Well it is has now been nearly two months since NICNAS transitioned to AICIS. We’ve lost the National Industrial Chemicals Notification and Assessment Scheme and gained the Australian Industrial Chemicals Introduction Scheme. There is a lot for everyone to grasp over the next two years – this is a transition period during which time importers and manufacturers can continue to rely on the old NICNAS provisions whilst also learning the new scheme and transitioning their ingredients across to AICIS.
AICIS Categorisation will become an activity that many chemical importers and manufacturers will need to become familiar with. We’ve been busy categorising our client’s ingredients into one of the six introduction categories: Listed, Exempted, Reported, Assessed, Commercial Evaluation, and Exceptional Circumstances.
Many ingredients will fall into the ‘Listed’ category – this includes any ingredient which is listed on the “Industrial Chemicals Inventory’ and where your introduction is in compliance with any conditions of use. For most purposes only the first three of the six categories will apply: Listed, Exempted, and Reported.
For non-inventory ingredients AICIS Categorisation will typically involve deciding whether the introduction is Exempted or Reported. There are pros and cons with both as there are different processes involved, different information and record keeping requirements, and possibly the risk of accidental compliance breaches if you categorise inappropriately.
We thought you might find this table useful to help you understand when the exempted category applies and when the reported category applies. This is only the first step – the next steps are to follow through with deciding whether your ingredient qualifies, the required record keeping requirements and also then creating the Pre-Introduction Reports for any ingredients that need to be Reported. We are that early into the process that there is no published method yet for declaring your exempted introductions to the regulator – stay tuned!
Need help with the new scheme? Whilst there is still plenty of time to transition to the new scheme there will also be a lot to familiarise yourself with! Please feel free to contact our office for a confidential no-obligation discussion.