· Market Access · By kishan

TGA vs AICIS: What Australian Market Entry Really Requires for Cosmetics

Australia splits regulatory oversight of personal care products between two bodies, and which one applies determines almost everything about your launch timeline: ingredient notification, claims you’re allowed to make, and whether you need product-specific approval before sale.

AICIS: the default for cosmetics

The Australian Industrial Chemicals Introduction Scheme (AICIS) governs the industrial chemicals used in cosmetic formulations. Most standard cosmetics — skincare, haircare, colour cosmetics — are regulated here. Depending on your introduction category (reported, exempted or assessed), you may need to register as an introducer and report the chemicals in your formulation before the product enters the Australian market.

TGA: where claims push a product over the line

The Therapeutic Goods Administration (TGA) takes over the moment a product’s claims cross from cosmetic into therapeutic — anti-acne treatments, sunscreens, and anything claiming to treat, prevent or cure a condition. A product formulated identically to a cosmetic but marketed with a therapeutic claim can be reclassified as a therapeutic good, triggering TGA listing or registration requirements that AICIS notification does not cover.

Where brands get caught out

The recurring failure pattern: a brand notifies correctly under AICIS, then a marketing team adds an SPF or ‘clinically proven to reduce breakouts’ claim post-launch without re-checking classification. Retailers and customs can flag this at the border, and remediation after stock has shipped is far more expensive than a claims review before formulation is finalised.

Our recommendation

Classify before you formulate the final claims strategy, not after. A ten-minute claims audit against the TGA’s therapeutic goods definitions, run alongside AICIS introduction planning, avoids the vast majority of reclassification issues we see in cosmetics market entry work.

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