Cosmetics Expiry Date: The 30-Month Rule and Best-Before Explained

Does your cream need a printed expiry date, an open-jar symbol, or both? Many brands are unsure, and labels on the market do not always help. The rule behind the cosmetics expiry date in the EU is simpler than it looks. In short: if your product stays fit for use for 30 months or less, you must print a date of minimum durability, preceded by the hourglass symbol or the words “best used before the end of”; if it lasts longer than 30 months, the date is optional and you print the period after opening (PAO) instead, unless the PAO concept does not apply to the product. This guide explains the 30-month rule, how to write the date and how to decide which side of the line your product falls on.

The short answer

EU law does not use the phrase “expiry date” for cosmetics. Article 19(1)(c) of Regulation (EC) No 1223/2009 speaks of the “date of minimum durability”: the date until which the product, stored under appropriate conditions, continues to fulfil its initial function and remains safe. It is mandatory only for products whose minimum durability is 30 months or less. Everything else carries a PAO, such as “12M”, where relevant. Your shelf life must be backed by stability data in your safety file.

What the 30-month rule says

• Minimum durability of 30 months or less: the date of minimum durability is mandatory.
• Minimum durability of more than 30 months: the date is not mandatory, but the label must show how long the product can be used safely after opening, using the open-jar symbol followed by a period in months and/or years.
• PAO not relevant: the PAO can be left out where the concept of durability after opening does not apply.

The 30-month threshold is about the product’s proven durability, not about how long you expect it to sit on a shelf. A brand cannot avoid the date simply by preferring a PAO; the stability data decide.

Read also Cosmetic Shelf Life and PAO: How to Set Expiry on Cosmetics

How to write the date correctly

• Symbol or words. The date, or a note saying where it appears on the pack, must be preceded by the hourglass symbol from Annex VII of the Regulation or by the words “best used before the end of”, in the language required where the product is sold.
• Format. Month and year, or day, month and year, in that order. Cosmetics Europe’s labelling guidelines give MMYYYY or MMYY and DDMMYYYY or DDMMYY as examples.
• Location. If the date is not next to the symbol or the words, the label must make clear where to find it, for example “see base of tube”.
• Storage conditions. If the durability depends on storage, such as keeping the product below a certain temperature, add that condition.
• Legibility. The information must be indelible, easily legible and visible, on both the container and the outer packaging.

Avoid date formats that readers in other markets could misread. “06/2027” is unambiguous; “06/07/27” is not.

When does the PAO apply instead?

For products that remain stable for more than 30 months, the PAO tells the consumer how long the product stays safe once opened, for example 6M, 12M or 24M. The figure is the brand’s responsibility and should be based on stability data, the challenge test result and the type of packaging. A jar that fingers dip into usually justifies a shorter PAO than an airless pump with the same formula.

When is neither a date nor a PAO needed?

Cosmetics Europe’s labelling guidelines, referring to Recital 48 of the Regulation and earlier Commission guidance, give three situations where the PAO is not relevant:

• Single-use products, such as a sachet used once.
• Packs that do not allow contact between the product and the outside environment, such as aerosol dispensers.
• Products with no risk of deterioration that would make them unsafe, for example products of low microbiological risk as described in ISO 29621, such as some high-alcohol perfumes.

These exemptions only remove the PAO. If such a product lasts 30 months or less, it still needs a date of minimum durability. And your safety assessor should agree with any exemption you claim.

Read also Natural Cosmetics Stability: Special Challenges and Solutions

How do you know whether your product lasts more than 30 months?

The answer comes from your data, not from guesswork:

• Stability testing. Accelerated and real-time studies show how appearance, odour, pH, viscosity and the packaging change over time.
• Microbiological quality. Counts at the start and end of storage show whether contamination rises.
• Preservation. A challenge test shows whether the preservative copes with contamination during use, which supports the PAO.
• Packaging compatibility. Interactions between product and pack can shorten shelf life even when the formula itself is stable.

A stability and compatibility test gives your safety assessor the evidence to support the shelf life and PAO in the CPSR. Many natural, low-preservative or vitamin-rich formulas end up below 30 months and therefore need a printed date.

A worked example

A brand makes a natural face oil with a vitamin C derivative. Stability data support 18 months unopened. Because 18 is below 30, the label must carry a date. A batch produced in March 2026 is labelled with the hourglass symbol followed by “09/2027”, plus “store below 25 °C” because the data showed faster degradation in heat. A second product, a well-preserved body lotion with data supporting more than 30 months, carries a 12M PAO and no date.

What about the US and the UK?

In the United States, the FDA states that no law or regulation requires cosmetics to carry an expiration date, although determining shelf life remains the manufacturer’s responsibility. Products that are also drugs, such as sunscreens, must be stability-tested and carry expiration dates. Great Britain’s cosmetics rules are based on the same text as the EU Regulation and use the same 30-month approach, but check current UK guidance before printing labels for that market.

Read also What Is Cosmetic Stability Testing? A Plain-English Guide

Label checklist for shelf-life information

• Is the proven minimum durability 30 months or less? Then print the date.
• Is the date preceded by the hourglass or the required words in the local language?
• Is the date in month/year or day/month/year order, and easy to find?
• Does the product need a storage condition next to the date?
• If it lasts longer than 30 months, is the PAO printed, or is an exemption documented?
• Does the batch number link the pack to the stability data in your file?

Common mistakes

• Printing only a PAO on a product that lasts less than 30 months.
• Writing “EXP” without the symbol or the required words.
• Using an ambiguous day/month format.
• Choosing a shelf life longer than the stability data support.
• Claiming a PAO exemption without your safety assessor’s agreement.

Frequently asked questions

Can I print both a date and a PAO?

Yes. Many brands do, and it gives consumers more information, as long as both are supported by data and consistent with each other.

Is the date of minimum durability the same as “use by”?

No. It is a “best used before” date: the product is expected to perform and remain safe until then if stored correctly.

Can I extend the date later?

Only with new data, such as completed real-time stability results, reviewed by your safety assessor and reflected in your safety documentation.

Key takeaways

• 30 months or less: print a date of minimum durability with the hourglass symbol or “best used before the end of”.
• More than 30 months: the date is optional and a PAO is required, unless the PAO concept does not apply.
• Write month and year (or day, month and year) in that order, plus storage conditions if needed.
• Stability, microbiology and challenge test data decide which rule applies.