{"id":5734,"date":"2026-09-09T11:48:18","date_gmt":"2026-09-09T01:48:18","guid":{"rendered":"https:\/\/argylllaw.com\/?p=5734"},"modified":"2026-09-09T11:49:06","modified_gmt":"2026-09-09T01:49:06","slug":"aicis-review-industrial-chemicals-australia","status":"publish","type":"post","link":"https:\/\/argylllaw.com\/de\/aicis-review-industrial-chemicals-australia\/","title":{"rendered":"Selling Chemical Products in Australia? Your AICIS Review Starts With the Ingredients"},"content":{"rendered":"

If you import industrial chemicals into Australia for commercial purposes \u2014 either on their own or as ingredients in finished products \u2014 you need to deal with the Australian Industrial Chemicals Introduction Scheme (AICIS)<\/a>.<\/p>\n

The mistake we see most often is treating AICIS as a product registration exercise.<\/p>\n

It isn’t.<\/p>\n

If you import a cosmetic, cleaning product, lubricant or other formulation<\/a> containing a number of industrial chemical ingredients, AICIS looks at the individual chemical introductions. Each relevant industrial chemical ingredient needs to be considered separately.<\/p>\n

That misunderstanding becomes expensive when it is discovered after the goods have been shipped. We have seen shipments held at the Australian border for months while the chemical ingredients and their AICIS status are worked through.<\/p>\n

By then, freight has been paid, customers are waiting and the Australian launch is already under pressure.<\/p>\n

The better time to establish the AICIS position is before your first commercial shipment.<\/p>\n

What does AICIS regulate?<\/h2>\n

AICIS regulates the import and manufacture of industrial chemicals in Australia.<\/p>\n

Industrial chemicals include chemicals used in cosmetics, soaps, cleaning products, paints, inks, adhesives, lubricants, plastics and many other commercial and consumer applications.<\/p>\n

AICIS regulates the industrial chemical being introduced<\/b>, rather than the finished formulation as a single regulatory item. For a mixture or product containing more than one industrial chemical, the introduction of each relevant chemical needs to be categorised separately.<\/p>\n

Take a cosmetic containing 20 industrial chemical ingredients. You are not asking whether \u201cthe cosmetic\u201d is on the Australian Inventory of Industrial Chemicals. You need to establish the Australian position for the individual industrial chemical ingredients in the formulation.<\/p>\n

The same principle applies where one ingredient appears across several of your products.<\/p>\n

Before you start looking at the Australian Inventory or AICIS introduction categories, you therefore need reliable chemical identity information for the formulation.<\/p>\n

A product name, trade name, INCI name or overseas marketing description does not necessarily give you the information needed to search the Inventory. AICIS recommends searching by CAS number or CAS name.<\/p>\n

Which chemicals fall under AICIS?<\/h2>\n

AICIS regulates chemicals introduced for industrial use.<\/p>\n

Chemicals introduced solely for therapeutic use<\/a>, agricultural or veterinary use, food<\/a> or animal feed are dealt with under the relevant specialist regulatory regime rather than AICIS. To learn more about which regulatory regimes might apply to your product, see our video:Which regulatory bodies govern your products in Australia?<\/a><\/p>\n

Cosmetic ingredients, cleaning chemicals, paints, adhesives, inks, lubricants and many other chemicals used in household and commercial products fall within industrial use.<\/p>\n

You therefore need to establish the intended Australian use before working through the AICIS position.<\/p>\n

The same chemical can have different uses. If you introduce it for an industrial use, the industrial introduction needs to comply with AICIS even if that chemical is also used for a therapeutic or other non-industrial purpose elsewhere.<\/p>\n

We already sell the product in Europe or the United States. Is that enough?<\/h2>\n

No.<\/p>\n

Australia has its own regulatory system for industrial chemicals.<\/p>\n

European or US compliance does not establish the Australian position. An overseas registration or assessment does not replace the work required under AICIS.<\/p>\n

Your overseas regulatory work is still valuable. Chemical identity, composition, concentration, hazard data, intended use and existing assessment information provide useful information for the Australian review.<\/p>\n

But Australia has its own Inventory, its own introduction categories and its own requirements.<\/p>\n

If your regulatory team has already completed the European or US work, use that information as the starting point for the Australian review \u2014 not as evidence that the Australian requirements have been satisfied.<\/p>\n

AICIS recognises specified overseas assessments under particular pathways. It does not adopt overseas registrations wholesale.<\/p>\n

So a product that has been successfully sold in Europe or the United States for years still needs an Australian AICIS review before you start importing its industrial chemical ingredients into Australia.<\/p>\n

Who is responsible for AICIS compliance in Australia?<\/h2>\n

You need to establish who the introducer is before your first shipment.<\/p>\n

The introducer is the person or business importing the industrial chemical into Australia or manufacturing it here.<\/p>\n

If your Australian distributor or agent imports your products, that Australian business is the introducer. It registers with AICIS and is responsible for the compliance and reporting obligations for those introductions.<\/p>\n

If your overseas company imports directly into Australia, different registration arrangements apply. A foreign business registering directly with AICIS needs to either set up an Australian subsidiary<\/a> to hold that registration or get an Australian Registered Body Number (ARBN) as the introducer must be an Australian resident entity or individual.<\/p>\n

This should be settled when you establish your Australian distribution and import arrangements.<\/p>\n

It also has a practical consequence. The introducer needs access to enough information to establish and support the AICIS position for the chemical introductions.<\/p>\n

That becomes difficult if the Australian distributor is expected to take responsibility for AICIS compliance but does not know the chemical identity or concentration of ingredients in a confidential overseas formulation.<\/p>\n

If the importer is registered with AICIS, are we covered?<\/h2>\n

No.<\/p>\n

This is the second misconception worth clearing up.<\/p>\n

You register the introducer. Registration does not approve the chemicals being introduced.<\/b><\/p>\n

AICIS itself describes registration as registration of the business, not of products or chemicals.<\/p>\n

After registration, the introducer still needs to establish the correct AICIS category for each industrial chemical introduction.<\/p>\n

The five main categories are:<\/p>\n