One question we are regularly asked is “What date should go on a label?” There are two legal options for cosmetic labelling purposes. It is known as the ‘minimum durability’ of a product and how long it will continue to provide the cosmetic function and remain safe for the consumer to use:
• Either the egg timer symbol with a future date OR the words “Best used before the end of” followed by a date written as month and year or day, month, and year. An example of this might be the egg timer symbol with a date twelve months after manufacture suggesting the product should be used by the end of this time period. Text such as BBE as is often seen on food is NOT suitable labelling.
• The open jar with a time period such as 12m inside it is used for products that will retain function and remain safe for a period of at least 30 months. The number of months or years inside the jar symbol is the time period that the cosmetic product should be used by AFTER the packaging has been opened or, for long term stable but unpackaged products, the period of time after it has been first used. Whichever of these options are used, appropriate instructions for storage and use should be included in order for these dating systems to be accurate.
My CPSR does not tell me which date to use
The CPSR authenticates the consumer safety of the products included based on the ingredients and final composition. Given the variety of manufacturing processes, ingredient and product storage, ingredient purchasing options, clean area maintenance and care of any packaging etc across makers; the report cannot give you a definitive product durability.
What do Soaposh recommend?
For most products we would recommend that the egg timer symbol with a date six months after manufacture would be suitable when you are initially starting to make these products for sale. This is not because of any safety aspects that have been missed in your report but that the product itself may undergo changes over time aesthetically which could affect your own preferences for product appearance.
As an example, a bath bomb may be brightly coloured and be a perfectly hard texture when it is initially manufactured. Over time, the colour may fade and not necessarily in a uniform way. If the packaging is permeable (will allow air to move in and out) higher humidity levels may cause warts to appear, the bath bomb to soften, fizz to deplete, the packaging to swell with air etc. Very cold and damp temperatures can do the same. None of this says the bath bomb is unsafe to use – but the action in use and the appearance may undergo changes over time. Similarly, in a body oil, one of the composition oils may develop some rancidity interfering with the scent, the colour may alter, texture may thicken or thin. Temperatures, light, time, can all create some changes. Again, while the original formulation remains safe to use, the appearance a year after making may not reflect the product you want advertising your brand vision.
Your emulsified sugar scrub may last the full 30 months or more in an unopened tub meaning the open jar symbol can be used. However, if your customer opens it, uses it with wet, dirty hands to introduce contaminants then sets it aside and doesn’t attempt to use it again for another twelve months, that water contamination may have started to degrade the product. If you haven’t actually opened your own product thirty months after making it – can you really just assume it will look perfect after that time? You need to retain retail samples and observe them over time. Also put them into different scenarios so you can keep your packaging instructions up to date. As an example, does the product react differently if it is kept in a humid bath room on a window sill versus a cool cupboard with no sunlight source. Does your packaging have any effect on the product eg coloured bottles vs clear bottles. Barrier packaging such as shrink wrap vs pretty papers.
Summary
These are all aspects that we cannot insert arbitrarily into a CPSR as they determine the appearance / function of of the product and the CPSR assesses the safety of the formulations. No one in the assessment team is able to monitor your manufacturing processes, your ingredients, your GMP, your packaging effects, your product when challenged by different environmental factors, use it or generally review it after a year or more to provide a perfectly suitable period of durability that meshes with how you want the product to look.
The egg timer and a six months post manufacture date will give you a period of time in which you can start collating your observation notes and determining suitable time lines to ensure your product is used while it remains the best possible version of itself. Starting with the six months and working out your own date information as time passes means you can adjust it and extend it as you experience your own products.
