Blending or manufacturing chemicals

Blending is different from manufacturing because it does not involve a chemical reaction. Understanding the difference between blending and manufacturing chemicals is important because any commercial activity resulting in a chemical reaction will require a business to register with NICNAS.

If the chemicals at the start of the process are the same as the ones at the end, then no new chemicals have been 'manufactured' and there is no need to register with NICNAS.

In other cases, combining the ingredients results in the creation of a new chemical. A common example is soap manufacture, in which fats/oils are combined with sodium hydroxide to produce soap. At the end of the process, the starting materials are consumed and the chemical reaction has resulted in the manufacture of soap—a different chemical to the starting materials. Where a new chemical is manufactured, you need to register with NICNAS as an introducer.

If you blend ingredients sourced within Australia (i.e. you are not importing), and the process of blending or mixing does not create a chemical reaction, you do not need to register your business with NICNAS. However, if you do this to produce cosmetics, your product will still need to meet the general requirements for cosmetics and specific requirements of the Cosmetics Standard 2007 if applicable.

Examples of blending chemicals

Common examples of blending chemicals—i.e. does not result in the creation or synthesis of a chemical—include:

  • mixing paints
  • making soaps using the melt and pour method with a pre-made base
  • mixing cosmetics such as moisturisers, fragrances or essential oils using domestically-sourced ingredients, and
  • cold emulsifying, meaning blending using a mechanical rather than a chemical process.

Examples of manufacturing chemicals

Common examples of manufacturing chemicals—i.e. involving a chemical reaction and the creation or synthesis of a chemical—include:

  • soap making involving saponification
  • any process that involves a chemical change, including some extraction processes used for making essential oils, such as steam distillation, and
  • polymerisation (the process of joining together a large number of small molecules to make a smaller number of very large molecules), such as in the manufacture of acrylic polymers used in paint, varnishes and nail polish.

Last update 29 July 2018