which is 0.03%. That real figure, not the blend percentage, is what matters for categorisation and for allergen thinking generally.

Ask your fragrance supplier for the component breakdown. Reputable suppliers provide this, sometimes under confidentiality terms that still let you extract percentages for compliance purposes.

Step 4: Determine the introduction category for each substance

AICIS uses introduction categories that scale regulatory scrutiny to risk, rather than treating every chemical the same way. Categories are shaped by factors like:

• Whether the chemical is already on the Inventory
• The volume being introduced
• The hazard profile of the substance
• The exposure situation (a leave-on facial serum touching skin daily is a different exposure story than an industrial solvent used in a closed system)

A well-characterized, high-volume, low-hazard ingredient like glycerin sits in a very different category than a newly-introduced novel chemical with limited toxicology data. Most of the ingredients in a straightforward serum formula, being common cosmetic staples, are likely to land in lower-scrutiny categories, but "likely" isn't a substitute for actually checking.

Step 5: Document what you did and why

Even when every ingredient turns out to be Inventory-listed and lands in a routine category, keep a record of the categorisation exercise itself. What you checked, when, against what version of the Inventory. AICIS requirements and the Inventory itself get updated, and a categorisation done today isn't a permanent stamp on the formula if you reformulate or if an ingredient's status changes.

Where this differs from a CNF-style filing

If you're used to Health Canada's model, the mental shift is that AICIS doesn't hand you a single number for the finished serum. You're not filing "Serum X" and waiting for approval. You're working through each ingredient's introduction requirements, and the finished product's compliance is really the sum of those individual determinations.

Cosmetic Comply currently handles this kind of ingredient mapping and screening for Canada's CNF process, matching every ingredient to its INCI name and CAS number and expanding supplier blends like that parfum example into their real components. Australian AICIS support is on the roadmap, and the underlying groundwork, knowing your true component percentages, is exactly the same work either market asks of you.