Short answer
In the EU and Great Britain, a cosmetic product with a minimum durability of 30 months or less must show a "best used before the end of" date (or the hourglass symbol and a date); a product that lasts longer must instead show a period-after-opening (PAO) symbol — an open jar with a number of months — unless the idea of durability after opening is not relevant. Most alcohol perfumes last longer than 30 months, and a sealed spray, which cannot be opened, is a recognized case where PAO may not be relevant. In the US, FDA does not require expiration dates on cosmetics, but manufacturers remain responsible for knowing their products' shelf life. Either way, the answer must come from stability data, not a guess.
The EU rule
Article 19(1)(c) of Regulation (EC) No 1223/2009 sets two cases:
| Minimum durability | What the label shows |
|---|---|
| 30 months or less | The date of minimum durability (month and year, or day, month and year), preceded by the hourglass symbol or the words "best used before the end of" |
| More than 30 months | No date required; instead the period after opening during which the product can be used safely, shown with the open-jar symbol followed by months and/or years (for example "12M") — except where durability after opening is not relevant |
European Commission guidance describes when the PAO is not relevant: products with no risk of deterioration, products that cannot be opened (sealed packaging, sprays), and single-use products.
What it means for perfume
- Crimped spray bottles cannot be opened by the user, so a PAO is commonly considered not relevant for them.
- Screw-cap sprays, splash bottles and dab-on oils are opened, so a PAO is relevant if the product lasts more than 30 months.
- Products with water or other ingredients that limit durability may last less than 30 months and need a date.
- Solid perfumes and oils depend on their bases' stability; the carrier oil may limit shelf life.
Whatever the format, the decision rests on the product's actual stability. The safety assessor reviews it as part of the safety report; see what a safety assessor needs from you.
Great Britain
GB rules follow the same structure; GOV.UK's guidance lists the date until which the product can be used among the label requirements. See selling perfume in the UK.
United States
FDA states that no US law or regulation requires cosmetics to have specific shelf lives or expiration dates on their labels, but that manufacturers are responsible for making sure their products are safe, and that FDA considers determining a product's shelf life part of that responsibility. Products that are also drugs must carry expiration dates. Many US brands print a production date or batch code and keep shelf-life data on file. See MoCRA requirements for fragrance brands for the broader duty to substantiate safety.
Finding the right figure
- Run a stability study on the product in its final packaging: odor, color, clarity and, where relevant, microbial quality over time and under stress conditions. See perfume stability testing.
- Decide whether the product lasts more or less than 30 months unopened.
- If the package can be opened, consider in-use stability — how long after opening it stays acceptable — for the PAO.
- Agree the conclusion with your safety assessor and record it in the product file.
- Review it when the formula or packaging changes.
The batch code should appear on every unit regardless; see perfume batch numbers and lot codes. Raw materials have shelf lives too, which feed into the product's; see fragrance raw material shelf life. The other market rules are in perfume regulations by market.
Sources
- EUR-Lex — Regulation (EC) No 1223/2009, Article 19(1)(c) and Annex VII, checked October 9, 2026.
- US FDA — Shelf Life and Expiration Dating of Cosmetics, checked October 9, 2026.
- GOV.UK — Making cosmetic products available to consumers in Great Britain, checked October 9, 2026.
Frequently asked questions
Can a label show both an expiry date and a PAO?
The EU rule treats them as alternatives depending on durability. Showing the one that applies, clearly, is what the rule asks for.
Does perfume "expire"?
It changes: top notes fade, color darkens, some materials oxidize. Many alcohol perfumes stay acceptable for years if kept closed, cool and dark. The label should reflect your product's tested behavior.
Written and reviewed by the RUŌOD Lab team. This article is general education about perfume formulation and record-keeping; it is not legal, regulatory or safety advice, and the examples are illustrations, not validated commercial formulas. How we write and check these guides.