AICIS Versus a Cosmetic Product Notification Compared

If you've filed a Cosmetic Notification Form with Health Canada, or you've watched a colleague submit through the EU's CPNP portal, your instinct in Australia will be to look for the equivalent per-product form. There isn't one. AICIS works on a completely different unit of regulation, and that trips up a lot of makers who assume every country runs the same playbook with a different logo on it.

What AICIS actually regulates

AICIS stands for the Australian Industrial Chemicals Introduction Scheme, and the word that matters there is "chemicals," not "cosmetics." AICIS doesn't ask you to notify a finished lip balm or a body scrub as a product. It asks about the individual industrial chemicals, meaning your ingredients, and whether each one is already recognized on Australia's Inventory of existing chemicals.

If every ingredient in your formula is already on the Inventory, in many cases you may not need to do anything further for those ingredients specifically under AICIS. If an ingredient isn't listed, you're introducing a new industrial chemical, and that triggers a categorization process based on risk, volume, and end use, not a product-level submission.

Why this trips people up

Canada's CNF and the EU's CPNP are both product-centric. You describe a specific formula, list its ingredients with concentrations, and the notification travels with that product. Renew the formula, refile.

AICIS flips the logic. The chemical is the thing being introduced into the Australian market, independent of which product it ends up in. So the same new ingredient used across five different products from five different brands is, from AICIS's perspective, one introduction question asked five separate times unless the ingredient has already cleared the Inventory. Once it's on the Inventory, later introductions by other makers get simpler.

Side-by-side comparison

	Canada (CNF)	EU (CPNP)	Australia (AICIS)
Unit of regulation	Finished product	Finished product	Individual industrial chemical
Filing trigger	First sale of the product	Placing product on market	Introducing a chemical not on the Inventory
What you submit	Formula, INCI list, concentrations	Formula, PIF, CPSR	Chemical identity, categorization info
Timing	Within 10 days of first sale	Before placing on market	Before introduction, category-dependent
Result	CN number	CPNP notification record	Inventory listing or exemption/certificate

What this means for a soap or skincare maker

Practically, your first job when eyeing the Australian market isn't "fill out a form for my moisturizer." It's "check every INCI name in my moisturizer against the AICIS Inventory." Most common cosmetic staples, things like glycerin, common plant oils, and widely used preservatives, are already on the Inventory because thousands of products have used them for years. Your risk usually concentrates on newer actives, novel extracts, or specialty ingredients from smaller suppliers who haven't gone through an Australian introduction before.

A few things worth doing before you assume you're clear:

• Get the exact INCI name and, where possible, the CAS number for every ingredient, including the ones hiding inside supplier blends.
• Check each one against the current Inventory rather than relying on what worked for a similar formula last year, since inventory status can change.
• If something is missing, don't panic and don't guess. AICIS has categories of introduction with different obligations depending on the volume you're bringing in and the risk profile of the chemical.

Where the confusion usually starts

Most of the frustration comes from applying muscle memory built in another market. If you've been through a CNF filing, you already know how to expand a supplier's trade-named blend into its individual INCI components and pull a percentage for each. That exact skill is what you need for AICIS too, just aimed at a different question: not "is this allowed at this concentration" but "has this chemical been introduced here before."

Cosmetic Comply already does that ingredient-to-INCI-to-CAS mapping work for Canadian filings, expanding blends and carrying percentages through automatically, and it's built with Australia's different structure in mind as that market comes online. If you're formulating with an eye on multiple countries, keeping a clean, INCI-mapped ingredient list from day one saves you from re-deriving it separately for each regulator later.