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AICIS and Fragrance Imports to Australia: Chemical Notification Guide

July 20, 2025 Aromiso Team 4 min read
AICIS and Fragrance Imports to Australia: Chemical Notification Guide

AICIS and Fragrance Imports to Australia: Chemical Notification Guide

Australia regulates industrial chemicals, including the aroma chemicals used in fragrance products, through the Australian Industrial Chemicals Introduction Scheme (AICIS), which replaced the old NICNAS system on 1 July 2020. AICIS is administered by the Department of Health and Aged Care. For B2B buyers importing scented candles, reed diffusers, essential oils, and room sprays into Australia, AICIS determines whether each chemical in a formulation can be legally imported and what notification or record-keeping duties apply.

Who Must Register

Under the Industrial Chemicals Act 2019 (Cth), any business that imports or manufactures industrial chemicals in Australia must register with AICIS before introducing those chemicals. Registration is an annual requirement and applies to the importing entity, not the foreign manufacturer. A Chinese fragrance factory has no direct AICIS obligation, but the Australian importer of record must be registered and must classify each chemical introduction correctly.

The definition of “industrial chemical” is broad and includes chemicals used in cosmetics, household products, and fragrance preparations. Chemicals used solely as food, medicine, or agricultural/veterinary products fall outside AICIS, but home fragrance and personal fragrance products are firmly within scope.

The Australian Inventory of Chemical Substances

The first compliance step is checking every ingredient against the Australian Inventory of Chemical Substances (the Inventory), which lists chemicals that have been assessed and can be introduced without separate notification, subject to any listed conditions. The Inventory contains more than 40,000 entries. Each fragrance component should be checked by its CAS number.

If a substance is listed on the Inventory with no conditions, it can be imported freely once the business is registered. If it is listed with conditions, such as a maximum concentration or a specific use restriction, the importer must comply with those conditions. If a substance is not on the Inventory, it is a new chemical and requires assessment or notification before import.

Introduction Categories

AICIS classifies every introduction into one of several categories, each with different obligations:

  • Listed: the chemical is on the Inventory with no conditions; no notification needed beyond registration and records.
  • Exempted: a low-risk introduction that meets strict criteria; the importer self-assesses and may need to apply for an exemption certificate.
  • Reported: a low-risk introduction requiring a one-off report to AICIS before import.
  • Assessed: higher-risk introductions, including many new chemicals, requiring a formal assessment certificate from AICIS before import. This process can take several months and requires a full data package.

Most established fragrance raw materials such as linalool (CAS 78-70-6), limonene (CAS 5989-27-5), and vanillin (CAS 121-33-5) are listed on the Inventory and can be imported without notification. The risk arises with novel aroma chemicals or specialty molecules not yet assessed in Australia.

Record-Keeping and Annual Declaration

Registered importers must keep records of their introductions for at least five years and submit an annual declaration to AICIS confirming the introductions made during the previous registration year. The annual declaration is mandatory even if no introductions occurred. Failure to register or to lodge the declaration can attract civil penalties under the Industrial Chemicals Act 2019, with infringement notices and enforceable undertakings available to the regulator.

Cosmetic and Consumer Product Overlap

Fragrance products that are applied to the body, such as perfumes and body mists, are regulated as cosmetics and must comply with the Standard for the Uniform Scheduling of Medicines and Poisons (the Poisons Standard) and the mandatory ingredient labeling requirements under the Competition and Consumer Act 2010 and the Australian Consumer Law. Home fragrance products such as candles and diffusers are consumer goods and must meet general product safety obligations, including the requirement not to supply goods with safety defects.

Certain fragrance allergens, including substances like hydroxycitronellal and cinnamal, may be subject to concentration limits or labeling disclosure when used in cosmetic products. Importers should align their formulation with both AICIS chemical rules and consumer product safety and labeling rules.

Practical Steps for Buyers

  1. Register your business with AICIS before the first import.
  2. Obtain a full CAS-level ingredient disclosure from your supplier.
  3. Check each substance against the Australian Inventory of Chemical Substances and note any conditions.
  4. Classify each introduction as listed, exempted, reported, or assessed.
  5. Complete any required reports or assessment applications before shipping.
  6. Maintain records for five years and lodge the annual declaration.
  7. Confirm consumer product safety and labeling compliance for the finished product.

How Aromiso Supports AICIS Compliance

Aromiso provides Australian buyers with complete composition statements, CAS numbers, and Safety Data Sheets aligned to the Globally Harmonized System as adopted in Australia (GHS Revision 7 under the Work Health and Safety Regulations). Our documentation enables importers to verify Inventory listings quickly and to classify each introduction accurately. For buyers developing custom fragrances, we flag any components that may be new chemicals requiring AICIS assessment, allowing compliance planning before production.

AICIS is a registration-and-classification system rather than a pre-market approval regime for most established chemicals, which makes Australian market entry efficient when documentation is in order. The key is accurate ingredient disclosure and disciplined record-keeping, both of which Aromiso builds into its standard export support.

#compliance #Australia #AICIS

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