Product Dating Requirements

This website does not supplant, replace or amend any of the legal requirements of the Consumer Products Regulations. Conversely, this website’s omission or truncation of regulatory requirements does not relieve responsible parties of their legal obligation to fully comply with all requirements of the regulation.

Who is a manufacturer in the Antiperspirant and Deodorant Regulation?

"'Manufacturer' means any person who imports, manufacturers, assembles, produces, packages, repackages, or relabels an antiperspirant or deodorant."

Ref: Cal. Code Regs., tit.17, § 94501(h)

Who is a manufacturer in the Consumer Products Regulation?

"'Manufacturer' means any person who imports, manufactures, assembles, produces, packages, repackages, or relabels a consumer product."

Ref: Cal. Code Regs., tit.17, § 94508(a)(84)

Who is a manufacturer in the Aerosol Coating Products Regulation?

"'Manufacturer' means any person who imports, manufactures, assembles, produces, packages, repackages, or relabels a consumer product."

Ref: Cal. Code Regs., tit.17, § 94521(a)(46)

What are some of the product dating requirements for the Antiperspirant and Deodorant Regulation?

"(a) Labeling

(1) No later than three months after the effective date of this article, each manufacturer of an antiperspirant or deodorant subject to this article shall clearly display on each container of antiperspirant or deodorant, the date on which the product was manufactured, or a code indicating such date. If a manufacturer uses a code indicating the date of manufacture, an explanation of the code must be filed with the Executive Officer in advance of the code's use by the manufacturer.”

Ref: Cal. Code Regs., tit.17, § 94504(a) Labeling

What are some of the product dating requirements for the Consumer Products Regulation?

"(b) Product Dating

(1) Each manufacturer of a consumer product subject to Section 94509 shall clearly display on each consumer product container or package, the day, month, and year on which the product was manufactured, or a code indicating such date.

Codes that represent a sequential batch number, or that otherwise cannot be attributed to a specific day, month, and year, do not satisfy this requirement.

(2) A manufacturer who uses the following code to indicate the date of manufacture shall not be subject to the requirements of section 94512(c)(1), if the code is represented separately from other codes on the product container so that it is easily recognizable:

YY DDD = year year day day day

Where: ‘YY’ = two digits representing the year in which the product was manufactured, and ‘DDD’ = three digits representing the day of the year on which the product was manufactured, with ‘001’ representing the first day of the year, ‘002’ representing the second day of the year, and so forth (i.e. the ‘Julian date’).

…

(1) If a manufacturer uses a code indicating the date of manufacture, for any consumer product subject to section 94509 an explanation of the code must be filed with the Executive Officer of the ARB no later than twelve months prior to the effective date of the applicable standard specified in section 94509. Thereafter, manufacturers using a code must file an explanation of the code with the Executive Officer on an annual basis, beginning in 2006.

The explanation of the code must be received by the Executive Officer on or before January 31st of each year, with the first explanation due on or before January 31, 2006.”

Ref: Cal. Code Regs., tit.17, § 94512 Administrative Requirements

What are some of the product dating requirements for Aerosol Coating Products Regulation?

“(2) Product Dating Requirements

(A) In addition to the labeling requirements specified in section 94524(b)(1), each manufacturer of an aerosol coating product subject to section 94522 shall clearly display on each aerosol coating product container or package, the day, month, and year on which the product was manufactured, or a code indicating such date.

Codes that represent a sequential batch number or that otherwise cannot be attributed to a specific day, month, and year, do not satisfy this requirement.

(B) A manufacturer who uses the following code to indicate the date of manufacture shall not be subject to the requirements of section 94524(b)(2)(E), if the code is represented separately from other codes on the product container so that it is easily recognizable:

YY DDD = year year day day day

…

(E) Additional Product Dating Requirements

(1) If a manufacturer uses a code indicating the date of manufacture, for any aerosol coating product subject to section 94522 an explanation of the code must be filed with the Executive Officer of the ARB no later than twelve months prior to use of the code or abbreviation. Thereafter, manufacturers using a code must file an explanation of the code with the Executive Officer on an annual basis, beginning January 1, 2015.

The explanation of the code must be received by the Executive Officer on or before January 31st of each year, with the first explanation due on or before January 31, 2015.”

Ref: Cal. Code Regs., tit.17, § 94524 Administrative Requirements

How do I submit the explanation of the code?

For products that utilize a code to represent the date of manufacture, an explanation of the code must be submitted by January 31 of each calendar year. Please submit the Date-Code Reporting Form by email (cpenforcement@arb.ca.gov), or by mail to:

California Air Resources Board
Enforcement Division
Consumer Products Enforcement Section
P.O. Box 2815
Sacramento, CA 95812