Brand & Bottle Guides
Australian Cosmetic Compliance Checklist (Free, Printable)
Compliance mistakes are expensive because they usually appear after the product is made: a label reprint, a pulled listing, or a dispute with a marketplace. This checklist covers the five areas every Australian skincare brand must clear before selling — ingredients, claims, labelling, documentation and advertising.
Ingredients: AICIS checklist
Every industrial chemical introduced into Australia must be on the Australian Inventory of Industrial Chemicals (AIIC) or covered by an AICIS authorisation. Most founders work with a manufacturer or supplier that has already handled this, but the brand is still responsible for what goes into the bottle.
- Confirm every ingredient is listed on the AIIC or introduced under a valid AICIS category.
- Obtain an ingredient statement or safety data sheet from each supplier.
- Record the supplier, batch and concentration of every raw material.
- Ask your manufacturer to confirm they have an AICIS-compliant supply chain in writing.
Claims: TGA boundaries
A cosmetic becomes a therapeutic good when it claims to treat, prevent, cure, diagnose or influence a disease, ailment or physiological process. That pathway is significantly more expensive and slower.
- Keep claims cosmetic: describe appearance, hydration, cleansing, fragrance or texture.
- Avoid words like treat, cure, heal, prevent, relieve, reduce symptoms, antibacterial, anti-inflammatory or medical terms.
- Check that sunscreen actives, anti-acne drug claims and any listed medicine ingredients are not present without the right pathway.
- Have your final label copy reviewed by your manufacturer or a regulatory adviser before printing.
Marketing: ACCC and Australian Consumer Law
The ACCC enforces Australian Consumer Law, which prohibits misleading or deceptive conduct. A claim does not have to be false to be unlawful — it has to be unsubstantiated or likely to mislead.
- Every claim on packaging, the website, ads and social posts must be accurate and capable of being substantiated.
- Keep evidence for any before-and-after, clinical or efficacy claim.
- Do not imply results that are typical unless you have evidence they are typical.
- Use clear pricing, shipping costs and refund policies without hidden conditions.
Labelling: what must appear on the pack
Australian cosmetic labels must carry specific information in a readable form. Missing any of these is a common reason for marketplace rejection or customer complaints.
- Product name and brand.
- Ingredient list in descending order of concentration using INCI names.
- Net contents by weight or volume.
- Batch code, lot number or date of manufacture.
- Australian business name and address of the responsible supplier.
- Country of origin if you are making an Australian-made claim.
- Warnings and directions for use if required by the product type.
Documentation and batch records
Retailers, insurers, marketplaces and auditors will eventually ask for proof that your product was made properly. A GMP-standard manufacturer should provide this as standard.
- Request a certificate of analysis for each batch.
- Keep manufacturing batch records, including ingredient weights and in-process checks.
- Retain stability test results for the shelf life you claim.
- Store microbial and challenge testing records for water-based products.
- Keep a product information file with the formula, supplier details, label copy and testing records.
How to use this checklist
Go through each section with your manufacturer before you approve the final label. Print the page, tick each item, and keep the signed copy with your product file. A few hours of verification now saves far more time and money after launch.
Frequently asked questions
Do I need TGA approval to sell skincare in Australia?
Not for standard cosmetic skincare. Most skincare products are regulated as cosmetics, with ingredients overseen by AICIS and claims by the ACCC. A product only moves under the TGA if it makes therapeutic claims or contains certain regulated actives.
What must be on an Australian skincare label?
The label needs the product and brand name, an INCI ingredient list in descending order, net contents, batch identification, an Australian business name and address, and any required warnings or directions.
What is a certificate of analysis?
It is a document from the manufacturer or a testing laboratory confirming that a finished batch meets the specifications for identity, purity, strength and quality. It is one of the first documents a retailer or marketplace will ask for.
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