CPGShield resources · Federal cosmetic labeling
If you are designing a cosmetic label in the United States, one question comes up constantly:
Do I have to print an expiration date on it?
For ordinary cosmetics, the answer is usually no.
FDA states that there are currently no U.S. laws or regulations requiring cosmetics to have a specific shelf life or to print an expiration date on the label.
That answer sounds simple. It is not the end of the compliance question.
A cosmetic company is still responsible for making sure its product is safe, and FDA considers determining shelf life part of that responsibility.
So the useful question is not merely:
“Am I required to print an expiration date?”
It is:
“Do I understand how long this product remains safe and fit for its intended use, and does anything else about this product trigger a different rule?”
Cosmetics can change over time.
FDA points to factors such as:
A cream that is stable when it leaves the factory can behave differently after months in a warm bathroom.
A mascara is repeatedly exposed to microorganisms every time the wand is used.
A jar product can be contaminated through repeated finger contact.
A brand therefore needs a defensible understanding of shelf life even if the label does not contain a federally mandated expiration date.
This is where brands can get into trouble by applying a cosmetic rule to a product that is legally something else.
FDA specifically notes that some products commonly thought of as “personal care products” are regulated as drugs.
Examples include:
A moisturizer with SPF can be both a cosmetic and a drug.
Drug products are subject to additional requirements, including stability testing and, unless an exemption applies, expiration dating.
So before deciding that your package does not need an expiration date, you first need to know what legal category the product falls into.
Many founders are familiar with the open-jar symbol used internationally-for example, a jar marked “12M.”
That type of marking is common in other markets, particularly under European cosmetic rules.
But seeing it on products does not mean it is a general FDA requirement for U.S. cosmetics.
A U.S. brand can still decide to communicate useful shelf-life information voluntarily, provided the information is truthful and not misleading.
The important point is to avoid confusing voluntary or foreign-market practices with a universal FDA mandate.
Voluntary statements become part of the labeling.
That means they should be accurate.
If a brand prints “Best before 24 months” without a reasonable basis for that statement, it has created a representation about the product that consumers may rely on.
The same principle applies to storage statements such as:
If you choose to put those statements on the package, they should reflect the product and the data supporting it.
A cosmetic label review should not turn into a shelf-life study.
But it should identify when the product category or the statements on the package raise additional questions.
Before print, a brand should know:
That last point matters because expiration dating is only one of dozens of possible label issues.
A package can get the expiration question right and still miss the identity statement, ingredient format, net quantity placement, business information, warning language, or required contact information. The FDA cosmetic label rules founders most often miss covers each of those.
For ordinary cosmetics, FDA says there is no general U.S. law or regulation requiring a printed expiration date.
FDA states that manufacturers are responsible for product safety and considers determining shelf life part of that responsibility.
Sunscreens are regulated as drugs in the United States, so drug requirements apply in addition to any cosmetic requirements when a product is both a drug and cosmetic.
A brand may provide additional truthful, non-misleading information. Any voluntary date or shelf-life representation should have a reasonable basis.
It is not a general FDA requirement for ordinary cosmetic labels.
Expiration dating is a perfect example of why cosmetic compliance cannot be reduced to a generic packaging checklist.
Sometimes the surprising answer is that a statement is not required.
The harder job is making sure everything that is required is actually present and correctly displayed.
CPGShield checks cosmetic labels against federal FDA requirements, state rules, claims rules, ingredient hazards, Proposition 65, retailer programs, and measurable artwork requirements.
Upload the label you are about to use and find the issues before they become printed inventory.
→ Run a free cosmetic label scan at CPGShield.com
Know before you print.
This article is educational and does not constitute legal advice.
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