On 1 April 2026, AICIS published a draft Evaluation for retinal proposing to stop allowing Exempted and Reported pathways for introduction of retinal containing products. All cosmetic products containing retinal are currently imported via the Exempted or the Reported Introduction pathways. The concern raised is reproductive toxicity of retinal, which is common to all retinoids (Vitamin A) including retinol and retinyl esters. Retinol and retinyl esters continue to be legal in Australia.
The decision will take effect immediately after the publication of the retinal evaluation, which AICIS advises will be this week. AICIS has verbally advised that products that are currently on order will not be targeted for compliance action. Accord awaiting written confirmation of this.
Accord has suggested alternative regulatory approaches to reduce the sudden and high regulation impact on industry. After considering our proposals, the regulator has decided to maintain its decision. We are frustrated and have expressed our concerns to AICIS and the Assistant Minister’s office.
To re-start the importation of retinal containing products, each importing company must prepare and submit an Assessment application, with a minimum cost of $24,100 (health focused assessment) plus necessary data generation. The timeframe for assessment, once AICIS starts the assessment, is 70 working days. This does not include ‘stoppage’ time where AICIS asks for more data from a company.
AICIS has confirmed that it will accept retinol reproductive toxicity data for retinal assessment application, recognising that the reproductive toxicity risk of retinol and retinal are the same.
AICIS has suggested that Accord could coordinate a single industry application. If you are interested in Accord coordinating a submission, with fees shared across importing companies, please contact Catherine Oh, Director of Regulatory Strategy. It is expected that some discussion may be necessary to ensure fair fee and data sharing arrangement, with potential additional cost for data generation/information gathering necessary if AICIS requests further information through its assessment process.
If you are an overseas company selling retinal containing products to Australian consumers directly, you are not impacted by AICIS' decision i.e. you can continue selling your retinal containing products to Australian Consumers.