Difference between blending and Manufacturing

This information is from the AICIS website.

What is blending

Blending is commonly described as the process of mixing two or more chemicals together without producing a chemical reaction or creating more industrial chemicals as a result. Many consumer and cosmetic products containing industrial chemicals are mixtures formed by blending.

You don’t need to be registered with us to blend industrial chemicals, as long as the ingredients are purchased from an Australian supplier.

If a chemical reaction does occur and more industrial chemicals are created as a result, it’s defined as manufacturing. You must register with us to manufacture industrial chemicals.

And if you import industrial chemicals or products that release industrial chemicals from overseas for commercial blending in Australia, then you must register with us.

Consumer and cosmetic products that are mixtures of industrial chemicals still need to comply with other Australian legal requirements for labelling and consumer safety.

Examples of blending industrial chemicals

• Mixing pigments or inks
• Making soaps using the melt-and-pour method with a pre-made base
• Mixing cosmetics such as moisturisers, fragrances or essential oils using Australian-sourced ingredients
• Cold emulsifying (mixing using a mechanical process that does not produce a chemical reaction)

Example 1: Janice wants to make her own cosmetic facial moisturiser by blending rosehip oil, vitamin E, lanolin and glycerine. She buys all of the ingredients locally, mixes them together at home and sells the finished product to friends and family. No chemical reaction occurs while Janice is mixing the ingredients together, so Janice does not need to register with us to make her moisturiser.

Example 2: Alex wants to make his own timber wax by blending beeswax, white vinegar, olive oil and lemon essential oil. He buys all the ingredients locally and mixes them together, but no chemical reaction takes place. After decanting the mixture into small jars, he keeps some and sells the rest for the cost of the materials only. Alex does not need to register with us.

What is manufacturing

If you mix industrial chemicals (or products containing chemicals) together and it results in a chemical reaction that produces more industrial chemicals, then this is defined as manufacturing under the Industrial Chemicals Act 2019. If your manufacturing is for a commercial purpose, then you must register with us.

Examples of manufacturing chemicals

• Making soap via saponification of fats or oils using lye (sodium hydroxide)
• Creating essential oils using steam distillation or solvent extraction
• Macrylic polymers (commonly used in nail polish, paints and adhesives) through the process of polymerisation

Example: Lewis wants to make Australian soap scented with ‘bush essences’ to sell at the markets by reacting olive oil with lye (‘sodium hydroxide’). During this process, the chemical reaction called saponification results in an additional industrial chemical - olive soap (‘sodium olivate’). Saponification can also produce other industrial chemicals such as glycerol that may not have a commercial value. We consider Lewis’s soap making to be manufacturing because it involves a chemical reaction that produces industrial chemicals. As Lewis plans to sell the soap, he must register with us.