What Is IChEMS
What is IChEMS?
IChEMS is Australia's Industrial Chemicals Environmental Management Standard. It sets nationally consistent standards for how industrial chemicals are imported, manufactured, exported, used and disposed of, so that they do less harm to the environment (DCCEEW, IChEMS page). The federal environment department (DCCEEW) keeps the IChEMS Register. The Commonwealth, states and territories implement the standard together.
Approach: I read the IChEMS Register of Scheduled Industrial Chemicals and DCCEEW's official IChEMS page.
What it covers
- It deals with environmental risk only. It "does not explicitly manage risk to human health." It works alongside the health department's controls, consumer product safety (ACCC) and worker safety (Safe Work Australia) (DCCEEW).
- Australia's industrial chemicals roadmap sets out how the framework is delivered. All Australian environment ministers agreed it, and it was released in March 2022. The protections become comparable across Australia as each government adopts IChEMS into its own laws (DCCEEW).
- In the 2024–25 Federal Budget, the government dropped its plan to recover the costs of running the Register (DCCEEW).
The Register and its seven schedules The Register is set up under the Industrial Chemicals Environmental Management (Register) Act 2021. The scheduling decisions are made in the Industrial Chemicals Environmental Management (Register) Instrument 2022 (F2022L01658) [1]. Each chemical goes into a schedule according to its environmental risk, and the controls get stricter as the schedule number rises:
| Schedule | Risk band | Example entry and measures |
|---|---|---|
| 1 | Not appropriate for listing in the other schedules | IChEMS Minimum Standards "must be complied with" [1] |
| 2 | Unlikely to cause harm to the environment | e.g. boric acid and precursors [2] |
| 3 | Potential to cause harm | e.g. a firefighting-foam surfactant (CAS 64265-45-8), in effect from 1 January 2025 [3] |
| 4 | May cause harm | e.g. limonene, in effect from 1 January 2027 [4]; PFBA/PFPeA/PFHxA [5] |
| 5 | Likely to cause harm | e.g. TBBPA: "must" not be discharged to sewer unless permitted under an approved agreement; waste "must" be managed in an environmentally sound manner; in effect from 1 January 2027 [6] |
| 6 | Likely to cause serious or irreversible harm, with essential uses | e.g. mercury: manufacture, import, export and use prohibited except for listed essential uses and other exemptions; waste threshold 15 mg total mercury/kg; in effect from 1 July 2026 [7] |
| 7 | Likely to cause serious or irreversible harm, with no essential uses | e.g. SCCPs: prohibited except as unintentional trace contamination (≤1% w/w in substances, ≤0.15% w/w in articles), research use, or under a hazardous waste permit; in effect from 1 July 2024 [8] |
The higher schedules also set rules for waste treatment and disposal, and for stockpiles. A stockpile holder must notify the relevant environment protection agency and manage the stockpile as waste. Recovering or recycling the chemical from waste is barred [8].
What is listed now The Register version I read has 54 entries. Schedule 7 holds the persistent organic pollutants: PFOS [9], PFOA [10], PFHxS [11], PCBs [12] and HBCDD [13]. Schedule 6 includes decaBDE [14], Dechlorane Plus [15] and UV-328 [16]. DCCEEW also posted a news item on 22 September 2026 titled "New proposed standards for industrial chemicals" (DCCEEW).
I can list every scheduled entry with its measures, or check whether a particular chemical (by name or CAS) is scheduled.
What does IChEMS mean for PFAS in Australia?
IChEMS sets up a tiered PFAS regime. PFOS, PFOA and PFHxS have been banned in Schedule 7 since 1 July 2025. PFHpS, PFNS and PFDS join them on 1 January 2027. From 1 July 2027 the shorter-chain PFAS in Schedules 4 and 5 move to controlled use: Commonwealth authorisation to import or export firefighting foam, transition strategies, and AFFF only in emergencies.
Approach: I read every PFAS entry in the IChEMS Register of Scheduled Industrial Chemicals (Register Instrument 2022, F2022L01658).
PFAS on the Register
| Schedule | PFAS entry | In effect |
|---|---|---|
| 7 (serious or irreversible harm, no essential uses) | PFOS, its salts, POSF and precursors | 1 Jul 2025 [9] |
| 7 | PFOA, its salts and related compounds | 1 Jul 2025 [10] |
| 7 | PFHxS, its salts and related compounds | 1 Jul 2025 [11] |
| 7 | PFHpS, its salts and precursors | 1 Jan 2027 [17] |
| 7 | PFNS and PFDS, their salts and precursors | 1 Jan 2027 [18] |
| 5 (likely to cause harm) | PFBS class | 1 Jul 2027 [19] |
| 5 | PFPeS class | 1 Jul 2027 [20] |
| 5 | PFHpA class | 1 Jul 2027 [21] |
| 5 | 6:2 fluorotelomer sulfonamides (14 CAS numbers listed) | 1 Jul 2027 [22] |
| 4 (may cause harm) | PFBA, PFPeA, PFHxA, their salts and precursors | 1 Jul 2027 [5] |
None of these PFAS is in Schedule 6, which is the tier that keeps essential uses. The Schedule 6 entries are UV-328, mercury, Dechlorane Plus, decaBDE/nonaBDE and DBDPE [16]. I also searched for PFNA, PFDA and C9+ carboxylic acids and found no entry for them.
Schedule 7: bans
Activities covered. Import, export, manufacture and use are prohibited, whether the chemical is on its own, in a mixture or in an article. The only exceptions are:
- Unintentional trace contamination. The limits for PFOS, PFOA and PFHxS are:
- ≤0.025 mg/kg for the acid and its salts.
- ≤1 mg/kg for any individual related compound or a combination of them.
- For Class B foam already installed in mobile or fixed systems: ≤0.8 mg/kg for PFOS and PFOA, and ≤0.1 mg/kg for PFHxS.
- The department is to review these trace limits by 1 July 2027 [9][11].
- Research or laboratory purposes.
- Import or export under a hazardous waste permit.
- Articles already in use on or before 1 July 2025, or on or before 1 January 2027 for PFHpS, PFNS and PFDS [10][17]. The PFHpS and PFNS/PFDS entries also allow use "for the purposes of environmentally sound disposal" [18].
Waste.
- At or above 1 mg/kg (acid plus salts) or 40 mg/kg (sum of related compounds), waste "must" be treated so the chemical is destroyed or irreversibly transformed. Environmentally sound authorised disposal is allowed where destruction is not the environmentally preferable option.
- Waste below those levels "must" still be managed in an environmentally sound manner.
- Diluting waste to get below a threshold is barred.
- Disposal "must not" lead to recovery, recycling or re-use [10].
Stockpiles. If an activity is no longer permitted, the stockpile holder "must" notify the environment protection agency of the stockpile's nature and size and manage it as waste [9].
Drafting slip in the source. Paragraph (h) of the PFNS/PFDS entry gives the waste thresholds in terms of "PFHpS", but paragraph (i) of the same entry refers to PFNS and PFDS [18].
Schedules 4 and 5: controlled use from 1 July 2027
The Schedule 5 entries (PFBS, PFPeS, PFHpA, 6:2 FTSAs) share the same measures [19]:
- Import and export of firefighting foams containing them "must be authorised" under a Commonwealth law.
- Use "should not occur" where an effective and feasible alternative is available.
- Users "must" develop a transition strategy and give it to their environment protection agency.
- AFFF "must only" be used in emergencies, and releases "should be fully contained".
- Waste "must not" be released, and "must" be managed in an environmentally sound manner.
The Schedule 4 entry (PFBA, PFPeA, PFHxA) has the same foam-authorisation, alternatives, transition-strategy, AFFF and no-release measures. It has no separate environmentally sound waste-management clause [5].
Scope rules.
- The Schedule 4 entry excludes precursors that also degrade to Schedule 5, 6 or 7 substances (for example PFHpA or PFOA). It also excludes C1-C5 hydrofluorocarbons and 6:2 FTSAs [5].
- The PFOA entry excludes fluoropolymers covered by CF3[CF2]n-R' with n >16, and C8F17-X where X is F, Cl or Br [10].
- All the Schedule 4 and 5 PFAS decisions "will be reviewed after July 2029."
What it means in practice
- Importers and formulators: check products against the Schedule 7 trace limits now. From January 2027 that includes PFHpS, PFNS and PFDS.
- Foam users and suppliers:
- Installed Class B systems may continue only under the Schedule 7 foam trace limits.
- From July 2027, short-chain-PFAS foams need Commonwealth import or export authorisation and may be used in emergencies only.
- Users of Schedule 4 and 5 PFAS: prepare transition strategies for your environment protection agency before 1 July 2027.
- Waste holders: PFAS waste at or above 1 mg/kg (or 40 mg/kg for related compounds) needs destruction treatment unless that is not the environmentally preferable option.
I can check a specific PFAS by CAS number against these entries if that would help.
How do AICIS recommendations feed into IChEMS?
AICIS (the federal health department's industrial chemicals regulator) does the science and recommends. DCCEEW and the Environment Minister make the IChEMS scheduling decision, after hearing from the IChEMS Advisory Committee and consulting the public. The states and territories then apply the Register. Two kinds of AICIS recommendation reach IChEMS. One goes to DCCEEW asking it to schedule a chemical under the Industrial Chemicals Environmental Management (Register) Act 2021; there are seven of these, and six are now on the Register. The other goes to state and territory environment agencies; there are 27 of these, all for lead and zinc substances, and none has moved past "Referral made".
Approach: I searched the AICIS Risk Management Recommendations Register, the IChEMS Register of Scheduled Industrial Chemicals and the Industrial Chemicals Act 2019, and read DCCEEW's IChEMS roadmap, Advisory Committee and consultation pages. The Register Act 2021 itself is not in the datasets, so the steps below come from DCCEEW's own description, not the Act's sections.
How a recommendation becomes a scheduling decision
- AICIS evaluates and recommends.
- One object of the Industrial Chemicals Act 2019 is "the provision of information and recommendations about managing the risks arising from the introduction and use of industrial chemicals" [23].
- When an evaluation finds risks, the evaluation statement "must" set out the proposed means of managing them. For chemicals on an assessment certificate, that includes "any recommendations relating to the introduction or use" (s73(2)(d)) [24]. For evaluations the Executive Director starts (s74), it includes "the proposed means for managing any risks" (s78(2)(d)) [25]. Both statements "must" be published on the AICIS website.
- Who does what. The roadmap gives AICIS three jobs: "conduct environmental risk assessments", "recommend risk management measures" and "recommend scheduling decisions". The governments then "Schedule and regulate": the "Commonwealth makes chemical scheduling decisions", assigns measures, records them on the Register and consults stakeholders. The states and territories "Incorporate IChEMS Register into jurisdictional frameworks". IChEMS "uses AICIS risk assessments to" schedule chemicals and recommend actions for different end uses (DCCEEW roadmap).
- IChEMS Advisory Committee. The committee is set up under the Register Act and "provides expert advice to the Environment Minister on industrial chemicals scheduling decisions". It weighs things the AICIS risk assessment does not decide: essential uses in Australia, viable alternatives, and the social or economic impact of restricting the chemical. The Minister or their delegate considers its advice when making the decision (DCCEEW, Advisory Committee).
- Public consultation, then the decision. The latest round covered 10 proposed decisions and ran from 21 September to 23 October 2026. DCCEEW received 76 submissions, and the date for final decisions is "TBA" (DCCEEW consultation). That consultation page does not say whether AICIS assessments are the basis for those 10 proposals. AICIS closes off its own entry with the note "Final scheduling decision is published on the IChEMS website. The final decision includes the date of effect" [26].
AICIS recommendations to DCCEEW to schedule a chemical (7)
| Chemical (CAS) | Referred | AICIS status | IChEMS outcome |
|---|---|---|---|
| Hexachlorobenzene (118-74-1) | 9/01/2023 | Actioned – implemented, 9/12/2024 [26] | Schedule 7, in effect 1 Jul 2025 [27] |
| Pentachlorobenzene (608-93-5) | 9/01/2023 | Implemented, 11/12/2023 [28] | Schedule 7, 1 Jul 2024 [29] |
| PentaBDE (32534-81-9) | 21/07/2022 | Implemented, 11/12/2023 [30] | Schedule 7 pentaBDE/tetraBDE entry, 1 Jul 2024 [31] |
| DBDPE (84852-53-9) | 24/07/2022 | Implemented, 9/07/2025 [32] | Schedule 6, 1 Jan 2027 [33] |
| Dechlorane Plus (13560-89-9) | 5/07/2023 | Implemented, 16/07/2024 [34] | Schedule 6, 1 Jul 2026 [15] |
| C13-rich isoalkyloxypropyl propanediamine acetates (151789-08-1) | 21/07/2022 | Implemented, 21/07/2026 [35] | Schedule 3, 1 Jan 2027 [36] |
| 1,3-Dioxane, 2-(2,4-dimethyl-3-cyclohexen-1-yl)-5-methyl-5-(1-methylpropyl)- (117933-89-8) | not given | Referral made, 11/08/2025 [37] | No IChEMS entry found |
Things to note from these:
-
"Implemented" on the AICIS register means the scheduling decision has been made. It does not mean the controls apply yet. DBDPE was implemented in July 2025 but its entry takes effect on 1 January 2027.
-
Some IChEMS entries carry an AICIS condition. The Schedule 3 propanediamine entry applies only if the chemical "must be introduced and used in accordance with the terms of the defined scope of assessment outlined in the Australian Industrial Chemicals Introduction Scheme assessment statement" [36].
-
Two Schedule 3 fragrance chemicals quote AICIS-derived PNECs:
The Register says this kind of figure "is not a regulatory limit or standard" [38].
AICIS recommendations to state and territory environment agencies (27)
All 27 are of the type "Recommendation relating to environmental risk management", and every one is still at "Referral made".
Lead substances (18), referred 25/10/2022:
- Lead (7439-92-1) [40]
- Lead oxide PbO (1317-36-8) [41]
- Lead oxide (1335-25-7) [42]
- Lead ores, sintered (69029-74-9) [43]
- Lead, dross (69029-52-3) [44]
- Lead, dross, bismuth rich (69029-46-5) [45]
- Lead, dross, antimony rich (69029-45-4) [46]
- Lead, antimonial, dross (69029-51-2) [47]
- Lead, antimonial (69029-50-1) [48]
- Lead, zinc dross (94551-60-7) [49]
- Lead alloy, base, dross (Pb, Sn) (69011-60-5) [50]
- Lead alloy, base, dross (69011-59-2) [51]
- Slags, lead smelting (69029-84-1) [52]
- Slags, lead reverbatory smelting (69029-58-9) [53]
- Slags, precious metal recovery lead refining (69029-85-2) [54]
- Residues, lead smelting (69029-79-4) [55]
- Residues, precious metal recovery lead refining (69029-80-7) [56]
- Flue dust, lead refining (69029-67-0) [57]
Zinc substances (9), status date 25/02/2026:
- Zinc (7440-66-6) [58]
- Zinc oxide (1314-13-2) [59]
- Zinc sulfate (7733-02-0) [60]
- Zinc, dross (69011-50-3) [61]
- Slimes and sludges, zinc sulfate electrolytic (69012-43-7) [62]
- Slags, zinc sinter-redn. (69012-36-8) [63]
- Leach residues, zinc ore-calcine, zinc cobalt (69012-72-2) [64]
- Leach residues, zinc ore-calcine (69012-70-0) [65]
- Flue dust, zinc-refining (69012-63-1) [66]
AICIS is not the only route onto the Register. Many entries come from Australia's international obligations. All governments agreed to "Prioritise scheduling of industrial chemicals to meet Australia's obligations under international conventions" (DCCEEW roadmap). The Advisory Committee's meetings on PFOS/PFOA/PFHxS, SCCPs, UV-328, mercury and, most recently, HFCs and long-chain PFCAs were framed around the Stockholm, Minamata and Montreal/Kigali listings (DCCEEW, Advisory Committee). None of those chemicals appears among the seven AICIS "schedule the chemical" recommendations above.