AICIS Recordkeeping: What to Keep and for How Long

I get asked a version of this question constantly by makers moving into the Australian market for the first time: if AICIS doesn't require a per-product notification the way Health Canada does, what exactly am I supposed to be keeping on file? The answer is that AICIS shifts the paperwork burden from a filing event to an ongoing record you maintain yourself, and that record is what an inspector or audit will ask for.

AICIS works differently from a per-product notifier

AICIS, the Australian Industrial Chemicals Introduction Scheme, regulates cosmetic ingredients as industrial chemicals through an Inventory and a set of introduction categories, rather than requiring a notification for each finished cosmetic product the way Canada's CNF process does. You self-assess which category your ingredient introduction falls into, based on factors like whether the chemical is already listed on the Inventory, the volume you're introducing, and the risk profile of the substance.

Because there's no per-product filing confirming your assessment, the burden sits on you to have documented, defensible reasoning for the category you chose, and to keep that documentation ready if it's ever requested.

What records actually matter

Categorisation records. For every industrial chemical you introduce, including cosmetic ingredients, you need records showing how you determined the correct introduction category. That means documenting the chemical's identity, whether you checked it against the Inventory, and the specific criteria that led you to your category decision. If your reasoning was "this ingredient is a common botanical extract already used widely," that's not enough on its own. You need the actual assessment trail.

Introduction records. Separate from categorisation, you need records of the actual introduction itself: what was introduced, in what volume, and when. This is what ties your paper categorisation back to real activity.

Supporting technical information. Anything you relied on to make your categorisation call, safety data sheets, supplier documentation, toxicological information, or risk assessments, should be kept alongside the categorisation record itself, not filed separately where it might get lost or disconnected from the decision it supports.

How long to hold onto it

The general expectation under AICIS is that these records need to be retained for a defined period after the introduction, and five years is the retention window most businesses plan around. Practically, that means if you introduced a cosmetic ingredient under a particular category in a given year, you should be able to produce your categorisation reasoning and introduction records for that ingredient for five years afterward, not just at the moment of introduction.

Since AICIS requirements and specific retention obligations can be updated, treat five years as the planning baseline and verify the current requirement against AICIS guidance directly before you assume your records program is fully compliant.

A simple record structure that holds up

Record type	What it should contain	Kept alongside
Categorisation record	Chemical identity, Inventory check result, category determination and reasoning	Introduction record
Introduction record	Volume introduced, date, importer or manufacturer details	Categorisation record
Supporting technical file	SDS, supplier documentation, any risk or toxicological data used	Both records above
Review log	Any date the categorisation was reassessed, e.g. after a formula or volume change	Categorisation record

Practical habits worth building now

• Set up a folder or system per ingredient, not per finished product, since AICIS's unit of regulation is the industrial chemical, not the cosmetic SKU.
• Revisit your categorisation whenever your import volume changes meaningfully or you switch suppliers for a raw material, since either can shift which category applies.
• Don't treat "I've been importing this for years without an issue" as a substitute for having the actual categorisation paperwork on hand. Recordkeeping obligations exist regardless of how long you've operated without a request for them.

Cosmetic Comply's Australian filing support is on the way as part of expanding beyond Canada, and the same ingredient-mapping approach, matching each raw material to its correct identity and screening it properly, applies well to getting AICIS categorisation right from the start rather than reconstructing it after the fact.