Private label cosmetics for Australia, made in India

Australia has no single cosmetics regulator. The ingredients in a cosmetic are regulated as industrial chemicals by the Australian Industrial Chemicals Introduction Scheme (AICIS). Ingredient labelling sits under a mandatory information standard enforced through the Australian Competition and Consumer Commission (ACCC). Products that are medicines or that are presented with therapeutic effects, including primary sunscreens, are regulated by the Therapeutic Goods Administration (TGA). We make private label products in our own facility in Ambala, Haryana, India, and supply the documents your Australian importer needs. The importer handles the steps that must be done in Australia.

Who is legally responsible when you sell cosmetics in Australia?

The business that brings the cosmetics into Australia is responsible. AICIS says that anyone who plans to sell cosmetics bought from overseas must register their business with AICIS before importing. There is no minimum value or volume. Registration still applies when the products arrive fully branded and packed, when someone else already imports similar products, and when a supplier says the product is approved or registered elsewhere.

AICIS registers the business, not the product or each ingredient. In a private label arrangement that business is usually the brand owner or its Australian importer. It is not us. We are the manufacturer in India, and our job is to give the registered importer accurate ingredient and product information so it can meet its obligations.

What has to happen before products go on sale?

For a cosmetic that is not a therapeutic good, the main pre-import work is about ingredients rather than a product approval.

1. Register the importing business with AICIS. This happens before the first shipment.
2. Check every ingredient against the Inventory. AICIS publishes the Australian Inventory of Industrial Chemicals. Each ingredient that is not listed must be categorised.
3. Categorise each introduction. AICIS uses five main categories: listed, exempted, reported, assessed and commercial evaluation authorisation. Depending on the category, the importer may need to submit a declaration after import, a report before import, or apply for an assessment certificate first. AICIS also has a pathway for fragrance and flavour blends whose make-up is confidential.
4. Keep records and declare each year. AICIS requires importers to keep records of their introductions and make an annual declaration.
5. Check other national rules. AICIS points importers to consumer product safety laws, the Poisons Standard and the cosmetics labelling standard. AICIS notes there is no single list of banned cosmetic ingredients in Australia, and suggests starting with the Poisons Standard.

AICIS also says that almost all cosmetic ingredients are regulated as industrial chemicals, including many sold as natural, such as oils, extracts and plant essences. A full ingredient list therefore matters even for simple botanical formulas.

Where the TGA comes in

According to the TGA, therapeutic sunscreens generally must be included in the Australian Register of Therapeutic Goods before they can be supplied. These include primary sunscreens, meaning products presented mainly for protection from UV radiation, and some secondary products, such as moisturising products with an SPF above 15. Many cosmetic secondary sunscreens are excluded from therapeutic goods law, for example lip products and tinted foundations with an SPF, within conditions the TGA sets out. The TGA says excluded sunscreens must still meet the testing and labelling requirements of the Australian sunscreen standard. If a product carries an SPF or any wording about health effects, ask your importer or an Australian regulatory adviser how it will be classified before you finalise the formula and artwork.

Labelling: language and what typically goes on the label

The Consumer Goods (Cosmetics) Information Standard 2020 sets the mandatory ingredient labelling rules. The ACCC's product safety guidance summarises them:

• An ingredient list on the container, or on the product itself if there is no container. Where size or shape makes that impossible, the list must be shown another way so consumers can see it.
• Order. Ingredients appear in descending order by mass or volume. The standard also allows an alternative order in which lower-concentration ingredients and colour additives follow the main ingredients.
• Names. The standard requires English names or INCI names for ingredients. Fragrance and flavour can be shown as a single term, such as fragrance or parfum.
• Legibility. The list must be prominent and clearly legible.

The standard does not apply to therapeutic goods, which follow TGA labelling rules. Your importer will also check other label details, such as how quantity and the supplier are shown, against the rules that apply to them. Keep claims cosmetic, because wording about health effects can move a product towards therapeutic regulation.

Documents your importer will usually ask us for

Australian importers mostly need ingredient-level detail to work through AICIS categorisation. Expect requests for some or all of these:

• Full formula disclosure or an INCI ingredient list, with CAS numbers where available, so each ingredient can be checked against the Inventory
• Information on fragrance blends from the fragrance supplier, where the blend's make-up is confidential
• Product specification and safety data sheet (SDS)
• Stability and pack compatibility information
• Certificate of analysis for the batch shipped
• Label artwork laid out for the Australian ingredient list rules
• Commercial invoice, packing list and certificate of origin

Our testing and documents service prepares the product paperwork. Tell us at the brief stage that Australia is a destination so the ingredient information is ready in the format your importer uses.

Which ranges suit Australia?

Because AICIS works ingredient by ingredient, ranges built on familiar, well-documented ingredients are the simplest place to start.

• Body care such as lotions and creams and body wash, where formulas are straightforward to document.
• Hair care, including shampoo and conditioner.
• Skincare without an SPF. If you plan a product in sun care, confirm its TGA status first.

Botanical ranges still need full ingredient documentation, for the reason AICIS gives about natural ingredients.

How an order to Australia works with us

1. Brief. Tell us the products, the Australian importer and whether any product carries an SPF.
2. Ingredient check. We share the INCI list so your importer can check the Inventory and categorise each ingredient.
3. Samples and approval. Samples are available on request. Ready formulas start from 500 units per product.
4. Labels and documents. We lay out the artwork and prepare the document set.
5. Production and shipping. Our fulfilment and export service packs and ships on the terms you agree.

The how it works page explains our side, and our guide to exporting cosmetics from India covers export documents in general. Our facility is ISO certified and GMP-compliant. These are facts about how we manufacture, not approvals for sale in Australia.

Next step

Send your product list and destination through the inquiry form for Australia. Requirements change, so confirm current AICIS, ACCC and TGA requirements with your importer or an Australian regulatory adviser before you place an order.