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Australian Guidance on Categorizing food contact materials

The Australian Department of Health (DOH) announced guidance for manufacturers and importers of chemicals that have an end-use in food-contact articles. The guidance shares six steps to categorize food-contact chemicals as “exempted”, “reported”, or “assessed”, while chemicals that are on their inventory are categorized as “listed”.

The guidance provides examples of food-contact articles such as food wrapping, food containers, coatings on the inside of food cans, and coatings on the insides of water storage tanks. However, chemicals used in cardboard, glass, or metal packaging that has no direct contact with food are not included in this scheme. Moreover, it classifies industrial chemicals introduced for an end-use in food-contact materials as a ‘specified class of introduction’ due to their potentials of migrating to food.

DOH shares the record-keeping obligations for exempted or reported introductions of a chemical for use in food-contact materials. The aim of the record-keeping, according to the DOH, is to ensure chemicals do not pose human health and environment hazard characteristics. The guidance requires to keep the following records in case the new substances have not been internationally evaluated for human health.

  • Data approved by other national authorities for the use of the substance in food contact articles, if available
  • Data on the possibility of the substance migrating to food
Australian industrial chemical introduction scheme- Soaps

Are you introducing soaps into Australian territory for commercial purposes to make a profit? Then you must register under AICIS. The registration duty applies only if soaps manufactured in Australia involving a chemical reaction (such as saponification using lye), importing soaps or their ingredients (essential oils, fragrance) for soap making intended for sale. 

The registration starts on 1st September and ends on 31st August every year, and registration expenses are primarily based on your previous financial year’s total importation and manufacture value. 

Before going for registration, introducers need to check whether all the ingredients in soap, are to be had in the Australian chemical inventory. if not then ingredients need to be registered.  

The registration obligation does not imply to those who make or buy soap for personal use, bought from local Australian shop, supplier, or manufacturer, and make soap and gift to family and friends or sell them for no profit. 

Soap-making process 

Description process 

Registration Obligation 



Yes if intend to sell for profit) 



Yes (if intend to sell for profit) 

Mixing & blending  

If using soap bases, glycerine blocks and pre-made, melt-and-pour bases purchased from an Australian supplier, the chemical process has already occurred. 



Click here to see more on compliance obligations for soap makers under AICIS.