Expiration date and PAO for Cosmetics – Obelis Group
The purpose of the EU Cosmetics Regulation (1223/2009) is to ensure the safety of cosmetic products sold on the internal market, even if they are manufactured outside the European Union. Thus, the core element of cosmetic safety compliance is the Safety Assessment, which includes (among others) stability testing. This specific test evaluates the shelf life of the finished products or their Period After Opening (PAO). Those elements indicate how long a cosmetic properly stored remains safe for use and maintains its function.
Key elements of the expiry date and PAO
According to the EU Cosmetics Regulation, if the shelf life is lower than 30 months, the product packaging must display an expiry date. On the other hand, if the shelf life is longer than 30 months, no indication of the expiry date is necessary on the packaging. In this case, the Period After Opening (PAO) is mandatory.
The PAO corresponds to the period during which the product is stable and can be used without posing any risk to human health after opening. Therefore, it is an assessment of the stability of the product towards the risk of microbial contamination following the first use.
The PAO determination also takes into account the type of product and its claim. For example, cosmetics applicable to sensitive body parts (e.g., around the eyes) or on more vulnerable consumer groups (e.g., children under 3 years) require a shorter PAO.
The PAO is indicated on the packaging with the below open jar symbol, and inside the jar are the months the product is safe after opening:
On the other hand, the symbol of the expiry date is the below hourglass followed by the expiry date (ex., 31/12/2024):
If the symbols are not used, then the expiry date or PAO must be mentioned using wordings to be translated into the national languages of the Member States where the product is marketed.
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Do you need a stability test for your cosmetic products? Do you want to verify if your packaging meets all regulatory requirements? Do you want help to ensure the compliance of your cosmetic products?
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Article updated in June 2023
References:
European Commission. (2009). Regulation (EC) No 1223/2009 of the European Parliament and of the Council of 30 November 2009 on cosmetic products. Retrieved on 22.06.2023