However, companies intending to place retinal-containing cosmetic products on the Australian market should be aware of an important regulatory development. As of 27 June 2026, the Australian Industrial Chemicals Introduction Scheme (AICIS) has changed the regulatory pathway for retinal intended for consumer use, including its use as a cosmetic ingredient. This update affects businesses importing or manufacturing retinal in Australia and represents one of the most significant recent developments in Australian cosmetic ingredient regulation.
Understanding the Australian regulatory framework
Unlike many jurisdictions that regulate cosmetics primarily through cosmetic-specific legislation, Australia regulates cosmetic ingredients as industrial chemicals.
The Australian Industrial Chemicals Introduction Scheme (AICIS), established under the Industrial Chemicals Act 2019, is responsible for regulating the importation and manufacture of industrial chemicals, including ingredients used in cosmetic products. Under the Act, an “introduction” refers to either the importation or manufacture of an industrial chemical in Australia.
Before introducing a chemical, businesses must determine the applicable regulatory pathway. If a substance is already listed on the Australian Inventory of Industrial Chemicals (the Inventory), introducers must comply with any conditions attached to that listing. For chemicals that are not covered by the Inventory or that do not meet the criteria for lower-risk introduction pathways, additional regulatory requirements may apply before importation or manufacture can begin.
AICIS uses a risk-based categorisation framework for introductions. The categories most relevant to cosmetic ingredients are:
- Exempted introductions, considered to present a very low risk to human health and the environment.
- Reported introductions, considered to present a low risk and subject to reporting and record-keeping requirements.
- Assessed introductions, where an AICIS assessment certificate must be obtained before the chemical can be introduced.
The applicable category determines the regulatory obligations that businesses must fulfil before introducing an industrial chemical into Australia.
What has changed for retinal?
On 14 July 2026, AICIS announced that introductions of retinal (CAS No. 116-31-4) for consumer end use can no longer be authorised under the exempted or reported introduction categories.
The change applies from 27 June 2026, meaning that any business intending to import or manufacture retinal for consumer applications—including cosmetic products such as serums, creams and lotions—must first obtain an AICIS assessment certificate before introducing the substance into Australia.
This represents a significant change for companies that may previously have relied on the exempted or reported pathways for retinal introductions.
AICIS recently completed a targeted human health hazard assessment of retinal and concluded that it has developmental toxicity.
As a result, retinal has been classified as a developmental toxin, meaning that introductions for consumer end use no longer meet the eligibility criteria for either the exempted (very low risk) or reported (low risk) introduction categories.
Importantly, AICIS has not prohibited the use of retinal in cosmetics. Instead, the ingredient is now subject to a higher level of regulatory scrutiny, requiring a pre-market assessment before it can be introduced for consumer use.
Practical implications for cosmetic manufacturers
The regulatory change applies specifically to retinal (retinaldehyde, CAS No. 116-31-4).
AICIS explicitly states that the new assessment requirement does not apply to retinol (CAS No. 68-26-8) or retinol esters that are already listed on the Australian Inventory of Industrial Chemicals. These substances continue to follow their existing regulatory pathways, provided all applicable Inventory conditions are met.
This distinction is important because retinal and retinol are closely related compounds but are regulated differently under this specific Australian measure. Manufacturers should therefore assess compliance on a substance-by-substance basis rather than assuming all vitamin A derivatives are treated identically.
For companies marketing retinal-containing cosmetics in Australia, the practical implications are clear. Before importing or manufacturing retinal for any consumer end use, businesses must obtain an AICIS assessment certificate. Introductions of retinal can no longer rely on the exempted or reported categories.
Because AICIS has already completed a hazard assessment for retinal, introducers may be eligible to apply through the Comparable Hazard Assessment pathway, which offers a reduced application fee. AICIS recommends contacting the agency before preparing an application to discuss the available assessment options and the information required to support the submission.
Companies should also be aware that assessment application fees apply when seeking an AICIS assessment certificate.
For manufacturers, this means reviewing product portfolios containing retinal, confirming the identity of the vitamin A derivative used in each formulation, and ensuring that any future importation or manufacture of retinal for consumer use is supported by the appropriate AICIS assessment certificate.
