Declaration once opened use by (X-Days or X-Hours) After Opening a Food Packaging

Dear all,

I'm researching the use of "Once opened, use within x days/hours" statements on food labels. I've reviewed several resources, including:

FDA "A Food Labeling Guide" (Jan 2013)

FSSAI (India) "Food Safety and Standards (Packaging and Labelling) Regulations, 2011"

GSO 9/2013 "Labeling of Prepackaged Food Stuffs"

England "The Food Labelling Regulations 1996"

Unfortunately, I haven't been able to find definitive information about the specific requirements for using these statements, particularly in the context of perishable foods such as fresh milk and yogurts etc.

 I'd appreciate any insights or references that could help me clarify the following:

It's a difficult one. While you can determine a products shelf life pre consumers opening through your shelf life validation trials, once the consumer has the product, these fly out the window.

To err on the side of caution is the best way. Look at some comparative products out in the market. Typically for high risk foods like fresh milk, we look at a maximum of 3 days if stored per the storage directions on the product.

But again, you have no control over how the consumer uses the product. They may drink straight out of the container and then put it back in the fridge. They may eat some using a spoon and then double dip, then put the lid back on and return it to storage, be it a fridge or pantry. They leave the product on the bench and forget to reseal it before putting it away where it should be.

They could have left their groceries in a hot car while the did further shopping. Then they may bring home their groceries and leave the perishable's out on the bench for 10,20 60 minutes, who knows? Their fridge may be running warm or their pantry is full of rodents, cockroaches and ants!

So many different scenarios and no real answer, short of you running your own validation trials of your product post opening, but then as above, you have no idea how the product has been handled or what the consumer has done with it once they bought it.

Then you get the consumer complaint, and wonder how you'll deal with it.

I too am interested in this topic. We manufacture sandwich fillings predominantly made of mayonnaise with chicken, or tune and sweetcorn. The business is looking to change the label from once opened consume in 3 days to 5 days. Should we validate this or is there guidance to state what can and can not be consumed after opening. I to mentioned the consumers usage that we can not control but is 5 days to long after opening!?