Selling cosmetics in Australia requires strict adherence to mandatory consumer product information standards. Non-compliance can lead to hefty penalties, product recalls, and severe brand damage (Visibelle 2024).
This guide simplifies the core legal requirement—the Consumer Goods (Cosmetics) Information Standard 2020—and explains how to manage ingredient naming, mandatory warnings, and the critical difference between cosmetic and therapeutic claims (Freyr Solutions 2024).
1. The Core Requirement: Ingredient Listing (The 2020 Standard)
The Consumer Goods (Cosmetics) Information Standard 2020, enforced by the ACCC (Australian Competition and Consumer Commission), is the foundational law for cosmetic labelling. Its primary goal is ensuring transparency for consumers, especially those with allergies (Product Safety Australia 2020).
The Ingredient Order Rule
All cosmetic ingredients must be listed either on the container or the product itself (if not in a container). The ingredients must be listed in a manner that ensures consumers are informed at the point of sale (Product Safety Australia 2020). You have two regulatory options for listing concentration:
| Option | Requirement |
|---|---|
| Standard Method | All ingredients must be listed in descending order by volume or mass (Product Safety Australia 2020). |
| The 1% Alternative | 1. Ingredients (except colour additives) in concentrations of 1% or more are listed in descending order by volume or mass. |
| 2. Followed by ingredients (except colour additives) in concentrations of less than 1% (in any order). | |
| 3. Followed by colour additives (in any order). |
Mandatory Warnings
The product label must display specific warnings, or phrases/pictograms that could reasonably be regarded as conveying the same meaning (Product Safety Australia 2020):
- Keep out of reach of children.
- For external use only.
- If ingested, seek immediate medical attention.
- Flammable – keep away from fire and heat. (If applicable to the formulation)
- Discontinue use if skin irritation occurs.
2. Navigating INCI Naming Conventions and AICIS Obligations
Australia mandates that all ingredients must be listed using their correct International Nomenclature of Cosmetic Ingredients (INCI) name or their English name (Freyr Solutions 2024).
The ingredient listing is crucial for consumers to accurately identify substances (Freyr Solutions 2024).
Additionally, any business that imports or manufactures industrial chemicals (i.e., ingredients) for use in cosmetics must register with the Australian Industrial Chemicals Introduction Scheme (AICIS) and comply with introduction reporting requirements (AICIS 2024a; AICIS 2024b).
3. Small Packaging and Display Exemptions
If the size, shape, or nature of the container or product prevents compliance with the direct listing methods, the ingredient list must be shown in another way that ensures the consumer can be informed at the point of sale (Product Safety Australia 2020).
Acceptable alternatives include (Product Safety Australia 2020):
- Prominent Display: A card, sign, or poster immediately next to the product display in a physical store.
- Online Listing: Displaying the full ingredient list clearly on the product’s webpage.
- Leaflet/Insert: Including a detailed ingredient list on a leaflet or insert inside the external packaging.
There is NO automatic exemption from providing the ingredient information just because a package is small.
4. Avoiding the TGA and AHPRA Trap: Cosmetic vs. Therapeutic Claims
One of the most complex areas is defining your product’s purpose. The wrong claim can instantly reclassify your product from a cosmetic to a therapeutic good, placing it under the rigorous regulation of the TGA (Therapeutic Goods Administration) (TGA 2024).
The definition of a cosmetic is a substance intended for contact with the external body or oral cavity, aimed at altering odour, changing appearance, cleansing, maintaining condition, perfuming, or protecting (AICIS 2024a).
| Product Classification | Intended Purpose (Claims) | Regulator |
|---|---|---|
| Cosmetic | Claims limited to changing appearance, cleansing, maintaining condition, or protecting (TGA 2025). | ACCC (Labelling) & AICIS (Chemicals) |
| Therapeutic Good | Claims related to preventing, diagnosing, curing, or alleviating a disease, ailment, defect, or injury; or influencing a physiological process (TGA 2025). | TGA |
Example of Claim Distinction:
- Cosmetic: “Our lotion helps hydrate and moisturise your skin.”
- Therapeutic: “Our lotion helps treat dry skin, soothing and repairing psoriasis patches.”
AHPRA Advertising Compliance
In the clinical space, practitioners must also adhere to guidelines set by the Australian Health Practitioner Regulation Agency (AHPRA), particularly concerning cosmetic procedures. Advertisements must not create unrealistic expectations, misuse testimonials, or imply that a registered professional is performing a procedure when they are not (AHPRA 2026; Aesthetic Medical Practitioner 2024; Visibelle 2024).
Crucial Exception: Sunscreens Note that sunscreens, when making claims about protection against UV radiation, are considered therapeutic goods and are regulated by the TGA, not the Cosmetics Standard, due to their physiological protection claims (TGA 2026).
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Frequently Asked Questions (FAQs)
The primary law is the Consumer Goods (Cosmetics) Information Standard 2020, which is enforced under the Australian Consumer Law (ACL) by the ACCC (Product Safety Australia 2020).
You must use the International Nomenclature of Cosmetic Ingredients (INCI) name or the common English name (Freyr Solutions 2024). Using INCI is highly recommended for clarity and global compliance.
Products sold commercially must list ingredients. The exemption only relates to the placement of the list on small containers, requiring it to be displayed prominently nearby (Product Safety Australia 2020). Free samples and testers are exempt from the standard.
The ACCC regulates cosmetic labelling and general claims under the ACL. However, if your claims stray into therapeutic territory, the TGA (Therapeutic Goods Administration) takes over regulatory authority (TGA 2024). Additionally, health professionals’ marketing is governed by AHPRA guidelines (AHPRA 2026).
References
AHPRA (Australian Health Practitioner Regulation Agency) 2025, New guidelines for cosmetic procedures, https://www.ahpra.gov.au/News/2025-09-02-New-guidelines-for-cosmetic-procedures.aspx.
AICIS (Australian Industrial Chemicals Introduction Scheme) 2024a, Cosmetics, https://www.industrialchemicals.gov.au/glossary/cosmetics.
AICIS (Australian Industrial Chemicals Introduction Scheme) 2024b, Personal care, skincare, make-up and other cosmetic products,
Aesthetic Medical Practitioner 2024, 10 Tips for Complying with TGA Advertising Rules, https://aestheticmedicalpractitioner.com.au/features/cosmetic-practice/10-tips-for-complying-with-tga-advertising-rules/.
Freyr Solutions 2024, Cosmetic Regulations in Australia: A Beginner’s Regulatory Compliance Guide, https://www.freyrsolutions.com/blog/cosmetic-regulations-in-australia-a-beginners-regulatory-compliance-guide.
Product Safety Australia 2020, Cosmetics ingredients labelling mandatory standard, https://www.productsafety.gov.au/business/search-mandatory-standards/cosmetics-ingredients-labelling-mandatory-standard.
TGA (Therapeutic Goods Administration) 2024, Cosmetics or therapeutic goods: Guidance for advertisers and suppliers, Department of Health and Aged Care, https://www.tga.gov.au/sites/default/files/2024-06/cosmetics-therapeutic-goods-guidance-for-advertisers-suppliers.pdf.
TGA (Therapeutic Goods Administration) 2025, Understanding the regulation of therapeutic sunscreens, Department of Health and Aged Care, https://www.tga.gov.au/sites/default/files/2025-08/understanding-regulation-therapeutic-sunscreens.pdf.
Visibelle 2024, TGA and AHPRA Compliance in Cosmetic Marketing: What Clinics Must Know to Avoid Fines and Build Trust, https://visibelle.com.au/tga-and-ahpra-compliance-in-cosmetic-marketing-what-clinics-must-know-to-avoid-fines-and-build-trust/.