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Organic and natural ingredients
Many chemical ingredients derived from natural sources – such as plant essences and minerals – are labelled as ‘natural’, ‘organic’, 'herbal' or ‘pure’. However, they may not meet our definition of a naturally occurring chemical because of the process used to extract the chemical from its source.
On this page
If all the ingredients in your products meet our legal definition of a naturally occurring chemical (and you don’t introduce any other industrial chemicals) then you do not need to register with us or search the Inventory - chemicals that meet our definition of 'naturally-occurring' do not need to be listed on the Inventory.
The legal definition of a naturally occurring chemical is:
- an unprocessed chemical occurring in a natural environment; or
- a chemical occurring in a natural environment that is extracted without chemical change by manual, mechanical or gravitational means; or dissolution in water; or flotation; or a process of heating for the sole purpose of removing uncombined water
What is a naturally occurring chemical?
Naturally occurring chemicals can be either:
- an unprocessed chemical that is found in nature, such as chemicals from plants, micro-organisms, animals, the earth and the sea
- a chemical that is found in nature and extracted using a process that does not change its chemical composition
If all the ingredients in your product that you import or manufacture meet our definition of a naturally occurring chemical, then you do not need to register with us.
Most processes used to extract chemicals and aroma compounds from the natural environment – such as steam distillation and solvent extraction – create ingredients that do not meet the legal definition of ‘naturally occurring’ because their chemical composition has been changed.
If any ingredient in your product does not meet our definition of a naturally occurring chemical, you must register your business with us before you can import or manufacture it. For example, if your product contains one ingredient that meets our definition of naturally occurring and 5 ingredients that do not meet the definition, then you must register with us.
You must also check to see if the chemical is on our Inventory. If your chemical is not listed on our Inventory, check our guide on what to do before you start categorising your introduction.
Example
Brian wants to import herbal cosmetics that 'don't contain chemicals' to sell commercially. However, the herbal ingredients include argan oil that was extracted using a solvent, and essential oils manufactured from plants using steam distillation. These ingredients do not meet the legal definition of 'naturally occurring' and are therefore regulated as industrial chemicals.
Brian must register his business and check to see if these chemicals are on our Inventory.
Brian is unsure of the process he needs to follow to import his herbal cosmetics, so he also checks the 'basics of importing and manufacturing chemicals' page for step-by-step instructions.
Example
Judy wants to import a ‘natural’ room deodoriser that includes lavender essential oil and frankincense resin to sell in her retail store. Both of these ingredients were manufactured using either steam distillation or solvent extraction and therefore do not meet the legal definition of 'naturally occurring'.
Judy must register her business with us and check to see if these chemicals are on our Inventory.
Keep reading for more examples that will help you if you work out if your chemical introduction is defined as naturally occurring.
Example
Chloe wants to make and sell her own aloe vera gel at local markets. She bought an aloe vera plant locally, removed the gel and blended it until it had an even consistency. No chemical change took place during the extraction or stirring of the gel, so the gel meets the definition of ‘naturally occurring’.
Chloe does not have to register her business with us or check if the gel is on the Inventory.
Keep reading for more examples that will help you if you work out if your chemical introduction is defined as naturally occurring.
Extraction processes that do not cause a chemical change
Extraction by manual, mechanical or gravitational means
A chemical is defined as naturally occurring if it is extracted by any of these methods.
| Method | Definition |
| Filtration | the solid and liquid parts of a mixture are mechanically separated by passing it through a porous medium |
| Centrifugation | the solid and liquid parts of a mixture are separated by mechanical or gravitational means |
| Sedimentation | the solid and liquid parts of a mixture are separated by enabling the suspended solids to settle via gravity |
| Cold pressing | a liquid-solid mixture is separated by squeezing it to obtain the liquid |
| Sieving | the solids in a mixture are separated on the basis of their particle size |
Extraction by dissolution in water (for water-soluble chemicals)
A chemical is defined as naturally occurring if it is separated from other components in a mixture using water.
For example:
- extracting sugar from sugar beets
- leaching soluble tea from tea leaves
- extracting a water-soluble chemical from mineral ore
Flotation
A chemical is defined as naturally occurring if it is separated from waste rock or solids using a flotation process.
For example:
- mineral ore is pulverised and mixed with water and chemicals that cause preferential wetting of the solid particles. Air bubbles then carry the unwetted particles to the surface to obtain a mineral concentrate
- lead, zinc and copper concentrates are manufactured this way
Heating for the sole purpose of removing uncombined water
A chemical compound is defined as naturally occurring if it is purified or concentrated using heat to remove uncombined water.
For example:
- drying a wet clay or mineral, where moisture is not chemically bound to the substrate
Extraction processes that cause a chemical change
Solvent extraction
If a chemical is extracted by dissolving the source material in any solvent other than water, it does not meet the definition of a naturally occurring chemical.
For example:
- argan oil that is manufactured from crushed kernels via lipophilic solvents
- plant-produced compounds that are removed from the source plant material via solvents such as methanol or supercritical carbon dioxide (CO2)
Example
Michael uses supercritical carbon dioxide (CO2) as a solvent in his extraction process for apple fruit (Malus domestica) to produce an apple extract. This process uses:
• a solvent other than water
• heat that is not used for the sole purpose of removing water
The extract Michael obtains does not meet the legal definition of ‘naturally occurring’.
Steam distillation
If a chemical or aroma compound is isolated from its source through steam distillation, it does not meet the definition of a naturally occurring chemical.
For example:
- essential oils that are manufactured from plants using steam distillation
- petrochemicals that are manufactured using steam stripping
Fermentation
If a chemical is extracted using a fermentation method, for example yeast/bacteria fermentation, it does not meet the definition of a naturally occurring chemical.
Microwave extraction
If you use microwave extraction to isolate a chemical, it does not meet our definition of a naturally occurring chemical.
Examples of naturally occurring chemicals
We don't have a list of approved chemicals or ingredients to use in products. But here are some examples of chemicals that are – or are not – defined as naturally occurring. As you’ll see, it depends on the process used to extract the chemical.
| Naturally occurring | Not naturally occurring | |
|---|---|---|
Essential oils Aroma compounds extracted from plant materials are commonly used in cosmetics. | If you produce essential oils using maceration or cold-press extraction of plants, then they are defined as naturally occurring chemicals. | If you produce essential oils using steam distillation or solvent extraction of plants – including the stems, leaves, roots, flowers or fruit – then they are not defined as naturally occurring chemicals. These processes change the chemical composition of the source product. |
Argan oils This plant oil extracted from the kernels of the argan tree is commonly used in cosmetics. | If you produce argan oil by cold-pressing the fruit and seeds from Argania spinosa, then it is defined as a naturally occurring chemical. | If you deodorise (the selective removal of volatile compounds from the oil using steam) the argan oil after cold-pressing, then it is not defined as a naturally occurring chemical. This process changes the chemical composition of the source product. |
Plant extracts Extracts from the leaves, roots or flowers of a plant can have industrial uses and are often included in cosmetics or cleaning products. | If you freeze-dry a plant (or part of a plant), grind the material and then use water to obtain the extracts, those extracts are defined as naturally occurring chemicals. | If you extract the ground-up plant with a solvent other than water (such as methanol or supercritical carbon dioxide), then it is not defined as a naturally occurring chemical. This process changes the chemical composition of the source product. |
| Beeswax | Beeswax that is heated to remove any water is defined as a naturally occurring chemical. | If you treat beeswax at any stage with bleaching earth or activated carbon (for example, to change the colour of the wax), then it is not defined as a naturally occurring chemical. This process changes the chemical composition of the source product. |
| Chemicals used in construction | These chemicals are defined as naturally occurring if they are obtained from the earth without chemical or heat processing: non-bleached clays | These chemicals and products contain ingredients that are not defined as naturally occurring: lime soda cement mortar grout epoxies |
| Mineral ores | These mineral ores are defined as naturally occurring if they are obtained from the earth without chemical or heat processing: hematite magnetite bauxite chalcopyrite. | Extractive and secondary manufacturing methods – such as refining, roasting, smelting, steelmaking and leaching – result in chemicals that are not defined as naturally occurring. |
Please note; finished products such as fibre board, glass, pressed wood and cement board are defined as articles. You don’t need to register with us if you are importing these products.
Read about introductions that don't require registration or categorisation
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