AICIS changed its chemical guidelines: what makeup artists importing products must re-check

Abby's take

What this means for the industry — and for independents

Industry impact. Small beauty businesses can become chemical introducers by importing cosmetics directly rather than buying through an Australian distributor. The September update changes a technical categorisation input, so old worksheets or supplier assurances may no longer be enough for a new introduction.

For freelancers. A makeup artist importing a small quantity for resale cannot rely on the order being branded, packaged or already sold overseas. AICIS says registration can apply regardless of how little is sold, and each relevant ingredient must be authorised under an applicable category.

What I'd do next

• Separate products bought from Australian suppliers from products the business imports directly, including low-volume and fully packaged overseas orders intended for sale.
• For each direct import, identify every relevant ingredient, the current AICIS category and the evidence or chemical data holder supporting that categorisation.
• Re-run any categorisation affected by the updated high-hazard list using the guide and guidelines in force from 1 September 2026.
• Keep registration, declarations, reports, supplier data and introduction records for the required period and obtain specialist advice where information is incomplete.

Watch-out. This is general regulatory information, not legal, chemical-safety or AICIS categorisation advice. Obligations depend on the product, ingredients, supply chain, end use and introduction circumstances.

What changed on 1 September 2026

AICIS released the 2026 Industrial Chemicals Categorisation Guidelines and updated its online categorisation guide with effect from 1 September 2026. The update added 293 entries to the high-hazard list, changed 122 existing entries, added five chemicals to specified developmental-toxicity information requirements and revised the definition of chemical identity holder.

These are categorisation changes, not a list declaring every affected cosmetic banned. Their practical effect depends on the chemical, concentration, use, exposure and the pathway the introducer is relying on.

Work out whether the business is the importer

AICIS says a business planning to sell cosmetics in Australia that it bought from overseas must register before importing, even when the products are branded and fully packaged or the quantity is small. Buying from an Australian wholesaler is different because another Australian business may be the introducer.

Map the invoice and shipping path for every overseas order. Marketplace listings, overseas brand websites and products carried into Australia for commercial resale can create a different responsibility from locally sourced kit stock.

Check the wider makeup-business setup

Registration is only the first step

AICIS regulates almost all cosmetic ingredients as industrial chemicals, including many described as natural or organic. Its guidance says each relevant chemical in a cosmetic introduction must be authorised as listed, exempted, reported, assessed or under a commercial evaluation authorisation.

Registering the business does not register or approve the finished product. The importer still needs sufficient ingredient identity, concentration, use and exposure information to determine the lawful category and complete any pre-introduction requirements.

Re-check old categorisation evidence

If the business previously categorised an ingredient using the high-hazard list, compare the evidence against the September 2026 list and current online guide before the next introduction. A new or updated entry may affect whether the introduction can remain exempted or reported or needs assessment.

Do not rely only on an overseas supplier saying a product is approved, compliant or already registered elsewhere. Ask for the ingredient names, CAS numbers where applicable, concentration information and access to the chemical identity holder or data provider needed for the Australian process.

Keep the declarations and records connected

AICIS states that exempted introductions require a once-off post-introduction declaration, reported introductions require a once-off pre-introduction report and some assessed introductions require a certificate before import. An annual declaration is also due after each registration year.

The regulator says introduction records must be kept for five years, including after the business stops introducing the chemical. Connect the product, supplier, ingredients, category decision, shipment, declaration or report and sales period in one auditable register.

Build traceability for products already sold

Check the other rules around the product

AICIS chemical authorisation is not the whole compliance picture. The regulator points cosmetic businesses to consumer product-safety law, the Poisons Standard and mandatory cosmetic-labelling requirements, while products making therapeutic claims may fall under a different regulatory pathway.

Review labels, claims, safety information, insurance disclosure and recall capability before selling the product or building it into a paid kit. If a product cannot be confidently classified as cosmetic rather than therapeutic, use the official decision tools or obtain specialist advice.

Tell the insurer what the business actually sells · Test new kit products in a controlled way

Use a stop-or-proceed import gate

Proceed only when the business has identified the Australian introducer, obtained usable ingredient data, confirmed the current category, completed required registration or reporting and checked the other product rules. Price those steps into the landed cost rather than treating them as free administration.

Pause the order when the ingredient identity is withheld without an authorised data pathway, the supplier cannot support Australian requirements or the business cannot establish the applicable category. A local authorised supply chain may be commercially safer even when the unit price is higher.

Common questions