Assessed Introductions: When Full AICIS Review Is Required

Most cosmetic ingredients heading into the Australian market move through AICIS without needing anyone to sit down and formally assess them one by one. AICIS sorts introductions into risk-based categories, and a lot of everyday cosmetic ingredients, especially ones already well-characterized and used at typical cosmetic concentrations, land in lower categories that don't require a full assessment before you proceed. But some introductions do trigger that higher bar, and it's worth understanding what pushes a substance into that tier before you're surprised by it mid-launch.

Why AICIS uses categories instead of one-size-fits-all review

AICIS regulates cosmetic ingredients as industrial chemicals through an Inventory and a category-based introduction system rather than requiring a per-product notification for every single cosmetic the way some other markets do. The logic is risk-proportionate: a well-known, low-hazard ingredient introduced in a way that matches how it's already used safely elsewhere shouldn't need the same scrutiny as a genuinely novel substance, or one being introduced at a much higher volume or in a use pattern that raises different exposure questions.

That category system is what lets the vast majority of routine cosmetic formulation work move forward without a bottleneck, while reserving deeper scrutiny for the cases that actually warrant it.

What tends to push an introduction into the higher tier

Without a full assessment certificate, an introduction generally can't proceed once it's identified as falling into the categories that require it. Broadly, the kinds of factors that tend to raise a substance's risk categorization include:

• Novelty. A substance genuinely new to the Australian inventory, without an existing track record, naturally invites more scrutiny than something already listed and used safely.
• Hazard profile. Substances with known or suspected higher hazard characteristics get more attention regardless of how they're going to be used.
• Volume and exposure pattern. How much of the substance is being introduced and how people are likely to be exposed to it (a leave-on facial product versus an occasional-use rinse-off product, for instance) factors into the risk picture.
• End use context. Some uses inherently involve broader or more direct human exposure than others, which shifts the risk calculation even for an otherwise familiar substance.

Because the exact category thresholds and criteria are detailed and can be updated by AICIS over time, this is a case where checking the current AICIS guidance directly, or working with someone who tracks it closely, is genuinely the right move rather than relying on a rule of thumb from a blog post.

What an assessed introduction actually involves

When a substance does require an assessment certificate, the general shape of the process involves:

1. Preparing an application that characterizes the substance, its intended use, and available hazard and exposure information.
2. Submitting that application to AICIS for review.
3. AICIS assessing the risk based on the submitted information, which can involve back-and-forth requests for additional data.
4. Receiving an assessment certificate once the review concludes, which then allows the introduction to proceed under whatever conditions the certificate specifies.

This is a materially heavier lift than the lower categories, both in the information you need to gather up front and the time it takes to get a result, so it's worth identifying early in product development if there's any chance an ingredient might fall into this tier, rather than discovering it right before a planned launch.

A simplified comparison

Introduction type	Typical scrutiny level	Timeline expectation
Well-characterized, low-risk, matches existing use pattern	Lower category, minimal upfront review	Fastest
Higher volume or altered exposure pattern for a known substance	Mid-tier category	Moderate
Novel or higher-hazard substance	Requires assessment certificate	Longest, involves formal application and review

What to actually do if you're unsure

If you're working with an ingredient supplier on something genuinely new, a novel active, an unusual delivery ingredient, or a substance you haven't seen used in cosmetics in Australia before, flag it early and ask directly whether it's likely to require an assessed introduction. Waiting until your formula is finalized and your launch date is set is the wrong time to find out you need a formal certificate first.

For the more routine side of the equation, ingredient mapping, INCI and CAS identification, and screening against restricted substance information, Cosmetic Comply is expanding into the Australian market alongside its existing Canada notification workflow, so the groundwork of knowing exactly what's in your formula and how it's identified is handled well before you get anywhere near a category determination.