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    Worldover, AI operating system for chemicals and cosmetics companies

    Topic · EU · UK · Labelling

    Period After Opening, and cosmetic expiration dates explained.

    Cosmetic products sold in the EU and UK must tell consumers how long they are safe to use. Two marks do the job: the Period After Opening (PAO) symbol, the open jar with a number of months inside, and the hourglass best-before date for products with a shelf life of less than 30 months. Picking the right one is a regulatory decision, not a design one. This is a practical guide for brands, formulators and contract manufacturers.

    Quick answer

    The Period After Opening (PAO) symbol is the open-jar pictogram, with a number followed by 'M', that tells the consumer how many months a cosmetic remains safe to use after first opening. Under Article 19(1) of EU Regulation 1223/2009 (and the equivalent UK Cosmetic Regulation), PAO is required on cosmetics with a stated minimum durability of more than 30 months. Products with a shelf life of 30 months or less must instead carry a best-before date, shown by the hourglass symbol or the words 'best used before the end of'. PAO is not required when the concept is meaningless (single-use products, aerosols, sealed products that do not allow consumer contact with the formula).

    See how Worldover handles PAO and shelf life
    • PAO applies when minimum durability is over 30 months
    • Hourglass best-before date applies when durability is 30 months or less
    • PAO is set by stability and challenge test data, not packaging
    • Single-use, aerosol and fully sealed products are usually exempt
    • Same rules apply in EU 1223/2009 and the UK Cosmetic Regulation

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    What is the Period After Opening symbol?

    The Period After Opening symbol is the open-jar pictogram that appears on most cosmetic packaging in the EU and UK. Inside the jar, a number followed by the letter M (for example 6M, 12M, 24M) tells the consumer how many months the product remains safe and fit for use once the container has been opened for the first time.

    The obligation sits in Article 19(1)(c) of Regulation (EC) No 1223/2009 on cosmetic products, retained in the UK by the Schedule 34 amendments to the Cosmetic Regulation. The PAO is set by the Responsible Person on the basis of stability data, preservative efficacy (challenge) tests and the way the product is packaged and used, not by marketing or convenience.

    When is PAO required, and when is a best-before date required instead?

    The two marks are mutually exclusive. PAO is required when the product's minimum durability is more than 30 months. When the minimum durability is 30 months or less, the product must instead carry a best-before date, shown by the hourglass symbol or the wording "best used before the end of" followed by the date.

    In practice, leave-on products in stable formats (creams, lotions, serums in airless or tube packaging) usually exceed 30 months and carry PAO. Mascara, liquid foundation, sunscreens, fresh or preservative-free formulas and some natural products often sit under 30 months and carry the hourglass instead. A product must never carry both.

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    Are your regulatory filings complete and current for every product you sell (FDA listings, CPNP notifications, PIFs)?

    When does PAO not apply at all?

    Annex VII of the Regulation sets out a small set of cases where PAO is not required because the concept is meaningless: single-use products (single-dose sachets), products whose packaging does not allow consumer contact with the formula (sealed aerosols, true airless dispensers under specific conditions), and products where there is no realistic risk of deterioration once opened.

    The exemption is narrower than it looks. Many brands assume their airless pump qualifies, when the regulator's test is whether the consumer can in fact touch the formula. If the formula can be reached, PAO applies, even if the dispenser is well designed.

    Worldover for this

    PAO and best-before dates, managed from the formula up.

    Worldover ties stability data, challenge tests and packaging to every SKU, so the correct PAO or hourglass mark falls out automatically into artwork briefs, CPSRs and product information files.

    See cosmetic labelling in Worldover

    How is the PAO actually set?

    PAO is a finding, not an opinion. It is set by the Responsible Person (or US Responsible Person under MoCRA, where applicable) and recorded in the product information file (PIF) and the cosmetic product safety report (CPSR). The inputs are real-time and accelerated stability data, preservative efficacy testing (typically ISO 11930), packaging compatibility and a realistic view of how the consumer will use the product.

    The CPSR must justify the PAO. A 12M PAO on a water-based emulsion with no challenge test or with weak preservation is the kind of gap that authorities flag in market surveillance. The same PAO must be reflected on artwork, in any retailer technical files, and in customer-specific product specifications.

    How do you manage PAO across a portfolio?

    For a brand with dozens or hundreds of SKUs, PAO is not a one-off artwork decision. Every reformulation, every packaging substitution, every new market launch can change the answer. A new fragrance, a switch from a tube to a jar, a change in preservative system, all of them can move the PAO and need to flow through to artwork, CPSRs, notifications (CPNP in the EU, SCPN in the UK) and retailer data sheets.

    Worldover treats PAO and minimum durability as structured properties of the SKU, linked to the underlying stability and challenge test data. When the formula or packaging changes, the system flags every downstream artefact that needs updating, so the right symbol and number reach the consumer on every market.

    PAO, stability data and the label

    The PAO you print has to be defensible from stability and challenge test data, and that data usually sits with the lab rather than with the label. Connecting test results to the product record is what LIMS software for cosmetics does, and it is why the PAO on the artwork and the evidence in the PIF stay consistent when the pack changes. For the artwork and filing side, see cosmetic ERP software.

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