You've perfected your recipe, sourced your ingredients, and you're ready to sell. But before your first bar hits the market — or even your own social media shop — it's worth understanding the legal framework that governs cosmetics in Australia. The rules are more detailed than most new soapmakers expect, but they're not as daunting as they seem once broken down clearly. This guide covers everything you need to know.

Who Regulates Cosmetics in Australia?

Unlike food or pharmaceuticals, cosmetics in Australia don't have a single dedicated regulator. Instead, they sit across three different government bodies, each covering a different aspect of the supply chain:

Understanding which body applies to your product is the first and most important step. For the vast majority of handmade soap and skincare makers, AICIS and the ACCC are the two that matter most.

Cosmetic vs Therapeutic Good: The Critical Distinction

This distinction is perhaps the most important concept for Australian soap and skincare sellers to understand — and the most frequently misunderstood. The classification of your product determines which regulatory framework applies, and getting it wrong can have serious consequences.

What Is a Cosmetic?

The Australian Government defines a cosmetic as "a substance that is designed to be used on any external part of the human body — or inside the mouth — to change its odours, change its appearance, cleanse it, keep it in good condition, perfume it or protect it."

Examples relevant to soapmakers: handmade cold process soap, body wash, face cleanser, lip balm, body butter, bath bombs, scrubs, shampoo bars, and room sprays. All of these, when making only cosmetic claims, fall under AICIS and the ACCC.

What Is a Therapeutic Good?

Therapeutic goods are "products that prevent, diagnose or treat diseases, or that affect the structure or functions of the human body." These are regulated by the TGA and require a significantly higher standard of evidence, testing, and registration.

Understanding AICIS: The New Framework

On 1 July 2020, the National Industrial Chemicals Notification and Assessment Scheme (NICNAS) was replaced by AICIS — the Australian Industrial Chemicals Introduction Scheme. This wasn't just a name change; it represented a fundamentally different, risk-based approach to regulating industrial chemicals, including cosmetic ingredients.

Why the Change?

NICNAS had a one-size-fits-all assessment model that was considered administratively burdensome for low-risk everyday chemicals like cosmetic ingredients. AICIS introduced a tiered, risk-proportionate model — meaning that a commonly used, well-understood ingredient like citric acid faces far less regulatory burden than a novel compound with unknown human health or environmental impacts.

The Five Categories

Under AICIS, every industrial chemical that is manufactured in or imported into Australia for commercial purposes must be classified into one of five categories. As a soapmaker sourcing ingredients, understanding these categories helps you work with your suppliers and verify ingredient compliance.

The Australian Inventory of Industrial Chemicals (AIIC)

The AIIC is Australia's master list of industrial chemicals that have been assessed and approved for use. If an ingredient in your cosmetic product is listed on the AIIC, it generally means that ingredient has been cleared for introduction into Australia under the applicable conditions.

Before using any ingredient in a product you intend to sell, you or your ingredient supplier must verify that it is listed on the AIIC or has been notified to AICIS for assessment. This is a key compliance step that many small makers overlook.

Natural and Organic Ingredients

A common misconception among handmade cosmetic makers is that "natural" or "organic" ingredients are automatically exempt from regulation. This is not the case. Under AICIS, all ingredients — including natural extracts, plant oils, and botanicals — are classified as industrial chemicals and fall within the regulatory framework.

However, "naturally occurring chemicals" do have a specific legal definition that grants some exemptions. AICIS defines these as chemicals that occur in a natural environment and are extracted without chemical change by: manual, mechanical, or gravitational means; dissolution in water; flotation; or heating solely to remove uncombined water.

This means cold-pressed plant oils, some essential oils, and unrefined butters may qualify as naturally occurring chemicals and benefit from reduced obligations — but they are still classified as industrial chemicals and still sit within the AICIS framework overall.

AICIS Registration: Do You Need to Register?

Whether you need to register your business with AICIS depends on what role you play in the supply chain. The rules differ between manufacturers, importers, and downstream users (formulators who buy already-compliant ingredients).

1. 01

   Manufacturers of Cosmetic Ingredients

   If you are creating or synthesising a cosmetic ingredient from scratch in Australia — for example, producing your own lye, synthesising a preservative, or manufacturing a novel compound — you are classified as a manufacturer under AICIS and must register and comply with the full scheme requirements.

2. 02

   Importers of Cosmetic Ingredients

   If you are importing cosmetic ingredients directly from overseas suppliers — not buying through an Australian distributor — you are an importer under AICIS. You must register with AICIS and ensure each ingredient you import is appropriately categorised. This is common for soapmakers who source ingredients from international wholesale suppliers.

3. 03

   Formulators (Downstream Users)

   If you are purchasing pre-compliant ingredients from Australian suppliers who have already handled AICIS obligations, you are a downstream user (or formulator). You generally do not need to register with AICIS, but you are still responsible for ensuring your finished product is labelled correctly under ACCC rules and that your ingredients are being used within their approved conditions.

4. 04

   Hobbyists and Personal Use

   If you are making soap or cosmetics purely for personal use with no commercial intent, AICIS obligations do not apply. The moment you sell, gift in exchange for value, or distribute commercially, compliance requirements kick in.

Cosmetic Labelling Requirements in Australia

Even if your ingredients are fully compliant, the ACCC's Consumer Goods (Cosmetics) Information Standard 2020 sets strict requirements for how your finished product must be labelled. Non-compliant labelling can result in enforcement action, product recalls, and significant fines.

What Must Appear on Your Label?

• Ingredient list in INCI format — all ingredients must be listed by their International Nomenclature of Cosmetic Ingredients (INCI) name, in descending order of concentration (highest first).
• Name and address of the responsible supplier — the Australian business name and street address (PO Box is not sufficient) of the party responsible for the product in Australia.
• Net contents — the weight or volume of the product, in metric units (grams or millilitres).
• Batch identifier or date of manufacture — to enable product recalls if necessary. A lot number, batch code, or manufacture date all satisfy this requirement.
• Directions for use and warnings — where required by the Standard or relevant safety data. For example, products containing certain allergens or ingredients with usage restrictions.
• Country of origin — required under Australian Consumer Law if the product is imported.
• All text in English — labels must be in English, legible, and permanent.

INCI Names Explained

INCI (International Nomenclature of Cosmetic Ingredients) is the globally standardised naming system for cosmetic ingredients. Every ingredient in your soap must be listed using its correct INCI name — not a common name, a trade name, or a marketing descriptor. For example:

Font Size and Legibility

The Information Standard requires that label text is legible under normal conditions of purchase and use. While there is no mandated minimum font size in the Standard itself, the ACCC interprets "legible" as meaning it can be read without magnification. As a general guideline, 6pt font is considered the practical minimum for ingredient lists on small products.

Animal Testing Ban

Since 1 July 2020, Australia has implemented a ban on the use of new animal test data for ingredients that are solely used in cosmetics. This means that if an ingredient is exclusively a cosmetic ingredient (not used in food, pharmaceuticals, or other applications), it cannot be assessed using new animal test data generated after this date.

For ingredients with multiple uses (for example, a chemical used in both cosmetics and industrial cleaning), there are also restrictions on using new animal test data — though the rules are more nuanced in these cases.

This change aligns Australia more closely with the European Union's long-standing ban and reflects growing consumer and regulatory sentiment against cosmetic animal testing. For most Australian soapmakers working with established cosmetic ingredients, this change has no practical impact on day-to-day operations — your suppliers are already working with compliant, cruelty-free ingredient safety data.

Your Practical Compliance Checklist

Here's a summary checklist for Australian soapmakers and cosmetic formulators selling commercially. Use this as a starting point — not a substitute for professional advice.

• Confirm your product is classified as a cosmetic (not a therapeutic good) and that all claims on labels and marketing are cosmetic-only.
• Determine whether you are a manufacturer, importer, or downstream user under AICIS and fulfil the applicable obligations.
• Verify that all ingredients in your formula are listed on the AIIC or otherwise compliant under AICIS.
• Register your business with AICIS if you are manufacturing or importing ingredients (not just buying from Australian suppliers).
• Ensure all ingredient documentation and Safety Data Sheets (SDS) are on file for every ingredient you use.
• Label all products in compliance with the Consumer Goods (Cosmetics) Information Standard 2020: INCI ingredient list, responsible supplier details, net contents, batch identifier, and required warnings.
• Review your social media and website copy to ensure no therapeutic claims are made about your cosmetic products.
• Keep business records as required by AICIS — introduction volumes, supplier documentation, and ingredient declarations.
• Confirm your product liability insurance covers your cosmetic products (highly recommended for all commercial makers).
• Consider engaging a cosmetic regulatory consultant if you are launching a new product line or are unsure about ingredient compliance.

Key Resources for Australian Makers

Navigating regulation is easier when you know where to look. Here are the official Australian government resources every soapmaker and cosmetic formulator should bookmark:

Frequently Asked Questions