Expiry Dates and Certificates of Analysis

We are often asked about the problem of expiry dates on all the many and varied products we have and there seems to be a great deal of confusion over this subject, so it would seem extremely useful to explain the process of expiry dates in cosmetic products and the difference from those used for food products.

Expiry Dates

Firstly, and very importantly, there is no connection between an expiry date of an ingredient you use to make a finished product and the eventual expiry, or ‘best before/best-after-opening’ date you would put on your finished product. If you use an oil to make a lotion that has 3 months left until expiry on it’s certificate of analysis you do not apply that date to your ‘best before’ or ‘best after opening’ date for your finished product.

Also, very important to understand is that Food products have different rules to cosmetic products so where products used as cosmetic ingredients are also used for food there can be much confusion. As an example, we will regularly receive large consignments of oils or butters such as Olive oil or Palm oil, which are widely used in both food and cosmetics and the date on the outer packaging for food purposes might suggest they ‘expire’ in just 2-3 months, BUT, this is a food date and does not apply to cosmetics. In the world of cosmetics there is no date applied to outer packaging but rather we rely on a separate document called a Certificate of Analysis (CofA for short) and this is the certificate that is sent to us after the most recent testing of that product by the manufacturer/refiner and that is likely to have quite different information on it. It’s common for a CofA to have an expiry date many months further ahead and this is why….

A CofA is exactly what it suggests it is, it’s providing the latest results of analysis of that product. In the text of that document it may also have wording to suggest that rather than the date being a fixed ‘expiry date’ it will refer to a re-test and this is because it’s not the expiry of the product it’s referring to, it’s the expiry of the period since the product was last tested and found to be in perfectly good condition. In many instances, where the manufacturer still has some of that batch reserved for re-testing, a new CofA can be issued extending the so-called expiry date a further number of months, often 6 or even 12 months after testing their reserved sample and finding it still in good condition.

In these days of huge amounts of controversial food waste, much of which is based around over-zealously applied expiry dates we should actually be more pragmatic about how we deal with dates put on packaging. In recently highlighted instances there has seen to be huge amounts of milk simply thrown away because it passed the expiry date on the bottle, but a simple ‘sniff test’ will usually demonstrate that the milk would seem fine for drinking many days after that date, and as such we should be applying different rules to milk, and many other food products to reduce unnecessary waste. It would seem sensible then, that in cosmetics, we are already practicing a far more reasonable method.

Now… aside of the original manufacturer or refiner, companies and consumers further down the line don’t have the ability to test and issue CofA’s, so it’s not uncommon for a product to be sold with a fairly short period remaining on the CofA and this presents a problem, BUT, as I’ve already mentioned, if you’re using that product as an ingredient in the making of another product there is no link between the expiry date of an ingredient and the best before or best-after-opening date you apply to that product. As a more understandable example of this, if you make a cake and the eggs you use are due to ‘expire’ the next day it does not mean that the cake is not safe to eat after just 1 day and this would make perfect sense to most people. In the same way, if you add an oil to a soap or a lotion it’s being further processed and at that time the new product becomes that which needs to have any required testing applied.

Most people who need to understand this information are those making products for re-sale, as they are compiling records for their product files as they’re required to, and they will see the dates on the CofA’s and often get unnecessarily alarmed. It’s important to realise that the Safety Assessment (CPSR) you will have had to have on your formula will give guidance for best before or best-after-opening dates that should be applied to that product and you will also notice that there will be NO variations to this based around any expiry dates on the CofA’s of ingredients, so the lesson here is… Just because your ingredient says it’s going to ‘expire’ quite soon does not mean it’s not perfectly good to use in making your finished products.

Now… there are many and varied rules for different types of product use and I’m only attempting to explain those for cosmetic ingredients here because that’s the primary reason most of our customers are buying product from us. I acknowledge that there are many other uses for the products we stock and some customers will be buying them for different applications but to cover all other options would be impossible in this short article and also out of my own area of expertise.

There is immense misunderstanding over expiry dates in general and it’s widely acknowledged that these types of dates are a direct cause of huge amounts of waste in our modern society, so my advice in general would be to trust your judgement. If a product looks or smells ‘off’ then it is ‘off’ but otherwise please don’t simply throw it away, as it’s likely to still be in fine condition for much longer than you might think.

Finally, if the regulations don’t call for any best before or other type of date to be applied to your product, don’t use one. As an example, bar soaps have an expected period where they’re safe to use over 30 months from their production and this means they do not require any dating as the purpose of dates is safety. The high pH of natural soaps means they are self-preserving, as bacteria cannot propagate on them. It is true that the fragrance (if you add one) might diminish over time and mean that the soap might be considered ‘better’ if used after maybe just 6 months, but it’s not unsafe until possibly years later and might never actually become unsafe to use because of it’s self-preserving nature, so why put a date on it and encourage waste? Better not to if you don’t have to.

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