Chill and Frozen Date Labelling

We manufacture fried soy-based products, which can be stored under both chilled and frozen conditions. Is it common in the industry to declare two expiry or best-before dates based on the storage condition?

you CANNOT do that

you must prepare packaging for refrigerated and separate for frozen

I think the closest I've seen on this is instructions that state an expiration date for frozen, along with "use within 14 days once defrosted, do not refreeze" type notice.  I think the general consensus would be to provide instructions that make it clear the consumer should not thaw and refreeze multiple times.

I wrote a really long answer and then lost it when my mobile lost reception.  D'oh!

But I suppose there are three possible scenarios to do this "right" and one to do this "wrong".

If you mean, can I sell a chilled product for a consumer to freeze?  Yes of course.  Validate the freezing process but then put on pack something like "product can be frozen, freeze as soon as possible after purchase and before best before / use by date (as applicable).  Product can be stored frozen for xx months and should be fully defrosted in a refrigerator before reheating." (or similar).

If you mean can I freeze a product then defrost and sell chilled?  Yes, of course, but then the product will need to be labelled with the shelf life as it comes out of freeze.  The shelf life frozen would only go on the cases and pallet used as the product is frozen.  The consumer would never see them.  You cannot put the frozen shelf life on the product as it could be misinterpreted by the consumer.  In the UK this might be achieved by labels or by adding secondary packaging like a sleeve at point of defrost.

Or do you mean can I freeze and defrost for a specific promotion?  Yes.  In the UK this often happens with some Christmas products and that's when you might have each pack labelled with a use by or best before because you know in advance when you will be taking out of the freezer and tempering and that the chilled life will not be exceeded.

But if you mean can I make a product which says shelf life, say UB 10th Feb if chilled or 10th May if frozen.  No you can't do that.  The reason is because the a consumer picking up a defrosted product on 9th May doesn't know if it's been chilled all that time or frozen for most of it.  It would cause confusion and be a food safety and recall risk.