Batch and Expiry Tracking for Beauty and Supplement Brands

Beauty and supplement warehouses track two separate things, and the rules treat them differently. The batch, or lot, is what a recall depends on: it is how you find the affected units and the orders they shipped on. The date is less regulated than many teams expect. In the US, a cosmetic does not have to carry an expiration date unless it is also a drug.

Supplements add a rule that is easy to miss. FDA's supplement manufacturing rule covers businesses that hold supplements, not only the factory, and a warehouse does not count as retail even if it ships direct to consumers. That puts written requirements on how you store the product and how you handle returns.

This guide covers what the rules say, then what each step on the floor has to capture. It is not legal advice; confirm your obligations with a regulatory specialist.

Does the FDA require expiration dates on cosmetics?

No, with one large exception. FDA says there are "no U.S. laws or regulations that require cosmetics to have specific shelf lives," and that cosmetics are not required to carry expiration dates. It treats shelf life as "part of the manufacturer's responsibility." The exception is a product that is both a cosmetic and a drug: drugs "are required to have expiration dates printed on the labels." In a beauty catalog, those dated items can sit next to undated ones.

The EU is stricter for cosmetics. Under Regulation 1223/2009, Article 19, a cosmetic that lasts 30 months or less must show a date of minimum durability, with an hourglass symbol or the words "best used before the end of." Above 30 months that date is not required, and the product shows a period-after-opening symbol instead, where relevant. Article 19 also requires the batch number on the label, or on the packaging if the product is too small. Great Britain's version of Article 19, checked on legislation.gov.uk, carries the same wording.

For the warehouse, a beauty SKU can arrive in one of five states:

• a printed expiry date, set by the brand or required because the product is also a drug;
• an EU-style minimum durability date;
• only a period-after-opening symbol;
• no date, just a batch code;
• neither a date nor a batch code, in which case assign your own receipt lot and raise it with the brand.

A period-after-opening symbol is not a date you can rotate stock by. It counts from the day the customer opens the product, which the warehouse never knows. If you run first-expired, first-out picking, the date the system sorts on has to come from something real: a printed date, or a shelf-life date the brand gives you per batch. If neither exists, rotate by batch, oldest first, by manufacture date if the brand can give it to you and by receipt date if not, and write that down in your procedure. Our guide to FIFO vs FEFO covers how the two sort orders behave.

What does MoCRA change for cosmetics warehouses?

The Modernization of Cosmetics Regulation Act of 2022 gave FDA new powers over cosmetics. According to FDA, the responsible person, usually the brand, must report serious adverse events within 15 business days, and must list its products and update the listings each year. Manufacturers and processors must register their facilities and renew every two years. FDA defines a facility as an establishment that manufactures or processes cosmetic products; its MoCRA page does not address warehouses that only hold or distribute them.

FDA can order a mandatory recall when it determines there is a reasonable probability that a cosmetic is adulterated or misbranded and that its use will cause serious adverse health consequences or death, and the responsible person refuses to recall voluntarily. It can also access certain records. Adverse event records are kept for 6 years under the statute, or 3 years for qualifying small businesses; those are the brand's files.

One thing MoCRA has not yet done matters for planning: there is no cosmetic good manufacturing practice rule in force. The statute set a deadline of 29 December 2024 for FDA to propose one. The Fall 2025 federal regulatory agenda lists the rule under long-term actions, with a proposal planned for November 2027. FDA's main text on cosmetic manufacturing practice is a 2013 draft guidance marked "Not for implementation." If someone tells you MoCRA requires a particular warehouse process, ask which section.

If a recall does come, voluntary or ordered, how fast you can act depends on your batch records far more than on your dates.

Does 21 CFR 111 apply to a warehouse that only stores supplements?

Yes. Part 111 is FDA's current good manufacturing practice rule for dietary supplements. Section 111.1 says you are subject to it if you "manufacture, package, label, or hold a dietary supplement." The holding exemption covers only holding "at a retail establishment for the sole purpose of direct retail sale to individual consumers," and the same section says a retail establishment "does not include" a warehouse for a retailer or "a warehouse or other storage facility that sells directly to individual consumers." A brand's own direct-to-consumer fulfillment warehouse is covered.

Subpart M sets out what holding means in practice:

• Written procedures. Section 111.453: "You must establish and follow written procedures for holding and distributing operations."
• Storage conditions. Section 111.455 requires "appropriate conditions of temperature, humidity, and light," and conditions "that do not lead to the mixup, contamination, or deterioration" of the product.
• Distribution records. Section 111.475 requires "records of product distribution." It does not list the fields. But Part 111 also requires a lot number on each packaged and labeled lot and the ability to trace it "through distribution," and the distribution record is where that trace lives. A record that cannot tie a batch to the orders it shipped on does not do that job.

What happens when a supplement is returned?

This is where Part 111 differs most from ordinary e-commerce returns. Under Subpart N, a returned dietary supplement must be held "until quality control personnel conduct a material review." Section 111.515 says it is destroyed or otherwise suitably disposed of unless quality control approves it for salvage or reprocessing. If the return points to a problem that could affect other batches, section 111.530 requires you to investigate those batches too. Section 111.535 requires records of "any material review and disposition decision."

On the floor, that means a supplement return never goes straight back to a pick face. It is received by batch into a quarantine location, held there, and released or scrapped only when the designated quality control personnel record a material review and a disposition decision. If the warehouse has no quality control function of its own, that is usually the brand's quality team, and the hand-off should be written into your procedure. The usual inspect-and-restock returns flow is the wrong default for these items.

What should be captured at receiving?

Everything downstream depends on the batch being recorded when the stock arrives. For each inbound line, capture:

1. The batch or lot number, exactly as printed. Section 111.3 defines a batch, lot or control number as the identifier from which "the complete history" of the product can be determined.
2. The expiry, best-before or brand shelf-life date, if one exists, and which of these it is.
3. The quantity per batch. If a carton holds more than one batch, split the receipt line rather than averaging.
4. The location each batch is put away to.

Scanning beats typing, where the barcode carries the data. Barcodes that use GS1 application identifiers, such as GS1-128, carry these fields: (10) is the batch or lot number, variable in length, and (17) is the expiration date, six digits in the format YYMMDD. Check what the barcodes on each item actually encode; if a unit carries only a product code, you may still need to key or label the batch. Our barcode scanning guide covers the hardware side.

One detail often trips up date parsing. When only the month and year are known, GS1 allows the day to be written as "00", and a GS1 change notice says that string "SHALL be interpreted as the last day of the noted month." A date of 270600 means 30 June 2027, not an invalid date and not 1 June. The same notice says that from 1 January 2025, on regulated healthcare products, the day "SHALL NOT be expressed as two zeros." Expect "00" to keep appearing on other items, and check how your scanners and your system parse it before you trust a first-expired sort.

How do batch records support a recall?

A recall needs two answers quickly: where the affected batch is now, and where it went. FDA's recall policy in 21 CFR Part 7 says firms should use "sufficient coding of regulated products to make possible positive lot identification." It recommends keeping distribution records "for a period of time that exceeds the shelf life and expected use of the product." A recall strategy also sets its depth: wholesale, retail or consumer level. For a brand shipping direct to consumers, that usually means knowing which orders received which batch.

That requires the batch to be recorded at the pick, not just at receiving. If pickers take any unit from a bin holding two batches, the batch-to-order link is lost. Two practical rules follow:

• Keep one batch per pick location where you can.
• Where two batches share a location, have the picker scan or confirm the batch on each pick.

A mock recall shows whether this works. Choose a batch received a few months ago and try to list every order it shipped on and every unit still in the building. Set yourself a time target for that exercise and see whether you meet it.

How long do the records need to be kept?

Check your system's history retention against these periods. Some are binding on the warehouse, some are the brand's files, and one is a recommendation:

Section 111.605 allows electronic records, but they must comply with FDA's electronic records rule in 21 CFR Part 11. One retention setting at the longest period you need is the simplest approach; set it per brand only if storage or a contract calls for it.