AICIS Will Require Information On 522 PFAS Imported Or Manufactured In Australia

On October 14, 2025, the Australia Industrial Chemicals Introduction Scheme (AICIS) announced that it has initiated an evaluation on the introduction and use of per- and polyfluoroalkyl substances (PFAS) in Australia under Section 74 of the Industrial Chemicals Act 2019 (IC Act). According to AICIS, the evaluation will review the 522 PFAS listed on the Australian Inventory of Industrial Chemicals. The evaluation will confirm whether the listed PFAS have been introduced in Australia, and if so, in what volumes and for what purpose. AICIS will use this information to consider which PFAS should be the subject of further evaluation. AICIS sent out written notices to AICIS introducers registered between September 1, 2023, and August 31, 2025. Responses are due 40 working days after the date of the notice. AICIS has added the 522 PFAS to its Rolling Action Plan.

AICIS sent the notice via e-mail to all introducers registered between September 1, 2023, and August 31, 2025. AICIS will require the following information:

• Whether the registrant has introduced into Australia, through import or manufacture, any of the listed PFAS;
• In respect of any listed PFAS the registrant has introduced, the Chemical Abstracts Service Registry Number^®(CAS RN^®) and name of the chemical, the mode of introduction (i.e., import and/or manufacture), the total volume introduced, and the end use, and
• In respect of any information that the registrant is not able to provide, the reason(s) why they are not able to provide that information.

AICIS notes that registrants do not need to provide information for a listed PFAS if it was imported or manufactured as an excluded introduction, as defined in IC Act Section 11. AICIS states that the notice will also ask registrants to supply voluntarily other information that may be relevant to the evaluation (such as information for earlier registration years), under IC Act Section 75.

Commentary

Under the IC Act, companies must register by September 1 of each year before importing or manufacturing industrial chemicals in Australia. Only companies registered for the years between September 1, 2023, and August 31, 2025, received notices requesting information on the 522 PFAS. Companies that received notices should prepare to respond promptly, given the deadline of 40 working days.

Australia's requirement is narrow, focused on 522 PFAS listed on the Australian Inventory. Canada's 2024 mandatory survey covered 312 PFAS that have not been recently surveyed. Australia seeks information for the two most recent registration years, while Canada's 2024 survey covered the 2023 calendar year. The narrow focus, both in the number of PFAS and time period involved, is in contrast to the United States, where companies will be required to report on PFAS meeting a structural definition manufactured (including imported) between January 1, 2011, and December 31, 2022. Canada and Australia have or will have data reflecting the current marketplace. The U.S. Environmental Protection Agency, once reporting occurs, will have increasingly outdated information. Unlike Canada, where companies had to calculate the concentration levels of the 312 PFAS in manufactured items falling within certain categories to determine what had to be reported, Australia's requirement seems much more straightforward. Was your company registered under the IC Act between September 1, 2023, and August 31, 2025? If so, did you manufacture or import any of the listed PFAS? If so, in what volumes and for what use?

Companies registered in Australia should confirm their contact details and check the contact e-mail for the notice. Hopefully having had to prepare to respond to reporting requirements in the United States and Canada will mean that companies are well positioned to respond quickly.

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