Malaysia Cosmetic Period After Opening (PAO) and Shelf-Life Labelling

In Malaysia, a cosmetic's "shelf life" follows two labelling logics: the date of minimum durability (commonly the expiry/best-before date) and the Period After Opening (PAO). Under the ASEAN Cosmetic Labelling Requirements that NPRA aligns with (Annex I Part 7), products with a minimum durability of less than 30 months must show an expiry date; those with a shelf life of 30 months or more may omit the expiry date and instead use the PAO open-jar symbol (such as "12M") to tell consumers how many months after opening the product should be used up. The two serve different purposes, and understanding them prevents mislabelling or omission.

Expiry date: when it is mandatory

The "date of minimum durability" is the period during which the product, under appropriate storage conditions, continues to fulfil its original function and remain safe. The labelling rules:

• Shelf life < 30 months: an expiry date is mandatory, usually prefixed with "best before (date)" or equivalent wording.
• Shelf life ≥ 30 months: an expiry date is not required, but expressing the usable period after opening via PAO is recommended.
• The date format must be clear, using "month/year" or "day/month/year" order, with no ambiguity.

PAO: how to use the open-jar symbol

PAO is shown as an "open cosmetic jar" symbol paired with a number of months, for example "6M", "12M" or "24M", meaning the product should be used within 6, 12 or 24 months after opening. It measures the stability and hygiene period after opening, and applies to creams, foundations, eyeshadows and other products used over a long time once opened. Conversely, single-use products (such as masks) or sealed packaging that is not easily opened have less meaning for PAO and may omit it depending on circumstances. In practice, providing both an expiry date and PAO is considered better practice, giving consumers clearer usage and safety guidance; the PAO months stated should also be backed by formula stability or preservative efficacy data and cannot be filled in arbitrarily.

Approved shelf life and stability testing

NPRA has a clear position on declared shelf life: since 27 November 2014, both local and imported products are uniformly approved for a 2-year shelf life; to declare more than 2 years, you must submit stability test data conducted in Malaysia under Climatic Zone IVb conditions (30±2°C, relative humidity 75±5%) as evidence. Zone IVb is specified because Malaysia has a hot and humid climate, and the temperature and humidity stress products actually endure locally is higher than in temperate zones; only testing under local conditions can reflect quality changes under real shelf and transport environments. In other words, a longer stated shelf life cannot rest on the manufacturer's claim alone and must have measured data matching the local climate.

Manufacturing date, batch number and traceability

Beyond the expiry date and PAO, the manufacturing date and batch number on the label are equally important: the batch number makes each production batch traceable, so that if a quality or safety issue arises, the affected scope can be quickly identified and a recall executed. If a manufacturing date is combined with a number of shelf months, consumers must still be able to clearly calculate the expiry point and not just see a vague year. In practice, the stability data underlying the expiry date/PAO should be consistent with the records in the Product Information File (PIF); the shelf life claimed on the label must be supported by test data within the PIF, otherwise it will be hard to justify during an audit or complaint.

Common mistakes

• A shelf life under 30 months labelled only with PAO and no expiry date — this is an omission.
• Using "MFG (manufacturing date)" in place of an expiry date without giving a clear number of shelf months, leaving consumers unable to judge.
• Declaring more than 2 years of shelf life but providing stability data not under IVb conditions (or not local) — not accepted.
• Messy date formats (such as "2027" alone with no month), failing the "month/year" requirement.

Frequently asked questions (FAQ)

Q: Do all cosmetics need an expiry date? No. Products with a minimum durability of less than 30 months must show an expiry date; those of 30 months or more may omit it and are recommended to use PAO instead.

Q: What does PAO "12M" mean? It means the product should be used up within 12 months after opening. It measures the stability and hygiene period after opening, which is a separate matter from the unopened expiry date.

Q: How long a shelf life does Malaysia approve by default? Since 27 November 2014, both local and imported products are approved for 2 years; exceeding 2 years requires stability test data under local Climatic Zone IVb conditions.

Q: Can I show both an expiry date and PAO? Yes, and it is considered better practice, giving consumers clearer usage and safety guidance.

Q: How should the date be written to be compliant? It must be clear and use "month/year" or "day/month/year" order, avoiding a year alone or ambiguous formats.

Self-check checklist

• [ ] Determined whether the product's minimum durability is < 30 months, deciding if an expiry date is mandatory
• [ ] Expiry date format is "month/year" or "day/month/year", clear and unambiguous
• [ ] Products used long-term after opening carry a PAO symbol and month count
• [ ] Declared shelf life is based on 2 years; IVb-condition stability data is prepared for anything longer
• [ ] Labelling is consistent with the stability data in the Product Information File (PIF)

Summary: The expiry date governs "unopened", PAO governs "after opening", and 30 months is the dividing line between them; the 2-year shelf life is Malaysia's approved baseline, and anything longer must be backed by IVb stability testing. Align your date format, PAO and stability data, and the labelling will hold up. Want to quickly check whether your label is missing anything? Run a free label check now

Further reading: Malaysia Cosmetic NPRA Notification Overview, Cosmetic Labelling Requirements Item by Item, Cosmetic Notification Process and CNH.

This article is compiled from official sources for reference only; actual compliance is subject to the latest official text and review by the competent authority.