Register With AICIS Before Your First Import: A Checklist

Australia does this differently than most makers expect coming from a Health Canada or FDA background, and the difference trips people up specifically because it looks similar on the surface but works on a different logic underneath. There's no per-product notification form to fill out for each SKU. Instead, AICIS, the Australian Industrial Chemicals Introduction Scheme, regulates the ingredients themselves as industrial chemicals, through an Inventory system and defined introduction categories. The registration step happens at the business and ingredient level, not the finished-product level, and it has to happen before anything crosses the border.

Here's the checklist, in the order it actually needs to happen.

1. Confirm you're the "introducer"

AICIS obligations attach to whoever is introducing the chemical into Australia, meaning importing or manufacturing it there. If you're a brand having a third party import on your behalf, get clear on who legally holds the introducer role before you assume it's automatically you or automatically them. This isn't a detail to sort out after the fact.

2. Register your business with AICIS

Before any introduction happens, the business itself needs to be registered with AICIS. This is a yearly obligation, not a one-time signup you forget about. Confirm your registration is active and current before you rely on it to cover a shipment.

3. Identify every ingredient against the Inventory

This is the step that actually takes time. Every ingredient in your formula needs to be checked against the AICIS Inventory to determine its status. Some ingredients will already be listed. Others might not be, and that changes what category of introduction applies to you.

Don't assume an ingredient is Inventory-listed just because it's common or because it's approved elsewhere. Canada's Hotlist status, EU status, or US usage doesn't automatically map onto Australian Inventory status. Check each one specifically.

4. Determine your introduction category

AICIS uses categories based on factors like the volume you're introducing, the ingredient's risk profile, and whether it's already on the Inventory, rather than a single blanket process for everyone. Your obligations, and how much detail you need to provide, depend on which category your introduction falls into. This is worth getting right early, since the requirements scale up meaningfully depending on category.

5. Handle blends and supplier formulations honestly

If you're importing a finished product or a supplier blend rather than raw ingredients you formulate with yourself, you still need visibility into what's actually in it at the INCI or chemical component level. Trade names and proprietary blend names don't satisfy an ingredient-level check. If your supplier won't share the actual composition, that's a real blocker to registering correctly, not a detail to route around.

6. Keep records that show your reasoning

Because this is a self-assessed category system rather than a single form a regulator reviews and stamps, your own records showing how you assessed each ingredient and category matter more than they might in a system with a formal per-product approval step. Keep documentation of your Inventory checks and category determination, not just a note that you "did AICIS stuff" at some point.

7. Reassess before you change formula or scale up volume

A formula change that introduces a new ingredient, or a significant increase in import volume, can shift your category or introduce a new ingredient-level check you haven't done yet. This isn't a one-and-done registration you set and forget. Build a habit of reassessing whenever the formula or volume changes meaningfully.

Quick reference

Step	What it actually confirms
Introducer identification	Who legally holds the AICIS obligation
Business registration	Your business is authorized to introduce chemicals at all
Inventory check per ingredient	Whether each ingredient is already listed
Category determination	Scale of obligation based on volume and risk
Blend transparency	Real ingredient visibility, not just trade names
Recordkeeping	Evidence of your self-assessment, since there's no per-product approval stamp

Why this is worth doing properly before the first shipment

Because AICIS works at the ingredient and business level rather than issuing a per-product approval, there's no single moment where a regulator tells you "yes, you're cleared." The system relies on you assessing correctly and keeping honest records. That makes the upfront checklist work more important, not less, since there's no external checkpoint catching an error for you later.

Cosmetic Comply's Canada notification workflow is live today, and Australia is on the roadmap alongside the US and EU. If you're currently juggling a Canadian Cosmetic Notification Form for the same product line you're prepping for AICIS, keeping your INCI names, CAS numbers, and concentrations organized in one place now means less redoing that groundwork market by market as more of them come online.