Anyone importing cosmetics into Australia must register with AICIS and lodge an annual declaration by 30 November. Here's what's required — and who's caught.

If you import cosmetics, you are almost certainly an "introducer"

Here is a fact that catches out more brands than it should: almost every ingredient in a cosmetic — including the ones labelled "natural" and "organic" — is regulated in Australia as an industrial chemical. That means if you import a finished cosmetic from overseas to sell here, you are introducing industrial chemicals into the country, and the Australian Industrial Chemicals Introduction Scheme (AICIS) applies to you.

There is no minimum threshold. It doesn't matter whether you import one pallet or a container-load — you must register your business with AICIS before you import, not after your first sale.

The three things AICIS expects of you

Compliance comes down to three recurring obligations. Miss any of them and you are exposed:

  • Register before you import. Registration runs on a set year, 1 September to 31 August, and must be renewed each year. You cannot lawfully introduce chemicals without it.
  • Categorise every introduction. Each chemical you bring in has to be sorted into one of the scheme's introduction categories — listed, exempted, reported, assessed, or commercial evaluation — each with its own legal definition and obligations. Getting the category right determines what you must do before the product can enter the country.
  • Lodge an annual declaration by 30 November. After each registration year ends, you must declare that everything you introduced was properly authorised. The deadline is 30 November every year, and it comes around faster than most businesses expect.

The annual declaration trap

The annual declaration is where otherwise-diligent importers slip up, for two reasons.

First, timing. You can only lodge the declaration after the registration year closes at the end of August — so the window to complete it runs across spring, with a hard 30 November cutoff. It is easy to file away as "later" until later becomes urgent.

Second — and this is the part many businesses don't realise — the declaration is a formal statement that every chemical you introduced during the year was authorised under the Industrial Chemicals Act. If some weren't, the declaration forces the issue. It is not a rubber stamp; it is a year-end reckoning. And the responsibility to lodge it sits with the registered introducer itself — it is your legal obligation as the business, however we can certainly assist you by doing all the heavy lifting - categorising your ingredients, tallying your yearly tonnages and then simplifying the declaration process itself!

Who needs to pay attention

You are squarely within AICIS if you:

  • Import finished cosmetics or personal care products for sale in Australia, at any volume
  • Manufacture cosmetics locally using imported ingredients
  • Have recently started importing and haven't yet registered
  • Are unsure whether every ingredient in your range is on the Australian Inventory of Industrial Chemicals, or introduced under a valid category

That last point is where the real work sits. Confirming each ingredient is either on the Inventory or lawfully introduced under the right category — and keeping the records to prove it — is the substance behind a clean annual declaration.

How Engel Hellyer & Partners helps

We have worked with AICIS and its predecessor scheme since it began, and we help importers stay on the right side of all three obligations: getting registered, categorising introductions correctly, screening ingredients against the Inventory, and making sure the year-end declaration is something you can sign with confidence rather than anxiety.

If you import into Australia and you're not completely certain your AICIS obligations are covered — particularly with the 30 November declaration deadline ahead — a short review is worth far more than the discomfort of finding a gap after the fact.

If that would be useful, we're happy to take a look.

This article is general information only and does not constitute regulatory advice for any specific product or business. Requirements change; confirm the current position before acting.

Further reading

Primary guidance from AICIS:

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Written by 
Dr Gloria Mao
Has over 15 years of international experience in the food, complementary medicine and cosmetic industries. She received her doctorate from the University of California, Los Angeles in Toxicology and Pharmacology. She received her Masters of Arts in Biochemistry and Molecular Biology from Harvard University and her Bachelors of Science in Biochemistry from the University of Illinois.