Topical Retinoids — Non-Prescription Cosmetic-Class

Legal Disclaimer (Adults Only, Australia)

This document provides evidence-based cosmetic-class skincare guidance for adults (18+) and does not replace medical advice, diagnosis or treatment ¹ ³. It excludes prescription retinoids and is written in accordance with Australian consumer law, AHPRA advertising rules and cosmetic regulatory frameworks ¹ ² ⁵. Patients should consult a GP, dermatologist or pharmacist for medical assessment, pregnancy considerations or skin disease management, and no part of this policy authorises non-medical staff to diagnose or treat any condition ² ³.

1. Purpose

The purpose of this policy is to define safe, evidence-based use of non-prescription cosmetic-class retinoids (retinol ≤ 1%, retinaldehyde ≤ 0.1%, retinyl esters) for improving mild photoaging, uneven texture and dyschromia while ensuring compliance with AICIS chemical regulations, ACCC consumer law, AHPRA advertising restrictions and Australian dermatology standards ¹ ² ⁴ ⁷. The policy aims to standardise recommendations, improve patient counselling and reduce the risk of misuse, adverse effects and misleading therapeutic claims in the context of cosmetic-class products only ² ⁵ ⁸.

2. Scope

This policy applies to all non-prescription retinoid products (retinol, retinal, retinyl palmitate/propionate and related esters ≤ 1%) recommended or sold within Newcastle Cosmetic Doctor for adult cosmetic use ⁴ ⁷. It excludes Schedule 4 prescription retinoids (tretinoin, adapalene, tazarotene), compounded retinoid preparations, prescription combination products and any use for the treatment of diagnosed skin disease, which remain under the jurisdiction of registered medical practitioners and TGA-regulated medicines ¹ ³.

3. Regulatory Framework

Under the Industrial Chemicals (General) Rules 2021, AICIS regulates cosmetic-class retinoids and requires that ingredients and introduction categories are appropriately recorded and managed by the business ⁴. The TGA regulates therapeutic claims and requires ARTG listing if products are represented as treating, preventing or curing disease (e.g. “treats acne”, “repairs sun damage”) rather than providing cosmetic benefit ¹ ⁵. AHPRA and the Medical Board of Australia require that all advertising of regulated health services is factual, not misleading and does not create unreasonable expectations of benefit, while ACCC enforces Australian Consumer Law against unfair, deceptive or unsubstantiated performance claims ² ⁵ ⁸.

4. Product Classification and Mechanism

Cosmetic-class retinoids (retinol, retinaldehyde, retinyl esters) act via conversion to retinoic acid in the skin and binding to nuclear retinoic acid receptors, which increases epidermal turnover, normalises keratinocyte differentiation and promotes collagen synthesis over time ⁶ ⁷. Retinaldehyde is generally more potent than retinol, which is more potent than retinyl esters, and increasing potency is associated with higher rates of irritation, particularly in sensitive or barrier-impaired skin ⁷ ⁸. Cosmetic-class strengths must remain within the ≤ 1% retinol / ≤ 0.1% retinaldehyde range and must not be presented as equivalent to prescription-strength tretinoin or other Schedule 4 retinoids ¹ ⁴.

5. Indications and Patient Selection

Suitable cosmetic-class indications include mild photoaging, fine lines, rough or dull texture and mild, non-medical uneven pigmentation in otherwise healthy adult skin ⁷ ⁹. Patients with active eczema, significant barrier damage, uncontrolled rosacea, open wounds, infection, recent sunburn or known retinoid allergy should not commence retinoids until medically reviewed, because these scenarios may require prescription or disease-specific management outside cosmetic-class practice ³ ⁷. Pregnancy and breastfeeding are exclusion criteria because Australian guidance recommends avoiding topical retinoids in these groups as a precaution, even at lower cosmetic-class strengths ¹ ⁹ ¹⁰.

6. Application Protocol (Clinic Recommendation)

Initiation should start with a low to moderate strength (e.g. 0.25–0.3% retinol) applied two to three nights per week, then slowly increased to alternate nights and finally nightly use over approximately 6–8 weeks as tolerated ¹⁰ ¹¹. Application is to clean, completely dry skin to reduce stinging, using a pea-sized amount for the full face, avoiding eyelids and corners of the nose, followed by a gentle barrier-supporting moisturiser; product must not be used more than once nightly regardless of tolerance ⁷ ¹⁰ ¹³. Strict daily broad-spectrum SPF50+ is mandatory whenever the UV Index is ≥ 3, in line with Cancer Council Australia recommendations, and patients must be advised that failure to use sunscreen can worsen pigmentation or irritation ¹¹ ¹².

7. Expected Improvement Timeline

Most patients notice increased brightness and smoother surface texture after 4–6 weeks of consistent use as superficial corneocyte build-up decreases ¹⁰ ¹⁴. Improvement in fine lines and more even tone typically becomes evident after approximately 12 weeks, and collagen-related changes are gradual, usually requiring 6–12 months of uninterrupted use to consolidate ¹⁴ ¹⁵. Results are maintained only while treatment is ongoing, and patients must be counselled that stopping product will gradually return the skin toward baseline over time, which aligns with Australian consumer law requirements for realistic representations of benefit duration ² ⁵ ¹⁴.

8. Adverse Effects and Management

Common early adverse effects include mild erythema, dryness, tightness and micro-flaking, particularly in the perinasal and perioral regions, and these are best managed by temporarily reducing frequency, moisturiser buffering and avoiding concurrent strong exfoliants ⁷ ¹⁰ ¹³. More significant reactions such as burning, marked swelling, oozing or suspected allergic contact dermatitis require cessation, cool compresses where appropriate and clinical review by a medical practitioner to exclude other causes and consider alternative management ³ ⁷. All moderate to severe reactions must be documented in the Adverse Reaction Register, and any serious or unexpected event should be escalated in line with NSW Health clinical risk management principles ³ ⁹.

9. Storage and Quality Control

Retinoid products must be stored below 25°C, protected from light and excessive heat, in accordance with manufacturer recommendations and general Australian cosmetic storage guidelines ⁴ ⁸. A first-in, first-out (FIFO) system must be used to minimise expiry risk, with batch numbers, expiry dates and Safety Data Sheets (SDS) recorded and readily accessible for all stocked products ⁴ ⁸. Staff must visually inspect products for colour change, separation or rancid odour prior to dispensing, as these findings may indicate oxidation or instability and require disposal according to clinic policy and environmental rules.

10. Advertising and Labelling Standards

All advertising and written materials must comply with AHPRA, Medical Board of Australia and ACCC guidelines, avoiding therapeutic claims such as “treats wrinkles”, “repairs sun damage” or “cures acne” for cosmetic-class retinoids ¹ ² ⁵. Acceptable wording includes phrases such as “helps improve the appearance of fine lines”, “supports smoother-looking skin” or “assists in improving skin texture”, provided claims are honest, substantiated and not misleading ² ⁵. Product labels and patient leaflets must highlight night-time use, the need for daily SPF50+ and key contraindications (e.g. pregnancy, breastfeeding, broken skin) consistent with Australian public health advice ¹ ¹⁰ ¹¹.

11. Roles and Responsibilities

The Medical Director is responsible for approving all cosmetic-class retinoid products used in the clinic, ensuring alignment with regulatory requirements and reviewing any significant adverse reactions or complaints ² ³. The Clinic Manager must ensure AICIS obligations, SDS documentation, storage and stock rotation are maintained, and that staff receive appropriate training in product counselling and contraindications ⁴ ⁵. Therapists and other staff involved in skincare recommendations must follow this protocol, provide clear written and verbal information, and document product selection, strength and frequency in the patient record ³ ⁸.

12. Audit and Review

This policy and related procedures must be reviewed at least every two years or sooner if there are material changes to AICIS, TGA, AHPRA, ACCC or NSW Health guidance regarding cosmetic-class products or advertising standards ¹ ² ³ ⁴. Quarterly audits should review product registers, SDS files, consent documentation and samples of patient notes to confirm compliance with this policy and early identification of any patterns of intolerance or complaint ³ ⁹. Findings are to be documented and any required corrective actions implemented with follow-up review.

Sources

Therapeutic Goods Administration (TGA) 2024, Determining if your product is a cosmetic or a therapeutic good, Australian Government Department of Health and Aged Care, Canberra. Available at:, viewed 19 November 2025, https://www.tga.gov.au/resources/guidance/determining-if-your-product-cosmetic-or-therapeutic-good ↩
Australian Health Practitioner Regulation Agency (AHPRA) 2023, Guidelines for advertising a regulated health service, AHPRA and National Boards, Melbourne. Available at:, viewed 19 November 2025, https://www.ahpra.gov.au/Resources/Advertising-hub/Advertising-guidelines-and-other-guidance/Advertising-guidelines.aspx ↩
NSW Health 2021, Cosmetic procedures – frequently asked questions, NSW Ministry of Health, Sydney. Available at:, viewed 19 November 2025, https://www.health.nsw.gov.au/patients/cosmetic/Pages/frequently-asked-questions.aspx ↩
Australian Industrial Chemicals Introduction Scheme (AICIS) 2025, Personal care, skincare, make-up and other cosmetic products, Australian Government Department of Health and Aged Care, Canberra. Available at:, viewed 19 November 2025, https://www.industrialchemicals.gov.au/cosmetics-and-soap/personal-care-skincare-make-and-other-cosmetic-products ↩
Australian Competition and Consumer Commission (ACCC) 2021, Advertising and selling guide, ACCC, Canberra. Available at:, viewed 19 November 2025, https://www.accc.gov.au/system/files/Advertising%20and%20selling%20guide%20-%20July%202021.pdf ↩
Mukherjee, S, Date, A, Patravale, V, Korting, HC, Roeder, A & Weindl, G 2006, ‘Retinoids in the treatment of skin aging: an overview of clinical efficacy and safety’, Clinical Interventions in Aging, vol. 1, no. 4, pp. 327–338. Available at:, viewed 19 November 2025, https://pmc.ncbi.nlm.nih.gov/articles/PMC2699641/ ↩
Australasian College of Dermatologists (ACD) 2021, Cosmeceuticals – A–Z of Skin, ACD, Sydney. Available at:, viewed 19 November 2025, https://www.dermcoll.edu.au/wp-content/uploads/2021/05/Cosmeceuticals-A-Z-of-Skin.pdf ↩
Australian Prescriber 2023, ‘Treatments for atopic dermatitis’, Australian Prescriber, vol. 46, no. 3, NPS MedicineWise, Sydney. Available at:, viewed 19 November 2025, https://australianprescriber.tg.org.au/articles/treatments-for-atopic-dermatitis.html ↩
Australasian College of Dermatologists (ACD) 2023, Ageing skin – A–Z of Skin, ACD, Sydney. Available at:, viewed 19 November 2025, https://www.dermcoll.edu.au/atoz/ageing-skin/ ↩
Healthdirect Australia 2024, Vitamin A and your health, Healthdirect Australia, Canberra. Available at:, viewed 19 November 2025, https://www.healthdirect.gov.au/vitamin-a-and-your-health ↩
Cancer Council Australia 2024, About SPF50+ sunscreen, Cancer Council Australia, Sydney. Available at:, viewed 19 November 2025, https://www.cancer.org.au/cancer-information/causes-and-prevention/sun-safety/about-sunscreen/spf50-sunscreen ↩
Cancer Council Australia 2023, Fact sheet: Sunscreen, National Cancer Prevention Policy – UV Radiation, Cancer Council Australia, Sydney. Available at:, viewed 19 November 2025, https://www.cancer.org.au/about-us/policy-and-advocacy/prevention/uv-radiation/related-resources/sunscreen ↩
See, J-A & DeAmbrosis, K 2024, ‘Cosmeceuticals for acne – integrating actives into practice’, in Cosmetic Dermatology – ASCD Journal, Edition 10, Australasian Society of Cosmetic Dermatologists, Sydney. Available at:, viewed 19 November 2025, https://ascpd.org.au/wp-content/uploads/ASCD-Journal-Edition-10-Cosmeceuticals.pdf ↩
Kafi, R, Kwak, HSR, Schumacher, WE, Cho, S, Hanft, VN, Hamilton, TA, King, AL, Neal, JD, Varani, J & Fisher, GJ 2007, ‘Improvement of naturally aged skin with vitamin A (retinol)’, Archives of Dermatology, vol. 143, no. 5, pp. 606–612. Available at:, viewed 19 November 2025, https://jamanetwork.com/journals/jamadermatology/fullarticle/412795 ↩
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Disclaimer for Newcastle Cosmetic Doctor Policies & Procedures

The policies and procedures contained within this document are the exclusive property of Newcastle Cosmetic Doctor and are provided for internal clinical governance and educational purposes only. These materials represent the internal operational framework, safety standards, and evidence-based protocols developed and implemented by Dr. Bart John Scanlon and the Newcastle Cosmetic Doctor team. They are designed specifically for use within Newcastle Cosmetic Doctor and reflect our clinic’s own professional standards, risk assessments, and compliance obligations under Australian law and regulatory authorities. External individuals, practitioners, or organisations must not copy, reproduce, distribute, or rely upon these materials, in whole or in part, for their own clinical, commercial, or educational use without prior written consent from Newcastle Cosmetic Doctor. These materials do not constitute medical, legal, or professional advice and are not intended to be adopted as official protocols or procedures by any other entity. Any external use or adaptation must be independently reviewed and modified to meet the relevant laws, guidelines, and standards applicable to the user’s own jurisdiction, scope of practice, and facility operations. Newcastle Cosmetic Doctor and Dr. Bart Scanlon accept no liability for any loss, injury, or damage arising from the unauthorised use, reliance upon, or misinterpretation of this material.