What is a naturally-occurring chemical?
Many products have ingredients (chemicals) derived from natural sources such as plants and minerals. Introducers and suppliers often market these products as 'natural', 'organic' or 'pure'.
Not all chemicals from natural sources meet the definition of a 'naturally-occurring chemical'.
If a chemical in your product does not meet the naturally occurring chemical definition, it is a relevant industrial chemical.
If you want to manufacture and/or import a relevant industrial chemical or a product containing relevant industrial chemicals, for commercial purposes, you will need to register your business with us.
You do not need to notify us if your chemical is a naturally-occurring chemical. This is because these chemicals are treated like they are on the Inventory, whether they are listed or not.
Has any processing occurred?
Introducers and suppliers can obtain some chemicals from nature without any processing, such as minerals and animal milk. These ingredients meet the definition of a 'naturally-occurring chemical'.
Most chemicals derived from nature, however, need some type of processing before introducers and suppliers can use them in a product.
Do the ingredients in my product meet the definition of a naturally-occurring chemical?
You need to consider:
- the process involved in deriving or extracting it
- if there has been a change in the chemical composition during the extractive process
Section 5 of the Industrial Chemicals (Notification and Assessment) Act 1989 (ICNA Act) defines a naturally-occurring chemical as:
- an unprocessed chemical occurring in a natural environment or
- a chemical occurring in a natural environment, being a substance that is extracted by
- manual, mechanical, or gravitational means
- dissolution in water
- a process of heating for the sole purpose of removing uncombined water
without a chemical change in the substance.
Factors to consider
You need to consider a number of factors when determining if a chemical meets the definition of a naturally-occurring chemical, including:
- how was the substance obtained
- has the substance been obtained after some form of processing
- if so, what type of processing
- was heat used in the processing
- was there any likelihood of chemical change during processing
Explanatory notes on the definition
1. Unprocessed chemicals occurring in a natural environment
Introducers and suppliers can obtain unprocessed chemicals from plants, micro-organisms or animals without any processing at all. For example blood and milk from animals.
This also applies to inorganic matter such as minerals, ores, crude oil, coal and natural gas obtained from the earth or sea without any processing.
2. Chemicals extracted without a chemical change
This refers to chemicals that occur in nature but which introducers and suppliers have extracted without changing their chemical composition.
Only the following processes comply with the definition of a naturally-occurring chemical.
If introducers and suppliers extract a chemical by some other means, such as steam distillation or solvent extraction, it will not be a naturally-occurring chemical but an industrial chemical.
a. Manual, mechanical or gravitational
- Filtration: solid and liquid phases of a mixture are mechanically separated by passing it through a porous medium
- Centrifugation: liquid phases or solid and liquid phases of a mixture are separated by mechanical/gravitational means
- Sedimentation: solid and liquid phases of a mixture are gravitationally separated by enabling the settling of solids in liquids
- Cold pressing: liquid of a liquid-solid mixture is separated by squeezing it to obtain the liquid
- Sieving: solids in a mixture can be separated on the basis of particle size
b. Extraction by dissolution in water (for water-soluble chemicals)
- Water is the only solvent an introducer or supplier can use to extract the chemical from other components in a mixture.
- Examples include:
- extraction of sugar from sugar beets using water
- leaching of soluble tea from tea leaves
- extracting a water-soluble chemical from mineral ore
- Dissolution by any other solvent or mixture of solvents (or mixture of water with other solvents) disqualifies the chemical from being naturally-occurring.
- Flotation is a separation process used in mineral processing to separate minerals from waste rock or solids.
- Mineral ore is pulverised and mixed with water and chemicals that cause preferential wetting of the solid particles.
- Air bubbles carry the unwetted particles to the surface to obtain a mineral concentrate. For example lead, zinc, and copper concentrates.
d. Heating for the sole purpose of removing uncombined water
- Introducers or suppliers can use heat to purify or concentrate chemical compounds by removing uncombined water, for example the drying of a wet clay or mineral, where moisture is not chemically bound to the substrate.
- Using heat for any other purpose, such as steam distillation, disqualifies the chemical from being naturally-occurring.
Last update 17 April 2018