Hi everyone, it’s Yeannie — back again this week! 👩💻
I had a meeting with an Australian buyer today, and something came up that genuinely surprised me. Right in the middle of our call, they asked, “Our product has retinal in it — what’s going on with that in Australia now?” Turns out Australia’s import rules for retinal just changed, almost overnight. So the moment the meeting wrapped up, I went and dug into it — and if you’re working with retinal or other retinoids right now, you’ll want to know this too.
What happened on June 27 — and why retinal imports suddenly got harder
In Australia, cosmetic ingredients fall under AICIS (the Australian Industrial Chemicals Introduction Scheme). On June 26, AICIS published its final evaluation of retinal (retinaldehyde) and classified it as a developmental toxin. The change took effect the very next day, June 27.
The catch: there was essentially no transition period. Brands that had been importing retinal through the simpler Exempted or Reported pathways found those routes closed overnight. It was significant enough that ACCORD, Australia’s cosmetic industry association, issued an urgent notice to members almost immediately.
Yeannie’s buyer tip: My first thought was, “Wait, is retinal banned outright now?” It’s actually more precise than that — the low-cost, low-paperwork pathways are closed, but a full Assessed introduction pathway still exists. It’s just far from simple, which I’ll walk through below.
Retinal vs. retinol — why only retinal got flagged
You probably already know retinal (retinaldehyde) and retinol are both vitamin A derivatives, just at different conversion steps once they’re on skin. This particular AICIS evaluation singled out retinal specifically over developmental toxicity concerns.
Here’s the interesting part, though: AICIS noted it will accept retinol reproductive toxicity data in support of a retinal application. In other words, existing retinol toxicology data can be leveraged when applying for retinal’s Assessed pathway — it can ease part of the burden. That said, it doesn’t mean retinol data alone guarantees approval. How you structure the application still meaningfully affects both timeline and cost, and that’s exactly the kind of thing we look at case by case when reviewing a formula.
If your product contains retinal, here’s what to check right now
This was the buyer’s core question in our meeting too — “so what do we actually need to do?” Here’s the short version.
- Cost and timeline for the Assessed introduction pathway
With the low-cost pathway gone, an Assessed introduction is now the route. Expect a minimum of roughly AU$24,100, and processing that takes at least 70 working days. If multiple introducers are working with the same ingredient, a consortium application to share costs is worth considering.
- The concentration cap was already in place, separately
Under the Poisons Standard, retinal is capped at 1% in cosmetic formulations. That’s a separate rule from this AICIS action, but it’s something to keep in mind at the formulation stage regardless.
- If your formula isn’t finalized yet, alternative actives are worth a look
If you haven’t locked in your final formula, alternatives like retinol, retinyl esters, or bakuchiol are worth considering. That said, this isn’t a simple “just swap retinal for X” answer — the right call depends heavily on the efficacy, texture, and target market your brand is aiming for. (We walk through this in more detail in our formulation case studies.)
So here’s how we handle it
Every time a regulation like this shifts, it reminds me that when one ingredient’s classification changes, the whole formula sometimes needs a second look — that’s just part of what a manufacturer does. At SPSCOS, we factor target-market regulations into formulation design from the earliest stage, specifically to avoid this kind of last-minute rework. We’re already working through formula alternatives with the Australian buyer I met today, actually.
Whether it’s retinal or any other ingredient, if you want to confirm your current product doesn’t run into target-market regulatory issues, feel free to reach out. We’ll flag it at the formulation stage before it becomes a bigger problem.
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That’s it for this week! Curious what field story I’ll bring next week — see you then. 🫡