Soaps and soap making
Last update 12 January 2017
In Australia, ingredients in soaps are regulated as industrial chemicals by NICNAS.
Soap makers and/or importers must comply with NICNAS requirements, as set out in the Industrial Chemicals (Notification and Assessment) Act 1989 (ICNA Act).
Who needs to register with NICNAS?
You need to register with NICNAS if you do any of the following activities for commercial purposes:
- make soaps in Australia by a process involving a chemical reaction (i.e. saponification);
- import soaps into Australia from overseas manufacturers or suppliers; and/or
- import chemical ingredients into Australia for soap making.
What is saponification?
Saponification involves the hydrolysis reaction of an animal or vegetable fat with an alkali, such as sodium hydroxide, also known as lye or caustic soda.
The cold-process and hot-process methods of soap making both use saponification.
Saponification is regarded as the manufacture of an industrial chemical. If you use saponification to make soap, you must register with NICNAS.
To confirm whether you need to register complete our questionnaire, Do I need to register my business?
Who does not need to register with NICNAS?
You do not need to register with NICNAS if you only make soaps in Australia without a chemical reaction by mixing or blending ingredients purchased from an Australian supplier.
What is mixing and blending?
Using products such as soap bases, glycerin blocks and melt and pour bases may not involve a chemical reaction because the saponification reaction has already occurred.
Soap-free cleansers, such as syndet bars, are generally made by mixing the ingredients, without a chemical reaction.
Read more about the difference between blending and manufacturing chemicals.
You should do your own research to understand whether a chemical reaction has occurred in your soap-making process.
Who needs to check the AICS?
All soap makers must check that every ingredient in their soap is on the Australian Inventory of Chemical Substances (AICS) and whether there are any conditions attached to the use of those ingredients.
Remember to check ingredients you think are 'natural' as they may not meet the definition of a 'naturally-occurring chemical' in the ICNA Act.
If an ingredient is not listed on AICS—or has a condition of use different to your intended use—it is considered a new industrial chemical to Australia.
You will need to inform NICNAS about the new chemical before you import and/or manufacture it for use in a soap to consumers. Read more about how to notify a new chemical.
Who needs to comply with the Cosmetics Standard?
If your soap is an anti-acne or anti-bacterial skin product you will also need to comply the Cosmetics Standard 2007.
What other laws apply to soap makers?
All soap makers and/or importers must also comply with other laws regarding cosmetics, including:
- the Australian Competition and Consumer Commission's (ACCC) product safety and mandatory cosmetics labelling standards, and
- the use of prohibited and restricted chemicals.
Depending on your soap you may also need to comply with:
- the requirements of Therapeutic Goods Administration (TGA) if your soap is for therapeutic use.