Just like many everyday consumer goods, cosmetic products have a shelf life, which corresponds to the period of time during which they can be used without any fear they might be less efficient, and without any danger or risk they might be contaminated by external elements (fungi and mould, bacteria…). Manufacturers must inform consumers of the product shelf life, and it is more than recommended to verify it first, and then to respect it!
The new Cosmetics Regulation in Europe, which entered into force on July 11, 2013, makes provision for it: this new, hourglass-shaped logo, introduces the date of minimum durability of a cosmetic product. It is important to understand this notion for an optimum use of our products!
The concept of minimum durability
The date of minimum durability is sometimes mistaken for the expiry date, although according to the new Regulation, it precisely refers to “the date until which the cosmetic product will continue to fulfil its initial function and remain safe”, which means “the date by which it is best to use the product”.
In practical terms, it should be composed, in the right order, of:
• either the month and the year,
• or the day, the month and the year,
and it may be presented in two ways:
• either after – as it is now – the mention “best used before the end of”,
• or after this new symbol.
The 30 month minimum
Indicating the minimum durability is mandatory when it is inferior to 30 months. On the contrary, when it is superior to the crucial minimum of 30 months, this indication is replaced by a different one, that of the period of time after opening that the cosmetic product may be used without any harm to the consumer, which is better known as “period-after-opening”, and which takes the shape of an open jar in which a number followed by the letter M for “months” are written.
We have already had the opportunity to underline this indication is hardly useful to consumers if they do not make the effort to carefully write down the date when they opened each and every one of their products for the first time. We have also already noticed there was no label on the market that made this easy.
Therefore we are now very pleased to see the first initiatives taken in this respect on a few labels.
30 months: what does this limit involve in terms of safety?
To sum it up, there are two different indications, depending on whether cosmetic products can “live” more, or less than 30 months. This regulatory principle, which was set out in the previous Directive, and resumed almost in the same terms in the new Regulation – except for one logo – does raise a few questions.
Indeed, who says a product whose durability is inferior to 30 months can remain open and partly consumed for 24 months without undergoing any damage?
Here is another example: let us imagine a cosmetic product whose durability exceeds 30 months. It is indicated, perfectly legally, that it can be used for 6 months after opening. Let us imagine this same product remaining on the shelf in a small beauty salon whose stock only “turns” slowly, or lying forgotten at the back of your bathroom’s cupboard… before being found out again. It means you could spread a 3, 4, 5, or maybe 10-year-old cream on your skin without any fear! Is it worth anything after so long?
If we have a closer look at it, it seems legislators have not thought about the fact that a cosmetic product is not kept the same way before and after opening, and that, in the end, both these indications represent very different marks, which are both essential to consumer safety, and should both be mandatory on all products. So the same question remains: what motivated the enactment of the “before/after 30 months” rule?
And we support manufacturers who make efforts beyond what the law imposes and indicate both dates!