On July 14, 2026, the Australian Industrial Chemicals Introduction Scheme (AICIS) issued a notice confirming that, as Retinal (CAS No.116-31-4) has been classified as a developmental toxin, from June 27, 2026 the import or manufacture of Retinal for any consumer end use (including as a cosmetic ingredient) can no longer be authorized under the exempted category (very low risk) or the reported category (low risk), and introducers must apply for and obtain an AICIS assessment certificate before introduction.
Background
The import and manufacture of industrial chemicals (including cosmetic ingredients) in Australia are centrally administered by AICIS, which classifies chemical introductions (i.e., import or manufacture) into three risk-based categories: the exempted category (very low risk, no approval required), the reported category (low risk, reporting/record-keeping required), and the assessed category (an assessment certificate must be obtained).
Cosmetics and their ingredients are regulated as industrial chemicals under AICIS in Australia. AICIS recently completed a targeted human-health hazard assessment of Retinal and concluded that it has developmental toxicity, which triggered the recategorization described above.
Key Contents
1. Substance in Scope and Effective Date
The substance affected is Retinal (CAS No.116-31-4), and the requirement takes effect from June 27, 2026. Any introduction (import or manufacture) of Retinal with a consumer end use must be managed under the assessed category.
2. Why Retinal Now Requires Prior Assessment?
AICIS recently completed a targeted human-health hazard assessment of Retinal and concluded that it has developmental toxicity. As Retinal is thereby classified as a developmental toxin, introductions for consumer end use no longer meet the eligibility criteria for the exempted or reported categories, and an AICIS assessment and certificate are required before introduction.
3. Implications for Introducers
Before introducing (importing or manufacturing) Retinal for any consumer end use in Australia, introducers (importers and manufacturers) must apply for an AICIS assessment and obtain a certificate.
4. Retinol and Retinol Esters Are NOT Affected
This regulatory requirement does NOT apply to introductions of Retinol (CAS 68-26-8) or Retinol esters listed on the Australian Inventory of Industrial Chemicals (AIIC).
CIRS Reminder
AICIS's reclassification of Retinal from the exempted/reported categories to the assessed category has significant implications for the export to, and local manufacture in, Australia of cosmetics formulated with Retinal. CIRS Group offers the following reminders:
- Accurately distinguish the substance to avoid misjudgement: the substance affected is “Retinal”, NOT “Retinol”. Their Chinese and English names are highly similar and frequently confused. Companies should verify each formula item by CAS number and confirm the specific vitamin A derivative used, to avoid misjudging compliance obligations.
- Review formulas containing Retinal: for products such as serums, creams, and lotions that contain Retinal, import into or local manufacture in Australia must first be covered by an AICIS assessment certificate; the previous exempted/reported routes no longer apply.
- Monitor global regulatory trends for vitamin A derivatives: Retinol/Retinal-type ingredients remain under continued assessment and restriction discussions in markets such as the EU and ASEAN; companies operating across multiple markets should review them holistically.
If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.
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