December 14, 2016  -  As our readers know, except for infant formula, Open Product Dating is not required by Federal Regulation. Nevertheless, a number of commonly used phrases appear on US food labels for both perishable and shelf-stable products in addition to the Closed Dating Codes required for Traceability. Finally, USDA FSIS has spoken and given its blessing to the phrase - Best if Used By - for products using optional Open Dating. 

Our Food Scientist readers who have studied Food Labeling in graduate school will remember the two categories – Open and Closed Dating. Open Dating, although frequently misunderstood by untrained food industry people, should be based upon the complex calculations of WVTRs and O2 Permeation which are usually referred to as Shelf-Life Studies (See Note 1 below).

Our trained readers will also remember to always check state law for state-specific Open Dating requirements for dairy and shell-egg products.

In contrast Closed Dating, using data codes and related to Traceability Systems, is often the sole Product Dating System used on canned, certain bottled, and other shelf-stable food products. However, many of these foods also do add optional Open Dating as well.

We are pleased to see FSIS opining on this topic and, despite lack of an expressed wording preference by FDA, we will recommend that all future Open Dating on labels use the Best if Used By wording.

Note 1 – for the best available discussion of Shelf-Life Studies please see Selke, Cutler, & Hernandez, Plastics Packaging: Processing, Properties, Applications, and Regulations, 2nd ed., Hanser, 2004.

We post the USDA FSIS Guidance Document released on December 14, 2016 below: