Can an indie brand launch a retinol product in New Zealand and Australia? Yes. Retinol and its esters are already listed on the Australian inventory (AIIC), so they remain accessible, but retinal needs an AICIS assessment certificate from 27 June 2026. If you plan to export to the EU, new products must also meet 0.3% (face) and 0.05% (body lotion) retinol-equivalent limits. Stability is the real challenge, so plan for it from day one.
Retinol is one of the most requested actives we hear about at The INCI Lab, and one of the easiest to get wrong. It is unstable, it can irritate, and the rules around vitamin A are shifting in your export markets. This guide explains what founders need to decide before a formula goes to bench.
Why is retinol so hard to formulate?
Retinol is sensitive to light, oxygen and heat. Left unprotected, it oxidises and loses potency, sometimes before the product reaches a customer. That means a retinol product is only as good as its whole system: the antioxidants, chelating agents, emulsion type, pH, and the packaging all work together.
This is why retinol formulas usually go through a longer development and testing cycle than a simple moisturiser. We typically recommend 12-week accelerated stability testing and assay of the active over time, not just a visual check for colour and separation.
What do the new EU retinol limits mean for NZ and Australian brands?
An April 2024 amendment to the EU Cosmetics Regulation caps retinol and related vitamin A compounds at 0.3% retinol equivalent in facial skincare and 0.05% in body lotions. Under the transition, new non-compliant products cannot be placed on the EU market from 1 November 2025, and remaining non-compliant products must be off shelves from 1 May 2027. Products also need a label statement that they contain vitamin A-related compounds that add to daily vitamin A intake.
If the EU or UK is on your roadmap, formulate to these limits from the start rather than reformulating later. Our guide to exporting to the EU and UK covers the Responsible Person and CPNP steps that sit alongside the ingredient limits.
What is the AICIS retinal rule in Australia?
From 27 June 2026, AICIS requires an assessment certificate before retinal (CAS 116-31-4) can be imported or manufactured for any consumer use, including serums and creams. The exempted and reported pathways no longer apply to it. AICIS has pointed to retinal's conversion to retinoic acid and a presumed developmental toxicity classification as the reason.
Retinol and retinol esters already listed on the inventory are not affected by that change. The practical lesson is to check each retinoid separately by CAS number and intended use, rather than assuming they share a pathway. Our overview of AICIS and TGA compliance explains how this fits into the wider picture.
How do you keep a retinol product stable and gentle?
We approach it as a system with four parts:
- Protect the active. Antioxidant and chelator choices, oxygen-limiting processing, and encapsulated or stabilised retinol forms are all on the table.
- Choose packaging early. Airless pumps or opaque, tightly sealed tubes limit light and air. See our notes on packaging compatibility testing.
- Balance efficacy and tolerance. A lower, well-delivered dose is often a better customer experience than a high percentage that irritates.
- Prove the preservative system. Active-rich formulas still need preservative efficacy testing, which starts from NZ$1,200 per formula.
What claims can you make about a retinol product?
Be careful. Language about changing skin structure or treating conditions can push a product towards therapeutic territory in Australia and New Zealand. Stick to appearance-based, substantiated claims such as improving the look of fine lines. Our guide to what you can legally claim on a skincare label goes through this in detail.
How does The INCI Lab help you launch a retinoid product?
Every pathway comes with the same indie-first foundations: low MOQs (100 to 500 units), full IP transfer to you before manufacturing, and compliance documentation for NZ, AU, EU and US markets. Cruelty-free, vegan and fragrance-free formulation are all available.
- Ask The Chemist: a 30-minute consult at $150 to sense-check your idea or troubleshoot an unstable retinol formula.
- The Accelerator: a semi-custom route, 4 to 6 months, starting from $2,000 to $5,000.
- The Visionary: bespoke from-scratch formulation, 9 to 12 months, starting from $4,000+.
Not sure where to begin? Get in touch and we will help you pick the right pathway.
Frequently asked questions
Is retinol legal in skincare in New Zealand and Australia?
Yes. Retinol and retinol esters listed on the Australian inventory remain available for cosmetic use. Always confirm your specific ingredient and supplier documentation, and keep claims cosmetic rather than therapeutic.
Is retinal different from retinol for compliance?
Yes. From 27 June 2026, retinal needs an AICIS assessment certificate before import or manufacture for consumer use, whereas retinol and listed retinol esters are unaffected by that rule.
What are the EU retinol limits?
0.3% retinol equivalent for facial skincare and 0.05% for body lotions, with a mandatory vitamin A intake label statement. New non-compliant products are barred from 1 November 2025, and all non-compliant stock from 1 May 2027.
How long does stability testing take for retinol products?
We recommend 12-week accelerated testing with potency assays, alongside real-time monitoring, before you commit to a production run.
Can I make a small batch of a retinol serum?
Yes. Our MOQs start at 100 to 500 units depending on the pathway, so you can validate demand before scaling.
Do I need special packaging for retinol?
Strongly recommended. Airless or opaque packaging reduces light and oxygen exposure, and it should be tested for compatibility with your formula.