How to Record Your AICIS Categorisation Decision

AICIS works differently from a lot of other cosmetic regimes, and that difference trips people up. Instead of notifying a finished product, Australia's Australian Industrial Chemicals Introduction Scheme regulates the ingredients themselves as industrial chemicals, through an Inventory and a set of introduction categories. You, as the importer or manufacturer, work out which category your introduction falls into based on things like whether the chemical is already listed on the Inventory, its volume, and its risk profile. That's a self-assessed decision, and it needs a paper trail.

Why the record matters more than the decision itself

A lot of makers focus all their energy on getting the categorisation right and treat the record of how they got there as an afterthought. That's backwards. If AICIS ever asks you to justify a categorisation, what saves you isn't just having landed on the correct category, it's being able to show, on paper, the specific facts and reasoning that led you there. A correct answer with no supporting record looks the same as a guess from the outside.

What a defensible record should contain

Think of this as the file you'd hand to an auditor with no other context, and it should stand on its own.

• Chemical identity. The specific substance name, and where possible its CAS number, since some botanical or complex substances may not have one and that itself is worth noting explicitly rather than leaving blank.
• Inventory check. Whether the chemical was already on the Inventory at the time of your check, with a date stamp, because Inventory status can change and "it was listed when we checked" is a meaningful defense.
• Volume calculation. How you arrived at your introduction volume figure, including the underlying sales or production estimate, since category often depends on volume thresholds.
• Category selected and why. Not just "Category X" but the specific criteria that pointed you there, referencing the actual categorisation factors you considered.
• End use description. How the chemical is actually being used in your product, since end use can affect categorisation.
• Date and person responsible. Who made the call and when, so it's clear this wasn't retroactively assembled after a problem surfaced.
• Source documents referenced. Supplier certificates of analysis, safety data sheets, or prior correspondence with AICIS that informed the decision.

A simple table format that works

Field	What to record
Chemical name / CAS	Full identity, note if no CAS exists
Inventory status at time of check	Listed / not listed, with check date
Estimated introduction volume	Figure and how it was calculated
Category determined	Category name plus the specific criteria met
End use	Actual application in your product
Supporting documents	SDS, supplier COA, correspondence
Decision maker and date	Name and date of record creation
Review date	When you'll re-check this categorisation

Why the review date line matters

Categorisation isn't necessarily a one-time decision that stays valid forever. If your introduction volume grows significantly, if you change suppliers, or if the chemical's Inventory status changes, your original categorisation might no longer hold. Building in a review date, even an informal annual check, shows a pattern of ongoing diligence rather than a single decision made once and never revisited.

Where makers get caught out

The most common gap isn't a wrong categorisation, it's an undocumented one. Someone worked it out correctly in their head, or on a phone call with a supplier, and never wrote it down anywhere retrievable. Six months or two years later, when it actually gets asked about, there's nothing to show. The second most common gap is treating the record as a one-line note ("Category 2, low volume") without the underlying reasoning, which doesn't hold up the same way a fuller record does.

Since AICIS categorisation criteria and thresholds are the kind of detail that can be updated, always confirm current volume thresholds and category definitions directly against the AICIS guidance before finalizing a record, rather than relying on last year's numbers.

Building this into your workflow

If you're managing more than a couple of products, it's worth treating this record as a living document per ingredient rather than per product, since the same industrial chemical might show up across several of your formulations and you don't want to redo the categorisation reasoning from scratch each time. Cosmetic Comply's ingredient mapping work, tracing INCI names to CAS numbers and tracking concentrations, is built around a similar principle: get the identity and quantity right once, in a retrievable place, and reuse that record with confidence across every product it touches. Australia notification support is on the roadmap alongside Canada, which is live today.

A categorisation decision without a written record is just a guess that happened to be right, at least until someone asks you to prove it.