F2024C00396 Manufactured soap

[Mike Dewhirst]

Previously, soap was just another chemical. The new (April 2024) Rules ease the way for two classes of saponification (soap) manufacture

1. Up to 10kg per year of a Listed fat or oil saponified with aqueous sodium or potassium hydroxide - Excluded "category", meaning of no interest to AICIS at all

2. Up to 100kg per year of any fat or oil saponified with aqueous sodium or potassium hydroxide - Exempted category, meaning AICIS is just as interested as with any other Exempted category chemical.

Other recipes or greater volumes need detailed categorisation as usual.

This ticket calls for a "Saponification of fat or oil with sodium or potassium hydroxide" selection plus other thingsnecessary for the software to identify the category without requiring all the chemical properties and hazards otherwise demanded.

Those other things include:

• identification of the ingredient fats/oils
• confirmation that saponification is done with sodium or potassium hydroxide
• checking that the chemical (soap) is Locally manufactured only
• up to 10kg of listed fat/oil being Excluded
• up to 100kg of any fat or oil being Exempted
• Post Introduction Declaration is not required
• Records need to be kept of the names of the fat or oil

[Mike Dewhirst]

• The actual chemical in soap has to be the oil or fat because the rules state "Listed" oil or fat at up to 10kg for it to be excluded.
• The saponification process presumably consumes the caustic solution.

So Chemintro will treat the "Soap" product as a blend of oil/fat with fragrances and other minor ingredients.

Selecting the "Soap" circumstances will trigger some tests according to the rules to determine if it is Excluded or Exempted or neither (>100kg) and therefore categorised normally.

[Mike Dewhirst]

The requirement to see if the oil is listed forces a rewrite because if it is listed and > 10kg the category is not Listed but Exempted due to the saponification process making it a different chemical.

So we have to pervert the flow of the software to detect an Excluded "category" or something which may not have been selected yet! Hence we need to start with Circumstances and if saponification is selected rejig the category from Listed to Exempted or Excluded depending on volume.

• if volume > 100kg the software won't permit selection of saponification
• at any volume <= 100kg saponification requires local manufacture not import
• at any volume <= 100kg selecting saponification results in ...
  • Exempted if the oil/fat is not listed
  • Excluded at <= 10kg if it is listed

AND if Circumstances is soap manufacture and the rules are satisfied we need to indicate that the oil/fat which is being saponified and which itself might have a CAS number is in fact a saponification reaction mass and not the original oil/fat.

To that end - and subject to further discussion with experts who might complain - we will append "(saponification reaction mass)" to the Chemical public name and close this ticket.