Cosmetic PAO Symbol vs Expiry Date: 30-Month Rule
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Quick Answer
Cosmetics carry one of two time markings. If the product has a minimum durability of 30 months or less, the label shows a date of minimum durability (the hourglass symbol, or the words "best used before the end of"). If the minimum durability is more than 30 months, the date is not mandatory, but the label must show a period after opening (PAO): the open-jar symbol followed by a number of months or years. The PAO may be left off only where the concept of durability after opening is not relevant. Either figure must be supported by evidence in the safety report.
Which Marking Does My Product Need?
| Your product | What Article 19 requires |
|---|---|
| Minimum durability of 30 months or less | A date of minimum durability, preceded by the Annex VII symbol or the words "best used before the end of" |
| Minimum durability of more than 30 months | The date is not mandatory, but a period after opening is required: open-jar symbol plus months and/or years |
| Product where "after opening" has no meaning (for example a sealed single-use item) | The PAO may be omitted where the concept of durability after opening is not relevant |
This summary follows the text of Article 19 of Regulation 1223/2009. The regulator HPRA gives the same reading in plain language: where a product's minimum date of durability is greater than 30 months, a PAO symbol is required, shown as an open-jar graphic followed by the period in months and/or years. See HPRA's labelling page.
Minimum Durability vs PAO: The Difference
- Date of minimum durability is how long an unopened product, stored properly, stays in good condition. It is a date.
- Period after opening is how long a product can be used safely once opened. It is a duration such as 12M or 24M.
Treat them as two different claims, each with its own evidence. A cream may be stable unopened for three years yet need a shorter PAO because preservation weakens once air and fingers get in.
Where the Evidence Comes From
HPRA states that these figures are not random: both come from testing, and evidence to support the declared minimum durability and PAO must be included in the safety report. In practice that means stability data and preservation data, such as those in our guide to stability and challenge testing. Ask your assessor which tests justify your figure, and keep those reports in the PIF, as in our PIF checklist. If you change the formula, preservative system or packaging, revisit the figure, as explained in keeping your PIF up to date.
Small Packs, Soaps and Leaflets
Article 19 also allows some information to go on an enclosed or attached leaflet, label, tape, tag or card where it is impossible for practical reasons to put it on the pack, and refers to a notice in immediate proximity to the container for soap, bath balls and other small products. The text I reviewed ties those allowances to specific points of the Article, so check which items qualify before moving a date or PAO off the pack. Our labelling requirements guide lists the full set of mandatory items.
Common Mistakes
Mistake #1 — Printing a PAO "because everyone does" with no data. The figure must be supported in the safety report.
Mistake #2 — Using the wrong marking. Under 30 months needs the date; over 30 months needs the PAO.
Mistake #3 — Reformulating and keeping the old figure. A new preservative system can change both numbers.
Mistake #4 — Hiding the symbol. If the date appears elsewhere on the pack, the label must say where.
Frequently Asked Questions
When do I need a PAO symbol instead of a date?
When a cosmetic product has a minimum durability of more than 30 months, the date is not mandatory, but a period after opening must be shown with the open-jar symbol, unless the concept of durability after opening is not relevant.
What wording can I use for the date of minimum durability?
Article 19 says the date, or details of where it appears on the packaging, must be preceded by the hourglass symbol from Annex VII, or by the words "best used before the end of".
How do I decide my PAO figure?
It must be based on testing. HPRA states that evidence supporting the declared minimum durability and PAO must be included in the safety report. Your safety assessor can advise which stability and preservation data apply.
Can I put these details on a leaflet for a very small product?
Article 19 allows certain information to appear on an enclosed leaflet, tag or card where it is impossible for practical reasons to put it on the pack, but only for the items the Article lists. Check with your assessor which apply to your product.
Final Word
Two small symbols on a pack represent real laboratory work. Decide which marking applies, base the figure on data, store the data in the PIF, and revisit it whenever the formula or packaging changes.
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Sources
- Regulation (EC) No 1223/2009, Article 19 (labelling) — legislation.gov.uk
- HPRA, Cosmetic products labelling — hpra.ie
- Related guides on this site: labelling requirements, stability and challenge testing
This article is for general information and does not constitute legal advice. Article 19 wording is quoted from the legislation as published; the Annex VII symbols are not reproduced here. Confirm current requirements with a qualified safety assessor or Responsible Person.