Record-keeping obligations for Inventory-listed chemicals

Records you must keep if you're introducing a chemical under the 'listed' category.

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Introducers must:

give us these records within 20 working days, if we ask for them
keep records for 5 years, even after they’ve stopped introducing their chemical.

An introducer is taken to know the CAS number, CAS name, IUPAC name, or eligible INCI plant extract name if it would be reasonably practicable for them to find out that number/name.
This means introducers must proactively try to find this information, including checking for it with their chemical supplier.

There are options for the types of records introducers can keep. This provides flexibility for introducers to be able to show that their introduction is authorised, whilst ensuring that AICIS has access to adequate information to accurately identify the Inventory listing for a chemical.

Record keeping requirements relate to:

chemical identity information and
other information about a chemical introduction.

Record-keeping requirements

Chemical identity information

There are 5 options. Introducers should try to fulfil options 1, 2, 3 or 4 (in that order) first, before resorting to option 5.

Option 1 - Introducer knows the chemical’s CAS number

Introducer must keep a record of the chemical's CAS number and one of the following:
- CAS name or
- IUPAC name or
- INCI name.

Option 2 - Introducer knows the chemical’s CAS name or IUPAC name (doesn't know the CAS number)

Introducer must keep a record of either the
- CAS name or
- IUPAC name as a record.
Plus a record that shows the chemical is listed on the Inventory.

Option 3 - Introducer knows the chemical’s eligible INCI plant extract name (doesn't know the CAS number, CAS name or IUPAC name)

Introducer must keep the eligible INCI plant extract name as a record.
Plus a record that indicates the chemical is listed on the Inventory.

Important! Eligible INCI plant extract name

The INCI name for an industrial chemical is an eligible INCI plant extract name if:

the industrial chemical is a plant extract that has not intentionally undergone any chemical processes, or treatments, to change its chemical structure and
 the INCI name is based on a botanical name for the relevant plant.

Examples of plant extracts

Extracts of flowers, seeds or leaves of trees, shrubs, herbs, grasses, ferns and mosses.

Examples of changes to the chemical structure: definition not met

Where the chemical has been intentionally:

hydrolysed
acetylated
hydrogenated.

Option 4 - Introducer knows the chemical’s AICIS approved chemical name (AACN ) (doesn't know the chemical’s CAS number, CAS name, IUPAC name or eligible INCI plant extract name).

This option only applies to introducers who were the holder of, or covered by, an assessment certificate for the introduction of a chemical, that was identified by an AACN, and where that chemical has since been listed on the Inventory.

The introducer must keep:

the AACN as a record
plus a record that indicates the chemical is listed on the Inventory.

Option 5 - If the introducer does not have any of the above information

Introducer must keep:

a record that indicates the chemical is listed on the Inventory (generally provided by the chemical supplier – such as a technical information sheet).
one of the following:
- names introducer knows the chemical by. This could be a Trade Name.
- names of any products the introducer has imported that contain the industrial chemical.
- name of the flavour blend or fragrance blend that the industrial chemical is to be introduced as part of.
name of the person or business who the introducer believes (on reasonable grounds) would give the CAS number (if assigned), and the CAS name or IUPAC name of the chemical, if requested by the introducer, following a request from the Executive Director. The introducer also needs a record of why they believe this person or business would supply this information. For example, this could be information in an email from the chemical identity holder or minutes of a meeting.

Other information

As well as the above information, records if any of the following apply to the introduction:

Defined scope of assessment If the terms of the Inventory listing for the chemical include a defined scope of assessment, the introducer must keep records to demonstrate that they are introducing or using your chemical in accordance with that defined scope.
Conditions relating to the introduction or use of the chemical If the terms of the Inventory listing for the chemical include conditions relating to its introduction or use, the introducer must keep records to demonstrate they are complying with those conditions.
Specific requirements to provide information - If the terms of the Inventory listing for the chemical include specific requirements to provide information to us, the introducer must keep records to demonstrate that they are meeting those requirements. For example, the introducer could hold a record to show that information has been provided to AICIS or records to show that information is not required to be provided (such as a record of correspondence from the chemical supplier showing that the chemical is listed on the Inventory and the introduction complies with the specific requirements to provide information).