Import Versus Manufacture: How AICIS Treats Each

A maker based in Australia asked me something that seemed like a reasonable assumption: since she sources every ingredient locally and blends everything herself, does she even need to think about AICIS the way an importer would? The short answer is yes, and the reason is that AICIS doesn't regulate cosmetics the way Health Canada or the FDA does. It regulates chemicals, and both bringing a chemical into Australia and making one here count as introducing it.

AICIS thinks in chemicals, not products

This is the part that trips people up coming from a Canada or US mental model. There's no per-product notification form under AICIS the way there is with Canada's CNF. Instead, the Australian Industrial Chemicals Introduction Scheme regulates the industrial chemicals that go into your cosmetic, including through an Inventory of existing chemicals and a set of introduction categories that determine what obligations attach to bringing a new or existing chemical into commercial use.

Practically, that means your compliance question under AICIS isn't "have I notified this product" but "has each chemical in this formula been properly introduced, and under which category." A formula built entirely from Inventory-listed chemicals used within their existing terms is a very different situation from one containing something not yet on the Inventory.

Import: the more obvious trigger

If you're bringing a raw material, a finished blend, or a finished cosmetic product into Australia from overseas, you are introducing an industrial chemical, and AICIS obligations attach to you as the importer. This is the scenario most people expect to be regulated, and it usually is treated that way without much surprise.

Manufacture: the one people underestimate

Here's the part worth sitting with. If you buy your ingredients from an Australian supplier and blend them yourself in Australia, using nothing imported, you can still be "introducing" a chemical under AICIS if the act of manufacturing creates a chemical that wasn't previously introduced in that form. Combining raw materials into a new mixture, or reacting them to form something with a different identity, can be treated as a manufacture-based introduction of a chemical, not just a product formulation step.

This is genuinely different from Canada's approach, where blending compliant raw materials at home doesn't itself trigger a fresh notification obligation the way introducing a new chemical does under AICIS. Under the AICIS framework, both routes, import and local manufacture, keep you inside the same regulatory question: has this chemical been properly introduced, and does your activity fit within a category that doesn't require further reporting.

Why the distinction still matters even though both are regulated

Even though both import and manufacture are captured, the specific obligations, recordkeeping requirements, and introduction categories that apply can differ depending on which one describes your situation, and depending on whether the chemical in question is already on the Inventory or is genuinely new to the Australian market. A maker importing a novel synthetic active is in a materially different position than one manufacturing a soap using long-established, Inventory-listed fatty acid salts. Because the categories and thresholds here are specific and do get revisited, this is an area worth confirming against the current AICIS guidance directly rather than assuming your situation matches a similar-sounding case you read about.

What this means day to day for an Australian maker

• Don't assume "I only use local ingredients" gets you out of thinking about AICIS entirely. The framework catches introduction by manufacture as well as by import.
• Keep a record of where each ingredient came from and whether it's a raw material used as-is or something you're combining into a new mixture.
• If you're using ingredients that are well-established and already on the Inventory, in their existing form, at ordinary use levels, you're likely in a more straightforward category than someone introducing something genuinely novel.
• When in doubt, especially with a new or unusual ingredient, checking the current Inventory and category guidance directly saves you from an assumption that doesn't hold up.

Cosmetic Comply's Canada filing is live today, with the US, EU, and Australia support on the way. Australia's framework is different enough in structure, chemicals and introduction categories rather than a single per-product notification, that it's being built to reflect that difference rather than force AICIS into a CNF-shaped box. If you're formulating for the Australian market now, it's still worth building the habit of documenting your ingredient sourcing and any local blending steps clearly, since that record is exactly what an AICIS assessment will eventually ask you for.