Recently, the Australian Industrial Chemicals Introduction Scheme (AICIS) released a comprehensive new "Guide to Applying for an Assessment Certificate", designed to help both Australian domestic and overseas businesses improve the quality and completeness of their assessment certificate applications. For cosmetics companies exporting to Australia, this guide has direct practical relevance — in Australia, industrial chemicals used in cosmetics (such as preservatives, surfactants, colorants, fragrance ingredients, etc.) all fall under AICIS jurisdiction, and companies must complete chemical categorisation and fulfill corresponding compliance obligations before importing or manufacturing.
Background: Five Categories of Chemical Introduction Under AICIS
In Australia, all importation and manufacture of industrial chemicals (including cosmetic chemicals) must be categorised. Companies need to review each industrial chemical in their products and assign it to one of the following five categories:
| Category | Risk Level | Key Requirements |
| Listed Introduction | Lowest | The chemical is already on the Australian Inventory; requires registration and submission of annual declaration; no fees |
| Exempted Introduction | Very Low | Must meet strict low-risk criteria; no pre-introduction notification required; records must be kept and annual declaration submitted; some require a one-time post-introduction declaration; no fees |
| Reported Introduction | Low | Requires submission of a one-time pre-introduction report before introduction; records must be kept and annual declaration submitted; no fees |
| Assessed Introduction | Medium to High | Must apply to AICIS for an assessment certificate; introduction is permitted only after approval; fees apply; the chemical is added to the Inventory 5 years after certificate issuance |
| Commercial Evaluation | Apply for a time-limited commercial evaluation authorisation to test commercial viability of a chemical; fees apply; the chemical will not be added to the Inventory |
Cosmetics companies should pay special attention: If a product contains a new chemical not listed on the Australian Inventory, and that chemical poses a medium to high risk to human health or the environment, an Assessment Certificate must be obtained before the chemical can be legally imported or manufactured in Australia.
Key Contents of the New Guide
The newly released Guide to Applying for an Assessment Certificate comprises 9 chapters and appendices, with core content covering:
1. Information required for each application type: Clarifies the data requirements for different types of assessment certificates;
2. Pre-application checklist: Helps companies confirm all necessary preparations are in place before creating an application;
3. Confidentiality and data ownership: Explains mechanisms for protecting commercially confidential information and data rights attribution;
4. Roles and permissions of involved parties: Clarifies the responsibilities of applicants, data providers, authorised representatives, and other parties;
5. Creating IUCLID chemical datasets: Guides companies on using the IUCLID platform to compile chemical dossiers;
6. Application submission and payment process: Provides operational instructions for submitting applications online via AICIS Business Services;
7. Post-application process: Covers requests for additional information that may be received during the evaluation and publication of assessment outcomes.
The statutory assessment timeframe is 70 business days. Additionally, AICIS has announced that a dedicated IUCLID operation guide will be released soon to help companies with dataset creation, mandatory field completion, and submission validation.
Key Points for Cosmetics Companies
1. Restrictions on Animal Test Data for Cosmetic Chemicals
Chapter 3 of the guide ("Using new animal test data for chemicals in cosmetics") specifically addresses the requirements for using new animal test data for cosmetic chemicals. Australia imposes strict restrictions on animal testing of cosmetic chemicals. When submitting an assessment certificate application, companies should prioritise alternative methods (such as in vitro tests, computational toxicology approaches, etc.) and avoid unnecessary new animal testing. This requirement aligns with the global cosmetics industry trend toward "cruelty-free" practices, and cosmetics companies should pay particular attention when preparing their data packages.
2. Categorisation of Cosmetic Chemicals
In Australia, chemicals used in cosmetics (including personal care products, skincare, bath products, colour cosmetics, etc.) are all classified as industrial chemicals and are subject to AICIS regulation. Companies should first confirm whether the chemicals in question are listed on the Australian Inventory:
- If already on the Inventory → Treated as a Listed Introduction, with lower compliance requirements;
- If not on the Inventory → Risk-level assessment is needed to determine whether the chemical falls under the Exempted, Reported, or Assessed category. Medium-to-high-risk chemicals must have an assessment certificate application.
3. IUCLID Dataset Compilation
Assessment certificate applications require the compilation of chemical datasets through the IUCLID platform. AICIS has also announced that a dedicated IUCLID operation guide will be released soon to help companies with dataset creation, mandatory field completion, and submission validation. Cosmetics companies are advised to familiarise themselves with the IUCLID system in advance to ensure proper data compilation.
4. Upcoming Categorisation Guideline Updates
AICIS has announced that the latest revisions to the Industrial Chemicals Categorisation Guidelines will take effect in September 2026. Cosmetics companies should monitor changes to the categorisation criteria and adjust their compliance strategies accordingly.
CIRS Reminder
The release of this AICIS assessment certificate application guide provides a clear operational pathway for cosmetics companies planning to export to Australia. Companies are advised to focus on the following:
- Conduct a comprehensive review of all chemical ingredients in product formulations and confirm their status on the Australian Inventory;
- For new chemicals not on the Inventory, complete risk categorisation as soon as possible to determine whether an assessment certificate application is needed;
- If an assessment certificate is required, refer to the new guide to prepare a complete chemical dataset in advance, paying particular attention to compliance requirements for animal test data;
- Closely monitor the categorisation guideline updates taking effect in September 2026, and promptly assess the impact on existing product compliance status.
If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.
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