SYDNEY, Australia, 17 July 2026 — Companies importing or manufacturing retinal for use in cosmetics, skincare formulations, or other consumer products must now obtain an assessment certificate from the Australian Industrial Chemicals Introduction Scheme before introducing the chemical into Australia.
From 27 June 2026, retinal — also known as retinaldehyde (CAS 116-31-4) — can no longer be introduced under the AICIS exempted or reported categories when it has any consumer end use. These pathways are reserved for introductions considered very low risk or low risk.
The change follows an AICIS-targeted human health hazard assessment that classified retinal as a developmental toxin. As a result, importers and manufacturers must apply for and receive an AICIS assessment certificate before bringing retinal into Australia for consumer applications.
Cosmetics and skincare products affected
The requirement applies to retinal used as an ingredient in consumer products, including:
serums;
moisturizers;
creams; and
other cosmetic or skincare formulations.
Assessment application fees apply, and the certificate must be issued before the retinal is imported or manufactured.
AICIS has made a comparable hazard assessment pathway available at a reduced application fee because the agency has already completed its retinal hazard assessment. Introducers are encouraged to contact AICIS before preparing an application to discuss the available options and information requirements.
Broader evaluation identifies risks from vitamin A-related cosmetic ingredients
The retinal decision was published shortly after AICIS completed a broader evaluation of retinol and four retinol esters used in consumer products:
retinol, CAS 68-26-8;
retinyl palmitate, CAS 79-81-2;
retinyl acetate, CAS 127-47-9;
retinyl linoleate, CAS 631-89-0; and
retinyl propionate, CAS 7069-42-3.
These chemicals are used in personal-care products available in Australia, including face creams, serums, moisturisers, body lotions, hand creams, nail polish, and lip balm. Available information indicated that they may be present in cosmetics at concentrations of up to 1%.
AICIS evaluated the chemicals as a group because they are structurally related vitamin A compounds, have similar uses and share retinoic acid as a biologically active metabolite. The evaluation also noted that the term "vitamin A" can encompass retinol and structurally similar retinoids, including retinal and retinol esters.
Developmental, liver, and bone risks identified
AICIS concluded that the evaluated retinol substances are expected to cause adverse effects on the development of an unborn child. The agency said the evidence supports their classification as human developmental toxicants, with the critical exposure period occurring during the early stages of pregnancy.
The evaluation associated exposure with abnormal development of the spine, limb deformities, and craniofacial malformations. It also identified the liver as a target organ following repeated or excessive exposure and noted reported effects on lipid metabolism and bone density.
For workplace health and safety purposes, AICIS recommended classifications under the UN Globally Harmonized System of Classification and Labelling (GHS) for the 5 chemicals it evaluated, including:
Reproductive Toxicity Category 1A — H360D: May damage the unborn child;
Specific Target Organ Toxicity, Repeated Exposure Category 1 — H372: Causes damage to organs through prolonged or repeated exposure; and
For retinol, the agency specifies the classification of Eye Irritation Category 2B — H320: Causes eye irritation.
Combined cosmetic exposure could exceed health thresholds
AICIS assessed potential exposure from the daily use of multiple personal-care products against a tolerable upper intake level of 3,000 micrograms of retinol equivalents per day, established on the basis of developmental toxicity.
Under a worst-case scenario in which all products contained the evaluated chemicals at 1% retinol equivalents, estimated aggregate systemic exposure was three times the upper intake level. The assessment found that daily use of body lotion alone could exceed that level by more than twofold.
A separate guidance level of 1,500 micrograms of retinol equivalents per day has been used for people at greater risk of osteoporosis and bone fractures, particularly post-menopausal women. AICIS found that estimated exposure from body lotion and hand cream could exceed that level, while daily use of a face cream containing the substances at 1% retinol equivalents could account for 79% of it.
The agency also noted that consumers may already be exposed to vitamin A compounds through food, dietary supplements, and topical therapeutic products, adding to exposure from cosmetics.
Lower cosmetic concentration limits recommended
AICIS recommended that Australia’s poisons-scheduling authority amend the existing vitamin A entry in the Standard for the Uniform Scheduling of Medicines and Poisons to restrict the evaluated chemicals to lower concentrations in cosmetic products.
The agency also recommended clarifying which chemicals are covered and expressing permitted concentrations in retinol equivalents rather than simply as vitamin A.
These recommendations concern retinol and the evaluated retinol esters and do not themselves impose the new retinal pre-market assessment requirement. Retinol and retinol esters already listed on the Australian Inventory of Industrial Chemicals remain outside the new requirement announced for retinal.
Implications for industry
Companies supplying retinal-containing products to Australia should verify whether any current or planned introductions previously relied on the exempted or reported categories. Consumer-use introductions cannot proceed until AICIS issues an assessment certificate.
While the requirement for retinal does not apply to the use of retinol (CAS 68-26-8) or its esters, businesses using retinol or retinol esters should separately review the evaluation’s hazard classifications, exposure findings, and recommendation for lower cosmetic concentration limits. Although both retinal and retinol remain listed on the inventory, the evaluation signals possible future changes to Australia's poisons scheduling, which could affect formulation restrictions, labeling, and workplace risk-management measures for these chemicals in Australia.