Expiry dates and lot codes on food, HBA and OTC closeouts

What do expiry dates mean on closeout food, HBA and OTC?

In the US, most food dates are quality dates set by the maker; only infant formula carries a federally required use-by date. OTC drugs must carry an expiration date under 21 CFR 211.137. Cosmetics have no general federal expiry requirement. For a buyer, the question is not just the date but how much shelf life remains for the channel you sell into.

Dated goods are where a manifest without dates and lot codes becomes risky. The manifests and condition guide covers the wider manifest; this page covers the dates.

The date types, and what each one means

US federal rules in brief

• Food. The FDA does not require expiration dates on most foods. Dates are generally voluntary and describe quality. Infant formula is the federal exception and must carry a use-by date. Some states set their own dating rules for certain foods.
• OTC drugs. 21 CFR 211.137 requires an expiration date on drug products, including OTC, determined by stability testing, with narrow exceptions written into the rule.
• Cosmetics. No general US federal requirement to show an expiry date. Many brands print one anyway, or use a PAO symbol for products also sold in the EU.

Retailers, marketplaces and importing countries often set rules stricter than these. Always check the current policy of the channel you will sell through. Official sources are on the FDA website and the Electronic Code of Federal Regulations.

Reading Julian codes

A common format is one year digit followed by a three-digit day of the year. Day 001 is January 1. Day 123 is May 3 in a normal year and May 2 in a leap year, because February 29 shifts every later day. Some makers use two year digits, put the day first, or add plant and line codes. If the format is not obvious, ask the seller or the manufacturer before you rely on your reading.

Remaining shelf life: how buyers should think about it

The useful number is remaining shelf life: how long you have to sell the goods before they hit the date your channel cares about. Work it out against your own sales speed and your channel's rules:

1. Find the earliest date on each line, not the latest and not the average.
2. Subtract the time to get the goods into your hands: pickup, transit, receiving.
3. Subtract your channel's cutoff. Many marketplaces and retailers refuse goods within a set window of their date. The window differs by platform, by category and sometimes by fulfillment method, and it changes. Read the current policy for your exact category before you price the load, not after it arrives.
4. For export, subtract ocean transit and customs time, and check the destination's rules. Many importing countries, and many importers, set a minimum remaining shelf life for food at entry. Get it in writing from your importer or the destination's food authority before the container is booked.
5. Compare what is left with your sell-through time for that product.

If what is left is shorter than your sell-through time, you are buying stock you will have to discount again, donate or dispose of.

Worked example: remaining shelf life

Illustration only. The dates are hypothetical; the receiving time, channel cutoff and sell-through time are letters, because they depend on your lane, your channel and your product.

Say you are offered a pallet of shampoo with an earliest expiry date on the line of 31 March 2027. Today is 1 October 2026.

• Months to expiry: October 2026 to the end of March 2027, 6 months.
• Time to receive the pallet: R months.
• Your channel refuses goods within C months of their date. Check the real figure in the channel's current policy.
• Selling window: W = 6 − R − C months.
• You usually sell this kind of item in T months, from your own sales records.

Result: if W is shorter than T, part of the pallet will hit the channel's cutoff unsold. Note how fast the window closes: every month the cutoff C adds, and every week the pallet spends in transit, comes straight off W. When W falls short, you either price for a faster outlet (bin store, discount store, a channel without a cutoff), buy only the part you can sell inside W, or pass.

Short-dated pricing logic

Short-dated stock is priced on time, not on retail. The shorter the window, the fewer channels can take it and the faster it must move, so the lower the price a buyer can pay. Two loads of the same product at the same retail can be worth very different amounts because of their dates. Sellers who know their dates are approaching do better clearing early, while more channels still accept the goods. Category detail for owners is on sell excess food and beverage inventory and sell excess HBA inventory.

How to put dates on a manifest

Sellers should add lot and expiry or best-by columns, one value per row. If a SKU has two dates, use two rows. Use one unambiguous date format for the whole file, such as year-month-day. State which kind of date it is (best by, use by, expiration). Photograph the date and lot code on a sample unit from each line. The full column template is in how sellers should build a manifest, and buyers checking those columns can follow how to read a liquidation manifest.

Recalls: check before you buy and before you sell

Lot codes are how a recall is matched to a product. Before buying food, HBA or OTC loads, search the FDA's published recall notices for the brands and products on the manifest, and check again before you sell. If a lot on the manifest matches a recall, do not buy it for resale. Keep your purchase records with the lot codes, so you can trace and pull stock later if a recall is announced after you bought.

Storage conditions

Dates assume normal storage. Heat, freezing and damp shorten shelf life and can damage packaging and contents, especially for chocolate, liquids, aerosols, creams and anything in glass. Ask where the goods have been stored (climate-controlled warehouse, trailer yard, outdoor), and look for signs in the photos: bloom on chocolate, swollen cans, separated lotions, leaking aerosols, water-stained cartons. Plan your own storage and freight around the product, especially in hot months.

Mistakes to avoid

• Buying on the latest date in the lot. The earliest date decides.
• Confusing PAO with shelf life. PAO starts when the product is opened.
• Guessing Julian codes. Confirm the format.
• Ignoring your channel's cutoff. Federal rules are the floor, not the ceiling.
• Skipping the recall check. It takes minutes and protects your customers and your business.
• Accepting dates without photos. Ask for a readable photo of each line's date and lot code.

Dated loads on Skyline Dealz Marketplace

Listings for dated loads on Skyline Dealz Marketplace show dates and lot codes wherever they are available, and approved member buyers can ask for more photos before they make an offer. Examples of these loads are on wholesale closeout HBA and wholesale closeout food and beverage. To get alerts on matching loads, request access.