Record-keeping obligations for Inventory-listed chemicals

This page describes the records you can keep for:

• listed introductions of 10 kg or less in a registration year
• listed introductions 
• listed introductions if you were an introducer under NICNAS (temporary administrative arrangements available until 30 November 2023)

You must give us these records within 20 working days, if we ask for them. You need to keep these records for 5 years, even after you’ve stopped introducing your chemical.

Records you can keep for listed introductions of 10 kg or less in a registration year 

This is when you intend to introduce 10 kg or less of your chemical in a registration year. 

You can choose to keep a simpler set of records for these introductions, compared with the other types of records described on this page. Importantly, if you don't know the CAS number of your chemical because it is proprietary or confidential, then you don't need to obtain a written undertaking from the person who holds this information (such as your supplier or manufacturer) to meet your record-keeping obligations.

• Chemical identity – keep a record of the chemical identity using one of the following options (A, B or C): 

A. If you know the CAS number for your chemical, keep a record of:  

• the CAS number, and
• the CAS name, IUPAC name or INCI name  

B. If you don’t know the CAS number for your chemical but you know the CAS name, IUPAC name or INCI name, you must keep: 

• the CAS name, IUPAC name or INCI name, and
• records to indicate that the chemical is listed on the Inventory

Note for option B: Even though you don’t have the chemical’s CAS number, you must have information to indicate the chemical is listed on the Inventory. You could obtain this information from the chemical supplier.

C. If you don’t know the CAS number, CAS name, IUPAC name or INCI name for your chemical, you must keep: 

• records to indicate that the chemical is listed on the Inventory
• names you use to refer to the chemical, and
• details for the person who you believe (on reasonable grounds) would give the CAS number (if assigned) and the CAS, IUPAC or INCI name directly to AICIS, if we ask for this information. You can hold details for a business or a specific person. For example, the chemical supplier may have indicated in an email that they would give this information to AICIS, if requested. You can keep a record of this email.

Notes for option C:

• Even though you don’t have the chemical’s CAS number, you must have information to indicate the chemical is listed on the Inventory. You could obtain this information from the chemical supplier. 
• If it is reasonably practicable for you to find out the chemical’s CAS number (if assigned) and the CAS, IUPAC or INCI name, then you are taken to have known it. This ensures you actively try to find this information. You should consider whether another reasonable person in your position, who is required to comply with the same obligations, would be able to source identity information on your chemical. 
• Keep a record of the names of any products containing your chemical that you have imported into Australia.

• Keep records to show you introduced 10 kg or less of your chemical throughout the AICIS registration year. 
  We’ll accept shipping records and any associated calculations for concentration.
• Keep records of any known hazard classification of your chemical. 
  We’ll accept a copy of the safety data sheet (SDS) or other technical data sheet.

Records you must otherwise keep for listed introductions 

These are the records you must keep for listed introductions, unless you choose to keep the records for listed introductions of 10 kg or less in a registration year, or the administrative arrangement applies to your introduction. 

Even if you introduce 10 kg or less of a chemical in a registration year, you can choose to keep these records instead. For example, you may choose to do this to avoid tracking volumes across many different products. 

• Chemical identity – keep a record of the chemical identity using one of the following options (A, B or C):

A. If you know the CAS number for your chemical, you must keep a record of:  

• the CAS number, and
• the CAS name or INCI name  

B. If you know the CAS name for your chemical, but no CAS number is assigned, you must keep a record of the CAS name.

C. If you don’t know the CAS number or CAS name for your chemical but somebody else does, you must keep a record of the:

• names you use to refer to the chemical, or the names of all products containing the chemical that you import into Australia, and
• a written undertaking from the chemical identity holder that they will give us the CAS name and CAS number (if assigned) within 40 working days from the date of our request, if we ask for this information.

• Other requirements

• If the terms of the Inventory listing for your chemical include a defined scope of assessment, you must keep records to prove that you are introducing or using your chemical in accordance with that defined scope.
• If the terms of the Inventory listing for your chemical include conditions relating to its introduction or use, you must keep records to prove you are complying with those conditions.
• If the terms of the Inventory listing for your chemical include specific requirements to provide information to us, you must keep records to demonstrate that you are meeting those requirements.

Written undertakings for listed introductions

A written undertaking confirms that the person who knows your chemical’s identity (for example, the supplier or manufacturer) will provide the chemical’s CAS name and CAS number (if assigned) within 40 working days from the date of our request, if we ask for this information. 

The chemical identity holder can give this information to us directly. We will not compromise any confidential business information.

Example of content for a written undertaking

Your written undertaking should include the following information:

1. The name by which the chemical is known to the introducer (for example, Chemical A).
2. Contact details for the person who holds the information (this could be the supplier, manufacturer or someone else).
3. A statement confirming that the person who holds the information will provide the CAS name and CAS number (if assigned) for Chemical A within 40 working days from the date of our request, if we ask for this information.
4. A statement confirming that Chemical A is listed on the Australian Inventory of Industrial Chemicals.
5. Information regarding the terms of the Inventory listing (if applicable). Note: this is not essential content for a written undertaking, but you may find it useful to demonstrate to us that your introduction complies with the terms of the Inventory listing.
6. The date that the person who holds the information gave the undertaking to the introducer. Note: the date should be prior to your introduction of the chemical as a listed introduction.

Records you can keep for listed introductions if you introduced the chemicals under NICNAS  

The following information applies if you’re introducing chemicals that were previously on the NICNAS Inventory. This option is only available until 1 April 2024. 

• You must hold the written confirmation from the supplier (or other person who knows the chemical identity) that you would have had under NICNAS to confirm that the chemical was listed on the NICNAS Inventory. You also need written correspondence to show that you’ve asked them for a written undertaking to meet your record-keeping obligations for listed introductions. 

Note: This arrangement only applies if you:

• don’t know the identity of an Inventory-listed chemical that you imported or manufactured (that is, introduced) before 1 July 2020
• have continued to introduce the chemical after this date

It does not apply to an introducer who started importing or manufacturing the same chemical under AICIS (that is, after 1 July 2020). 

We may ask for your records

You must keep certain records about your chemical introductions to confirm they are authorised as listed introductions. This also ensures you’re aware of any changes that could impact your categorisation. You must keep these records for 5 years, even after you’ve stopped introducing your chemical.

What else do I need to keep or submit?

All importers and manufacturers (introducers) of industrial chemicals must submit an annual declaration after the end of each registration year (31 August). Your AICIS annual declaration is due by 30 November every year.