Soap making and importing

Most soaps are cosmetics and the soap chemicals are industrial chemicals. Some exceptions apply, such as soaps that are therapeutic goods. 

If you’re planning to sell soaps with a cosmetic (or other industrial) use that you make or import, read this page to see if you need to register with us and what your next steps are if you do.

You can also use our self-guided decision tool Do I need to register as a soap introducer?

When you don't need to register with us

You don’t need to register with us if you only make or sell soaps that meet any of the 5 scenarios below:

Scenario 1: Personal use

soaps that you made or bought for personal use only.

Scenario 2: Melt and pour bases that you bought in Australia

Selling soap that was made by mixing and blending materials in a melt and pour base kit bought from an Australian shop or supplier. 

Scenario 3: Re-selling soaps (packaged and unpackaged) that you bought in Australia 

Re-selling soap that was bought from an Australian shop, supplier, or manufacturer.

Scenario 4: Making soaps to gift to family and friends or sell for no profit 

This is where the money you make is to recover the cost of the materials only.  

Scenario 5: Australian-made soap using lye and maximum 10 kg of fat or oil

When mixing lye with oils or fats to make soaps, you are making (or manufacturing) soap-chemicals.

Criterion 1 – The soap-chemical must be made (manufactured) in Australia.

Criterion 2 – The soap-chemical must be made using a saponification process with a fat or oil and lye (either aqueous sodium hydroxide or aqueous potassium hydroxide).

Criterion 3 - The fat or oil you use to make the soap-chemical must be on the Australian Inventory of Industrial Chemicals (Inventory). To search the Inventory, you must know the CAS name or number of the fat or oil you’ve used. 

Use our table below of some common fats and oils used in soap-making and their CAS name and CAS number.

Criterion 4 – The total volume of fat or oil you use to make the soap-chemical must not be more than 10 kg in an AICIS registration year (1 September to 31 August).

The volume threshold relates to each fat or oil that you use. For example, you could use up to 10 kg of oil A and up to 10 kg of fat B to make your soaps in a year – the soap chemicals made from oil A and fat B would meet criterion 4. 

These criteria relate to the ‘soap-chemical’ that is made by mixing lye (sodium hydroxide or potassium hydroxide) with an oil or fat, i.e. the criteria do not apply to the colours, fragrances or other additives that you might add to make your soap product.

If all 4 criteria are met for the soap-chemical that you are making, then the introduction of that chemical is an excluded introduction. You won’t need to register with AICIS if you only make soap chemicals that meet all the scenario 5 criteria. 

Example for scenario 5 - criteria met and registration is not required

Kate makes soaps using aqueous sodium hydroxide and olive oil and coconut oil. She works out that in an AICIS registration year, she uses 10 kg of coconut oil and 7 kg of olive oil. She also adds a fragrance blend at the end of the saponification process. She sources all her ingredients from within Australia.

The soap-chemicals that Kate is making meet the scenario 5 criteria and are excluded introductions.

The ingredients Kate uses are sourced locally – she is not the introducer of these chemicals.

Since all of Kate’s chemical introductions are excluded introductions, she does not need to register with AICIS.

Examples of when you will still need to register with AICIS:

• You import other ingredients to add to your soaps, such as essential oils or colours/dyes bought online from outside Australia.
• You use more than 10 kg of one or more of the fats or oils you use to make soaps in an AICIS registration year.
• Any of the fats or oils you use to make your soaps are not on the Inventory.
• You make or import any other chemicals for a cosmetic (or other industrial) use.

If you need to register with us, you’ll also need to categorise chemical introductions and meet any obligations associated with the introduction category.

When you must register with us

You must register with us if:

1. you’re making or selling soap that does not fall into any of scenarios 1-5.
2. you’re importing any ingredient to make soap for sale in Australia – this includes soaps sold in-store, online, at local markets and giving out free samples to market your product. These ingredients could be the fat, oil or lye, or other additives such as fragrances or colours.
3. you buy already made soap from overseas that will be packaged (or repackaged) locally and then sold on the Australian market.
4. you buy melt and pour soap bases from overseas to make and sell within Australia.

You must register with us because you’re making (manufacturing) or importing chemicals with a cosmetic (or other industrial) use. If you need to register with us, you’ll also need to categorise chemical introductions and
meet any obligations associated with the introduction category.

See information below on what this means and next steps.

Soap made from natural or organic ingredients

Most soaps, including ‘natural’ or ‘organic’ soaps, contain industrial chemicals. Many natural and organic ingredients do not meet the legal definition of a naturally occurring chemical. This is because many ingredients from natural or organic sources are made using a process that could involve a chemical reaction, such as steam distillation or solvent extraction (for example, to make essential oils).

If you plan to import soap or make soap using natural or organic ingredients, you still need to check if you need to register with us as an introducer.

Chemical names and CAS numbers of some fats and oils commonly used to make soap

You may find this table helpful when you’re working out if you meet criterion 3 in scenario 5 -‘Australian-made soap using lye and maximum 10 kg of fat or oil’. 

You can search the Inventory using the CAS number of the fat or oil. If the fat or oil that you’re using is not in this table, in order to search the Inventory, you will need to contact your supplier for the CAS number (preferred) or the chemical name.

I have to register and categorise my introductions, what do I do next?

1: Register online

Sign up to AICIS Business Services and register with us as an introducer. You register your business - not your products or chemicals.

See more information about registering on our Getting started: registration, importing and manufacturing page.

If you’re registering with us for the first time because you’re a new starter, then you are a ‘level 1’ registrant. See our registration fees and charges.

Otherwise, your registration fees and charges are based on your previous financial year’s total importation and manufacture (introduction) value. To work out how much you will pay, see how much is my registration fee? 

Your registration is valid until 31 August, regardless of when you registered during the year. This is because our registration year starts on 1 September and ends on 31 August every year. There is no pro-rata registration.

2: Categorise your introductions

You are a chemical ‘introducer’ and you must work out which AICIS introduction categories apply to the soap that you are selling.

1.    You import ingredients to make soaps or import soaps to sell in Australia

Use our Guide to categorising your chemical importation and manufacture to work out which AICIS category applies to your introduction and any other obligations that apply.

2.    You make soap in Australia using lye and maximum 100 kg of fat or oil

If all 3 criteria are met, the introduction of the soap-chemical can be categorised as an exempted introduction.

Criterion 1 – The soap-chemical must be made (manufactured) in Australia.

Criterion 2 – The soap-chemical must be made using a saponification process with a fat or oil and lye (either aqueous sodium hydroxide or aqueous potassium hydroxide).

Criterion 3 – The total volume of fat or oil you use to make the soap-chemical must not be more than 100 kg in an AICIS registration year (1 September to 31 August).

These criteria relate to the ‘soap-chemical’ that is made by mixing lye (sodium hydroxide or potassium hydroxide) with an oil or fat, i.e. the criteria do not apply to the colours, fragrances or other additives that you might add to make your soap product.

The volume threshold relates to each fat or oil that you use. For example, you could use up to 100 kg of oil A and up to 100 kg of oil B to make your soaps in a year – the introductions of soap chemicals made from oil A and oil B would be categorised as exempted introductions at step 2 of the categorisation process.

If your soap-chemical introduction is categorised as exempted, you must be registered with us, but do not need to give us any information before you start your introduction. 

Reporting and record keeping
You must submit an annual declaration and keep records (we may ask you to provide them).

3.    You make soap in Australia using lye and more than 100 kg of fat or oil

Use our Guide to categorising your chemical importation and manufacture to work out which AICIS category applies to your introduction and any other obligations that apply.

Remember that when you mix lye with oils or fats to make soaps, you are making (or manufacturing) soap-chemicals. 

To categorise your introduction, you’ll need to check if the soap-chemical you make is on the Inventory – i.e. search the Inventory for the soap-chemical after saponification has completed and not the starting ingredients that you used. 

See examples under the table where chemical is on the Inventory and chemical is not on the Inventory.

This table may help you to categorise your soap-chemical introduction. 

Example - soap-chemical is on the Inventory

Eva makes soap using coconut oil and sodium hydroxide (NaOH). She will use 150 kg of coconut oil in an AICIS registration year and she sources all her ingredients from within Australia. The soap-chemical formed after saponification is complete has the CAS name ‘fatty acids, coco, sodium salts’ and CAS number 61789-31-9.

Eva searches the Inventory and finds the chemical is listed. She clicks on the chemical record to see the 'Inventory terms of listing'. She sees that there are no specific information requirements, no defined scope of assessment and no conditions of introduction or use. 
Eva's soap manufacture is a listed introduction.

Eva is already registered with us, so she can manufacture the soap without telling us first. Eva needs to be aware that the soap may be subject to other Australian Government and State or Territory Government regulations such as labelling. 

Once Eva manufactures the soap, she needs to keep records about her introduction and she needs to submit an annual declaration at the end of the registration year.

Example – soap-chemical is not on Inventory 

Helen makes soaps using linseed oil and potassium hydroxide (KOH). She will use 200 kg of linseed oil in an AICIS registration year and she sources all her ingredients from within Australia. The soap-chemical formed after saponification has the CAS name ‘fatty acids, linseed-oil, potassium salts’ and CAS number is 91051-18-2.

Helen searches the Inventory using the CAS number. She does not find the chemical in her search.

Helen needs to continue with the categorisation process and follow the link in the search results to a page called I can't find my chemical on the Inventory. This page includes information on next steps to take in the categorisation process.