AICIS and Canada's CNF Are Two Different Systems

If you're selling into both Canada and Australia, you've probably assumed the two regulators want roughly the same thing from you. They don't. One cares about your product. The other cares about the chemicals inside it, and honestly not even in the way you'd expect.

Canada's CNF is about the finished product

Health Canada regulates cosmetics under the Food and Drugs Act and the Cosmetic Regulations. When you sell a cosmetic in Canada, you file a Cosmetic Notification Form (CNF) through the Cosmetic Notification System, and you have 10 days from first sale to do it. It's a notification, not a pre-market approval, meaning nobody signs off before you sell. But the filing is tied directly to your finished formula: every ingredient goes on the CNF by INCI name with its concentration or a concentration range, and the whole thing gets checked against the Cosmetic Ingredient Hotlist for anything prohibited or restricted.

Change the formula, and you file an amendment. Discontinue the product, and you file a discontinuation. The unit of regulation is the product.

AICIS is about the chemical, not the product

AICIS, the Australian Industrial Chemicals Introduction Scheme, works from a completely different angle. It doesn't ask "is this lotion safe" the way Health Canada's system implicitly does through ingredient screening. It asks whether each industrial chemical you're introducing into Australia is already on the Inventory, and if not, which introduction category it falls into based on factors like use pattern, volume, and hazard profile.

Cosmetic ingredients are industrial chemicals under this framework. So instead of filing your finished lotion, you're really tracking each chemical that goes into it, checking Inventory status, and categorizing your introduction accordingly. There's no per-product notification number the way there's a CN number in Canada. There's a chemical-level record, and depending on the category, potentially a duty to keep records or report rather than to submit anything for review.

Where the confusion actually bites

The mistake I see most often is a maker who's used to Canada's model trying to find "the AICIS number" for a product, the way they'd look for a CN number. It doesn't exist in that form. Similarly, a maker used to AICIS assumes Health Canada only cares about hazardous chemicals in bulk, and skips the CNF because "it's just a small-batch product." Canada doesn't have that carve-out. Small batch or not, first sale starts the 10-day clock.

Feature	Canada CNF	Australia AICIS
Unit of regulation	Finished product	Individual chemical
Filing trigger	First sale	Import or manufacture of the chemical
Timing	Within 10 days of first sale	Before introduction, tied to category
Output	CN number	Inventory listing / category record
Formula change	File an amendment	Reassess chemical status if new to you
Ingredient granularity	INCI name + concentration	Chemical identity, hazard, volume

Practical steps if you sell into both markets

1. Keep your ingredient list in INCI form with CAS numbers from day one. Both systems eventually want you mapped from trade names to real chemical identities, even though they use that information differently.
2. Track your Canadian filing per SKU. One CNF per formula, updated with amendments as needed, discontinued when you pull a product.
3. Track your Australian obligations per ingredient. Before you introduce a new-to-you raw material into Australia, check its Inventory status rather than assuming your Canadian compliance covers you.
4. Don't assume reciprocity. A clean Hotlist screen for Canada says nothing about AICIS categorization, and vice versa. They're solving different problems with different units of analysis.

A quick reality check on what changes

AICIS specifics, like which introduction category applies to your particular ingredient volumes, are exactly the kind of thing that shifts as your business grows or as the scheme's guidance is updated. If you're scaling past small-batch, it's worth confirming your current category directly with AICIS rather than assuming last year's assessment still holds.

For the Canadian side, Cosmetic Comply already handles the CNF workflow end to end: it maps your ingredients to INCI and CAS, screens against the Hotlist with a confidence score, has a real reviewer check the result, then files and hands you back a trackable CN number. If you're juggling both regulatory frameworks at once, at least the Canada half of your paperwork doesn't have to be a guessing game.