AICIS Chemical Import Notification Guide for Taiwan Exporters

The Australian Industrial Chemicals Introduction Scheme (AICIS) replaced NICNAS in July 2020 as Australia's national regulator for the introduction of industrial chemicals. AICIS operates under the Industrial Chemicals Act 2019 and administers the Australian Inventory of Industrial Chemicals (AICS) -- a database of approximately 44,000 chemicals that have been assessed for safety and can be introduced into Australia. Any person or company introducing an industrial chemical into Australia -- through import or manufacture -- must hold an AICIS registration and comply with notification or exemption requirements.

For Taiwan exporters, AICIS requirements apply to a broad range of products. Industrial chemicals include ingredients in cosmetics, cleaning products, inks, paints, adhesives, plasticizers, solvents, and surface coatings. Chemicals used solely in food, therapeutic goods, or agricultural products are regulated by other agencies (FSANZ, TGA, APVMA respectively) and are exempt from AICIS. However, cosmetic ingredients are classified as industrial chemicals under AICIS -- a Taiwan cosmetics brand exporting to Australia must comply with both AICIS chemical requirements and the relevant consumer product safety standards.

AICIS registration is mandatory before introducing any industrial chemical. Registration categories include Standard (for introducers with annual revenue exceeding AUD 5 million from chemical introductions), General (for revenue between AUD 500,000 and AUD 5 million), and Nil (for revenue below AUD 500,000 or introducing only listed chemicals). Registration fees range from AUD 0 for Nil tier to AUD 14,700 for Standard tier annually. All introducers must register regardless of revenue level.

The Australian importer -- not the overseas manufacturer -- holds AICIS obligations. If a Taiwan company exports cosmetic ingredients to an Australian distributor, the Australian distributor is the introducer and must hold AICIS registration. If the Taiwan company's Australian subsidiary directly imports chemicals, the subsidiary is the introducer. For Taiwan brands selling finished consumer products containing industrial chemicals, the party that causes the goods to be imported (typically the importer of record) holds AICIS responsibility.

Before introducing any industrial chemical into Australia, the introducer must verify whether the chemical is listed on the AICS inventory. Listed chemicals -- those already on the AICS database -- can be introduced without pre-market assessment, though some carry conditions of use or restrictions. The AICS is searchable by CAS number, chemical name, or molecular formula through the AICIS online portal. Taiwan manufacturers should provide CAS numbers and full chemical identities for every ingredient in their products to enable accurate inventory checks.

The AICS contains approximately 44,000 entries as of 2025. Each entry specifies whether the chemical is listed with or without conditions. Chemicals listed without conditions can be freely introduced. Chemicals listed with conditions may have restrictions on concentration levels, product types, or exposure scenarios. For example, certain UV filters used in cosmetics are AICS-listed with conditions limiting concentration to specific percentages -- Taiwan cosmetics formulations must comply with these condition limits even though the ingredient is technically listed.

Confidential AICS entries present a unique challenge. Approximately 4,000 AICS entries are confidential -- the chemical identity is not publicly available. If a Taiwan manufacturer's ingredient does not appear on the public AICS but may match a confidential entry, the introducer can submit a Confidential AICS Search Request to AICIS. AICIS staff will confirm whether the chemical matches a confidential listing within 20 business days. The search request fee is AUD 0 for Nil-tier registrants and AUD 190 for General and Standard tier registrants.

For Taiwan exporters selling finished consumer products (cosmetics, cleaning products, surface coatings), a complete ingredient AICS check is the first step in Australia market entry. Create a spreadsheet listing every ingredient by CAS number, INCI name, concentration, and function. Run each CAS number against the AICS public database. Flag any ingredients not found on the public AICS for confidential search requests or new chemical assessment. This inventory check typically takes 2 to 4 weeks for a product line of 10 to 20 SKUs.

AICS listing status can change. AICIS periodically adds new chemicals through the evaluation pipeline and may impose new conditions on previously unrestricted listings based on updated hazard data. The AICIS Chemical Gazette publishes all inventory changes monthly. Taiwan brands with ongoing Australian chemical introductions should monitor the Gazette to identify any changes affecting their product ingredients.

If an ingredient is not listed on the AICS, it is classified as a new chemical requiring assessment before introduction. AICIS categorizes new chemicals into five assessment categories based on risk: Exempted, Reported, Assessed, Commercial Evaluation, and Not Automatically Assessed (for chemicals with specific hazard concerns). The category is determined by the chemical's intrinsic hazard profile, introduction volume, and end-use exposure scenario using the AICIS online categorization tool.

Exempted introductions cover low-risk scenarios such as chemicals introduced at volumes below 10 kg per year, chemicals used in cosmetics at concentrations below 1%, or chemicals with well-established low-hazard profiles. Exempted introductions require no pre-market notification but must be reported in the Annual Declaration. Reported introductions cover medium-risk chemicals requiring a notification to AICIS before introduction with processing within 5 business days. Reported notification fees are AUD 0 for Nil-tier registrants and AUD 2,450 for Standard tier.

Assessed introductions require a full pre-market assessment by AICIS scientists. The introducer submits a data package including physico-chemical properties, toxicological studies, ecotoxicological data, and exposure assessment. AICIS evaluates the data and issues an Assessment Certificate within 90 business days (extendable to 180 days for complex chemicals). Assessment fees range from AUD 5,460 for standard assessments to AUD 47,700 for extensive assessments requiring detailed evaluation. Taiwan manufacturers must budget for assessment timelines in their Australia launch plan.

Commercial Evaluation permits time-limited introduction of new chemicals for evaluation purposes before full assessment. This pathway allows up to 4 years of market testing with annual introduction limits. Commercial Evaluation authorization fees are AUD 2,450 to AUD 8,190 depending on the registrant tier and chemical risk profile. For Taiwan brands wanting to test-market a new formulation in Australia, Commercial Evaluation provides a pathway to begin sales while the full assessment is underway.

After assessment, the new chemical is added to the AICS inventory -- potentially with conditions based on the assessment findings. The Assessment Certificate specifies any conditions, and the introducer must comply with these conditions for all subsequent introductions. Conditions may include concentration limits, mandatory PPE requirements for downstream users, or specific labeling requirements. Taiwan manufacturers should share Assessment Certificate conditions with their Australian distributors to ensure downstream compliance.

All AICIS-registered introducers must submit an Annual Declaration by September 30 each year covering the previous financial year (July 1 to June 30). The Annual Declaration reports the value of industrial chemicals introduced, details of each introduction (chemical identity, volume, and category), and any changes to the registrant's business. Failure to submit the Annual Declaration by the deadline triggers an automatic AUD 420 late fee and may result in registration cancellation.

Record-keeping obligations require introducers to maintain records for 5 years including import documentation, Safety Data Sheets (SDS), AICS check results, assessment certificates, and introduction volumes. AICIS conducts compliance audits of registered introducers on a risk-based schedule. Standard-tier registrants can expect audit scrutiny every 2 to 3 years, while Nil-tier registrants are audited less frequently. Audit non-compliance can result in enforceable undertakings, infringement notices of up to AUD 16,650, or referral for criminal prosecution.

Safety Data Sheets must comply with the Globally Harmonized System (GHS) as adopted in Australia under the model Work Health and Safety Regulations. SDSs must be prepared in English and made available to all downstream users of the chemical within Australia. Taiwan manufacturers supplying industrial chemicals or chemical-containing products should provide GHS-compliant SDSs to their Australian importers. SDS preparation by an Australian regulatory consultant costs approximately AUD 300 to AUD 800 per chemical.

Enforcement under the Industrial Chemicals Act 2019 includes civil penalties for introducing chemicals without appropriate categorization (up to AUD 222,000 for individuals and AUD 1.11 million for bodies corporate), criminal penalties for serious breaches, and enforceable undertakings. AICIS also has the power to issue Chemical Review Notices requiring additional data on already-listed chemicals if new hazard information emerges. Taiwan exporters should treat AICIS compliance as an ongoing obligation rather than a one-time market entry exercise.

Taiwan brands with multiple products containing numerous chemical ingredients should consider engaging an Australian regulatory consultant specializing in AICIS compliance. Consultant fees for a comprehensive AICIS compliance program -- covering AICS inventory checks, categorization, notifications, and Annual Declaration preparation -- typically range from AUD 5,000 to AUD 20,000 per year depending on the number of chemicals and introduction volumes.