What is the difference between expiry date and PAO for UK skincare labels?

Expiry date is the final use-by date for unopened products, and PAO (Period After Opening) shows safe use duration after opening. UK regulations mandate both on skincare labels for consumer safety.

UK buyer view Launch planning Updated: February 18, 2026
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US brand owners, Amazon/FBA sellers, distributors, and private label buyers
Core intent
Who submits, what data is needed, and how to plan timelines before production

Quick Answer (for busy buyers)

Here’s the buyer-first summary. If your brand name is on the label, you usually act as the responsible person and must ensure the listing is submitted and kept current.

  • In the UK, skincare labels require both an expiry date (the date until which the unopened product is safe and effective) and a PAO symbol (e.g., 6M for 6 months, indicating safe use after opening).
  • This stems from retained EU Cosmetics Regulation, ensuring clarity on product shelf life and post-opening safety to prevent contamination or efficacy loss.
  • As an OEM/ODM, we guide you through implementation: stability testing for expiry dates typically takes 3-6 months during sampling, while PAO determination adds 1-2 weeks for microbial challenge tests.
  • MOQs often start at 10,000 units per SKU, influenced by packaging complexity and ingredient sourcing.
  • Packaging must support PAO claims with designs like airless pumps to minimize contamination.
  • We provide documentation support including CPSRs and UK CPNP notifications, with lead times of 8-12 weeks post-sample approval for full production, testing, and labeling.
  • Note that while we assist with testing and docs, regulatory approval responsibility lies with your appointed person.
Buyer outcome
A launch-ready compliance plan: inputs collected, roles assigned, and update cadence defined.
Most common blocker
Missing facility information + inconsistent ingredient/label snapshots across SKUs.
⚠️
This page is a practical buyer guide. For definitive requirements and updates, use FDA resources and qualified regulatory counsel.
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