News Brief
The Australian government is intensifying its regulation of PFAS substances to fulfill its international environmental commitments and to continue safeguarding human health and environmental safety in Australia.
On 14 October 2025, the Australian Industrial Chemicals Introduction Scheme (AICIS) updated the Rolling Action Plan (RAP) to include an evaluation on the introduction and use of 522 per- and poly-fluoroalkyl substances (PFAS) listed in the Australian Inventory of Industrial Chemicals (AIIC).
This evaluation will confirm whether the listed PFAS are being introduced or are in use in Australia, and if so, what they are used for, and in what volume they are being introduced, to consider which PFAS should be the subject of a further evaluation.
According to the latest RAP update, this evaluation process will conclude on 31 December 2026. Additionally, as required under the Industrial Chemicals Act, as part of the evaluation, AICIS will require AICIS registrants to provide information on whether or not they import or manufacture PFAS in Australia.
To this end, AICIS will next week send all introducers who were registered between 1 September 2023 and 31 August 2025 (inclusive) a notice via email, requiring them to provide the Executive Director with information on the introduction and use of listed PFAS chemicals in Australia covering the 2023–24 and 2024–25 registration years.
What are PFAS?
PFAS, or Per- and polyfluoroalkyl substances, is a collective term for substances such as perfluorooctane sulfonic acid (PFOS), perfluorooctanoic acid (PFOA), and perfluorohexane sulfonic acid (PFHxS). These substances are highly persistent and resistant to degradation in the natural environment, and they possess various hazardous properties.
In Australia, PFAS have been used in the past in a variety of industrial processes and in commercial and consumer products. PFOS, PFOA, and related compounds were imported mainly for use as:
mist suppressants in the metal plating industry
hydraulic fluid in the aviation industry
surface treatments in the photography industry
fire-fighting foams
Some imported articles, such as textiles, may have been treated with PFAS.
What is the Rolling Action Plan (RAP)?
The RAP is part of the Australian Industrial Chemicals Evaluation Roadmap and is primarily used to continuously update and publish lists of industrial chemicals under evaluation or recently evaluated. For each evaluation listed in the RAP, AICIS provides details on the subject, reason, focus, and period within which the evaluation will be conducted.
Based on the evaluation results, relevant information and recommendations on managing the risks associated with the introduction and use of industrial chemicals can be submitted to AICIS.
Additionally, by prioritizing chemicals on the Inventory through the Evaluation Selection Analysis (ESA) process, the evaluations are more risk-proportionate, timely, and targeted.
What Information Must Introducers Provide?
For this assessment of PFAS substances in the inventory, the information required to be provided by each registrant will be:
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 (CAS) number 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.
Registrants will also be asked to voluntarily supply other information that may be relevant to the Executive Director’s evaluation (such as information for earlier registration years), under section 75 of the IC Act.
As a result, all AICIS introducers registered between 1 September 2023 and 31 August 2025 will receive email notifications from AICIS.
All AICIS introducers registered between 1 September 2023 and 31 August 2025 (inclusive), will receive a written notice from the Executive Director via email. They will need to review the list of 522 PFAS listed on the Inventory to determine whether they have introduced any of the listed PFAS and inform AICIS of that matter. If registrants have introduced any of the listed PFAS, then they must provide the information required in respect of each chemical introduced (as outlined above).
According to the requirements specified in this announcement, the required PFAS information must be submitted within 40 working days of the date of the notice.
Important Reminder for Enterprises
Under Section 77 of the Industrial Chemicals Act, failure to submit the required information as stipulated will result in penalties under the following scenarios:
Failure to comply constitutes an offense. Penalty: 300 penalty units;
Failure to comply constitutes a strict liability offense. Penalty: 60 penalty units;
Failure to comply may result in a civil penalty. Penalty: 300 penalty units.
Therefore, REACH24H Consulting Group recommends that relevant enterprises conduct a review of product components introduced into Australia in accordance with regulatory requirements and notifications to confirm whether they contain any PFAS substances involved in this assessment.
If it is confirmed that the products contain relevant substances, enterprises should enhance communication with upstream suppliers to obtain the required information as mandated by regulations and submit the relevant information on time to fulfill compliance obligations.
Enterprises should also proactively conduct internal compliance reviews to ensure that compliance requirements are communicated to relevant departments and personnel, thereby preventing non-compliance resulting from information gaps or oversight.
For more information and inquiries, please feel free to contact us at customer@reach24h.com.
