Organic and natural cosmetics
Why you might still need to register your product with AICIS
Consumer preferences for cosmetics and soaps containing natural ingredients has resulted in a huge choice of products on the shelf labelled as natural, organic, herbal or pure.
AICIS is the Australian government scheme that monitors and registers imported or manufactured chemical ingredients. Products with naturally occurring ingredients and which don’t have any other chemicals added, do not have to be registered with AICIS. However, the term ‘naturally occurring’ can be deceptive…
What is and isn't naturally occurring?
In Australia, naturally occurring chemicals are defined by AICIS as:
- an unprocessed chemical that is found in nature, such as chemicals from plants, micro-organisms, animals, the earth and the sea
- a chemical that is found in nature and extracted using a process that does not change its chemical composition
However, extracting naturally occurring chemicals and aroma compounds for use in cosmetics is very often done in a way that changes the chemical composition of the original ingredient. Argan oil for example is commonly extracted using a solvent. Steam distillation is another process that’s commonly used.
The use of these processes, as well as fermentation and microwave extraction means that the extracted material no longer meets the legal definition of naturally occurring.
Therefore any product with ingredients extracted in this way are regulated by AICIS. That means you must register your business with AICIS before you can import or manufacture it.
On the other hand, if your product contains only ingredients that have been extracted using processes that don’t cause a chemical change, such as:
- Filtration, centrifugation, sedimentation, cold pressing or sieving.
- Extraction by dissolution in water
- Flotation
- Heating to remove uncombined water.
Then your product is unregulated and you do not have to register with AICIS.
For absolute certainty as to whether your product should or should not be registered, it might be quicker and easier to get your product to market by seeking some expert advice.
This communication (including any attachment) has been prepared by BWES and is based on the available information at the time of publication and is believed to be true and accurate. The information contained in this communication should be used as a guide only and may cease to apply if applicable regulation or the product’s design or application is altered. BWES does not take responsibility for any Injury, Loss for damage suffered by any party’s interpretation or decisions made by any party on the information provided in this communication.