You can make and sell acne-prone skincare in New Zealand and Australia as a cosmetic, but only if the formula and the claims stay on the cosmetic side of the line. Cleansing, moisturising, exfoliating and oil-balancing are fine. Claiming to treat or cure acne or pimples makes a product a therapeutic good, with a very different regulatory path.
This is one of the most common places indie founders get caught out, because "blemish-prone skin" is a huge market and the wording on your label matters as much as what is in the bottle. Here is how we guide brands through it at The INCI Lab.
Is an acne skincare product a cosmetic or a therapeutic good?
It depends on three things: the claims you make, the ingredients you use, and how the product is presented. Australia's TGA guidance lists "pimples and acne" among the conditions that, if you claim to treat or relieve them, point to a therapeutic good. The same guidance recognises that some anti-acne skincare products that only prevent acne through cleansing, moisturising, exfoliating or drying the skin can be excluded from therapeutic regulation, provided they meet the conditions of the Excluded Goods Determination.
In practice, that means "helps keep skin clear and balanced" sits in very different territory from "treats acne" or "kills acne bacteria". Antibacterial or antiseptic claims, before-and-after photos of severe skin, and references to medical conditions can all tip a product over the line. New Zealand takes a similar approach: a product that makes a therapeutic claim can be treated as a medicine rather than a cosmetic, so check your wording before you check your formula.
What can you say on the label for blemish-prone skin?
Safe cosmetic territory is about how skin looks and feels, and about what the product physically does to the surface. Wording such as "cleanses excess oil", "gently exfoliates", "leaves skin feeling clear and fresh" or "for oily and combination skin" describes appearance and cleansing. Wording such as "treats breakouts", "clears acne" or "reduces acne-causing bacteria" describes a medical outcome.
Our rule of thumb: describe the skin type and the experience, not the disease. We cover the wider rules in our guide to what you can legally claim on a skincare label in NZ and Australia, and we review draft claims as part of every project.
Which ingredients are popular in acne-prone formulas, and what do you need to watch?
Brands commonly ask for niacinamide, zinc PCA, azelaic acid derivatives, bakuchiol, willowbark extract, clay and gentle AHAs or BHAs. Most of these can sit in a cosmetic when used at appropriate levels with cosmetic claims. The watch-outs are:
- Restricted ingredients. Salicylic acid is controlled in cosmetics in both regions, with limits that depend on the product type and use, so we check the current NZ and Australian rules for each formula rather than working from memory.
- Scheduled ingredients. The TGA notes that products containing ingredients in Poisons Standard Schedules 2, 3, 4 or 8 are likely to be therapeutic goods.
- Essential oils. Tea tree is popular, but an essential-oil product that makes therapeutic claims is treated as a therapeutic good, and tea tree is a frequent sensitiser. We use it sparingly or not at all.
- Chemical status. In Australia, every ingredient must be covered under AICIS. New or unusual actives need checking first.
How do you formulate for skin that is oily and easily irritated?
Acne-prone skin is often oily and sensitised at the same time, so the formula has to do two jobs. We typically aim for a light, non-comedogenic-leaning emulsion or gel, a skin-friendly pH (see our explainer on why skin pH matters), a sensible acid strategy rather than stacking several exfoliants, and a barrier-supporting base so the active does not leave skin tight and angry. Fragrance-free is the default recommendation for this audience, and it is something we do well.
What testing does an acne-prone range need before launch?
Any water-containing formula needs stability testing (we recommend a 12-week accelerated programme) and preservative efficacy testing, which is NZ$1,200 per formula at The INCI Lab. Because the claims are about skin type and feel, you will also want a safety assessment and, if you plan to say "suitable for sensitive skin", evidence behind that. We help you plan this so you only pay for testing that supports the claims you actually make. If you are exporting, we also prepare documentation for EU and US markets.
How does The INCI Lab work with blemish-prone skincare brands?
We are a cruelty-free formulation studio in Auckland working with indie brands across NZ and Australia. Minimum order quantities start at 100 units for Ready-to-Go formulas and up to 500 for custom routes, and you own the IP of a bespoke formula before manufacturing begins.
- Ask The Chemist (30 minutes, $150): sense-check your concept and claims wording.
- The Accelerator (4–6 months, from $2,000–$5,000): a semi-custom route to launch faster.
- The Visionary (9–12 months, from $4,000): a bespoke formula built from scratch with full IP transfer.
- Ready-to-Go formulations: stability-tested bases you can brand with a low MOQ.
Ready to talk it through? Get in touch and we will help you choose the right pathway. Regulations change, so treat this article as general guidance and confirm current requirements for your product with the relevant authority.
Frequently asked questions
Can I call my product an acne treatment in NZ or Australia?
Not as a cosmetic. Claiming to treat or cure acne makes a product a therapeutic good in Australia, with different registration requirements, and it can make it a medicine in New Zealand.
Can I use the word "acne" on a cosmetic label at all?
Australian guidance allows some anti-acne skincare that only prevents acne through cleansing, moisturising, exfoliating or drying the skin, if it meets the Excluded Goods Determination. Safer wording usually focuses on "oily" or "blemish-prone" skin types. Get your wording reviewed first.
Is niacinamide allowed in cosmetics in NZ and Australia?
Niacinamide is widely used in cosmetics in both markets. Concentration, claims and the full formula still need to be assessed, and Australian ingredients must be covered under AICIS.
Does an acne-prone range need stability and preservative testing?
Yes, for any water-containing formula. We recommend 12-week accelerated stability testing, and preservative efficacy testing is NZ$1,200 per formula with us.
What is the minimum order for a custom acne-prone formula?
MOQs at The INCI Lab range from 100 units for Ready-to-Go formulas to around 500 for custom routes.
Can I formulate vegan, cruelty-free and fragrance-free blemish-prone skincare?
Yes. All three are core capabilities and are particularly well suited to sensitive, acne-prone customers.