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Supplement shelf life: what buyers should ask

There is no single shelf life for all supplements. FDA’s CGMP guidance says the rule does not require an expiration date, but a date used on a label should have supporting data. Ask for evidence covering your formulation, packaging and storage conditions.

Ask what supports the proposed date

FDA distinguishes the absence of a mandatory expiration date from the need for data supporting a date that is used. Ask the manufacturer which measurements and acceptance criteria support the proposed period. Do not assume one product’s study covers a different formula or package.

FDA: dietary supplement CGMP guidance

Agree storage and change controls

Our buyer checklist asks who owns the stability evidence, which conditions the label assumes and what triggers reassessment after a supplier, formula or packaging change. Ask whether the protocol covers the characteristics that matter to the product rather than only its appearance.

FDA: dietary supplement CGMP guidance

Ask about reserve samples

21 CFR 111.83 requires reserve samples to be held one year past the shelf-life date when dating is used, or otherwise two years from distribution of the last batch associated with the sample. Sample retention and evidence for a shelf-life claim answer different questions.

eCFR: 21 CFR 111.83, reserve samples

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