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Record keeping for exempted introductions – chemicals resulting from non-functionalised surface treatment of listed chemicals

You must keep certain records for introductions of chemicals resulting from non-functionalised surface treatment of listed chemicals, which you’ve categorised as exempted. You must provide these records within 20 working days if we ask for them.

On this page

Before you read this page’s content, make sure you’ve already read and understood our record-keeping overview page.

Records you must keep

The type of records you must keep depends on whether you know the CAS number, CAS name or, IUPAC name or INCI name. 

An introducer is taken to know the CAS number, CAS name or IUPAC 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.  

Chemical identity

  • If you know the CAS number – written or electronic record of the CAS number for the chemical and one of the following:
    • CAS name
    • IUPAC name
    • INCI name.
  • If you don’t know the CAS number or it is not assigned - written or electronic record of one of the following: 
    • CAS name
    • IUPAC name 
  • If you don’t know the CAS number or it is not assigned, and you don’t know the CAS name or IUPAC name - written or electronic record of: 
    • the names you use to refer to the chemical
    • name of the person or business who you believe (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. 
    • why you believe the information holder will give the required information to AICIS. For example, this could be information in an email from the chemical identity holder or minutes of a meeting.

Introduction requirements

You will also need the following records:

  • Records to prove your chemical is not one that cannot be exempted or reported at step 1 of the categorisation process. That is:
    • isn’t listed in Annex III of the Rotterdam Convention* or 
    • isn't listed in Part 1 of Annex A, B or C of the Stockholm Convention* 
    • the Persistent Organic Pollutants Review Committee has not decided that your chemical meets the POPs screening criteria set out in Annex D of the Stockholm Convention*
    • the AICIS Executive Director has not decided that your chemical meets the Annex D screening criteria for POPs while making the decision about issuing an assessment certificate for that chemical*
    • the AICIS Executive Director has not decided that your chemical meets the Annex D screening criteria for POPs based on an AICIS evaluation done on that chemical*

    • your chemical isn’t listed on the Inventory with conditions of introduction or use that will be contravened

      We'll accept a signed and dated declaration that these checks took place. 

      *unless it is introduced solely for use in research or analysis and the amount that you introduce in a registration year does not exceed 100kg.

If you know your chemical’s identity

You must have records to demonstrate that your chemical introduction meets the criteria for introductions of chemicals resulting from non-functionalised surface treatment of listed chemicals – see checkboxes below.

If someone else holds information about your chemical’s identity

You must have records showing all 3 below:

  1. Why you believe your chemical introduction meets the criteria for introductions of chemicals resulting from non-functionalised surface treatment of listed chemicals. These criteria are detailed in the checkboxes below.
  2. The name of the person or business who you believe (on reasonable grounds) would give AICIS the records to demonstrate that the criteria for introductions of chemicals resulting from non-functionalised surface treatment of listed chemicals are met, if requested by you, following a request from the Executive Director. 
  3. Why you believe the information holder will give the required information to AICIS. For example, this could be information in an email from the holder of the information or minutes of a meeting.
  • A record of the CAS numbers and CAS names for the substrate chemical and all other chemicals involved in the reaction at the surface of the substrate chemical plus records to show that the chemicals are listed on the Inventory.
  • A record proving that the industrial chemical is the result of a reaction between 2 or more chemicals where the reaction occurs at the surface of one of the chemicals (the substrate chemical).

  • Nanoscale – records to demonstrate one of the following:

    • it’s not introduced as a solid or in dispersion (if applicable). We’ll accept an SDS or product information sheet that indicates the appearance.
    • it doesn’t consist of solid particles in an unbound state or as an aggregate or agglomerate, where at least 50% (by number size distribution) of the particles have at least one external dimension in the nanoscale. The information we’ll accept depends on the particle size range of the solid or dispersion:
      • Greater than 1000 nm in all dimensions - we'll accept:
        • an SDS or technical data sheet for the chemical or the product that it’s introduced in that indicates it will be introduced as granules, pellets, or a wax; or
        • a study result from a particle size distribution study on your chemical or the product that you will introduce into Australia (conducted according to OECD TG 110)
      • Greater than 200 nm and less than or equal to 1000 nm in all dimensions – we’ll accept:
        • a study result from a particle size distribution study on your chemical or the product that you will introduce into Australia (conducted according to OECD TG 110 or 125). 
        • If the chemical is in a dispersion, the spectroscopy- and microscopy-based methods such as scanning electron microscopy (SEM) and transmission electron microscopy (TEM) are more appropriate. 
      • Note: for particle size distributions in this range, information only from an SDS/technical data sheet or similar is not enough. 
      • Less than or equal to 200 nm in at least one dimension – we’ll accept: 
        • a study result from a particle size distribution study on your chemical or the product that you will introduce into Australia (conducted according to OECD TG 125).
        • If the chemical is in a dispersion, the spectroscopy- and microscopy-based methods such as scanning electron microscopy (SEM) and transmission electron microscopy (TEM) are more appropriate.

    Note: For particle size distributions in this range, information only from an SDS/technical data sheet or similar is not enough.

    You can use OECD TG 110 to measure particle size and distribution to support that a chemical is not at the nanoscale for particles and fibres with sizes above 250 nm.

    OECD TG 125 on Nanomaterial Particle Size and Size Distribution of Nanomaterials measures particles and fibres with a diameter of 1 to 1000 nm and fibres with a length up to 20 µm.

  • Records to prove your chemical doesn’t have any reactive functional groups that weren’t present on the substrate chemical. The information that we’ll accept depends on the type of reaction that has occurred at the surface of the substrate chemical.

How to print the checklist

Use your browser to print the record-keeping checklist content on this page by:

  1. clicking the print button at the top-right this page / or pressing Ctrl P 
  2. selecting your printer or choosing the 'Save as PDF' option
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