Navigating Date Coding in Food Manufacturing

Clear and informative date coding on food products is helpful for both consumer safety and brand compliance, but can sometimes cause confusion about what a customer should do with that information.

Manufacturers provide dates on food packaging to help consumers and retailers understand when food quality is best. Dates are not an indicator of the product’s safety and are not required by Federal law for the majority of foods.  Infant formula is the only food category where date coding is mandatory.  

While the USDA and FDA do not enforce specific date coding formats, they offer valuable guidelines to help food manufacturers implement effective systems.

Understanding USDA and FDA Recommendations

The USDA's Food Safety and Inspection Service (FSIS) and the FDA's Center for Food Safety and Applied Nutrition (CFSAN) emphasize the use of clear and informative date labels. Key recommendations include:

• "Best By" Dates: Indicate when a product is at its peak quality.
• "Use By" Dates: Indicate the last date for safe consumption.
• Additional information may also be included such as storage instructions or explanations of date labels

States may also have their own regulations and guidance, especially around perishable and potentially hazardous foods. This chart from the Harvard Law School Food Law and Policy Clinic (FLPC) gives a brief overview of what products may need date coding.

Here's a quick overview of the two recommended tags and how they differ:

Download the resource here

Beyond the Regulator - Retailer Expectations for Remaining Shelf Life 

Retailers often have their own policies or contractual obligations in place, which may stipulate how long a product may remain on shelves and how far in advance of “best by” dates it may be sold.  For many retailers, this is often six months of shelf life for shelf-stable products, and even longer for certain categories of goods. In this example, if your product shows up for delivery with five months left of shelf life, a retailer may reject that shipment, and your team will be tasked to find a secondary distribution channel to sell the end-of- shelf-life product.

Implementing Best Practices

1. Work with a Food Safety & Quality expert: Identify what quality and safety attributes can be achieved based on the type of product you’re manufacturing and the route to market.  
2. Choose Appropriate and Consistent Date Labels: Select "Best By" or "Use By" based on product characteristics and safety considerations.
3. Identify What is Possible at the Manufacturer: Be sure your artwork designer understands what printing capabilities your manufacturer has at the production facility.  Where on the label will the date code be printed should be sure there’s sufficient contrast and readability.  
4. Understand Retail Requirements: Be sure date codes and shelf life align with retailer expectations.
5. Educate Consumers: Clearly explain the meaning of date labels on product packaging or your website and help them understand when taste or quality may be compromised.‍
6. Regularly Review and Update: As regulations or best practices evolve, ensure your date coding system remains compliant and effective.

Key Considerations for Effective Date Coding

• Clarity: Use easily understandable and readable date formats (e.g., MM/DD/YYYY) and terms
• Consistency: Apply consistent coding practices across all product lines.
• Traceability: Ensure codes allow for tracing products back to their source.
• Compliance: While not mandatory, aligning with USDA and FDA recommendations enhances transparency and consumer trust.

When bringing a new product to market, brands should consider cross-functional perspectives including: product safety, quality, manufacturer capabilities, artwork design, regulatory compliance, retailer readiness and supply chain.