Name each date field before interpreting the record
In MIHEN's document inventory, a package or supporting file may label a value as manufacture, packaging, release, test, retest, expiration, best-if-used-by, report issue, or another date. Those are issuer-provided labels, not interchangeable regulatory definitions. Transcribe the exact wording, value, location, punctuation, and surrounding qualifier. If a field is only a code, leave its meaning unresolved unless the responsible company publishes a key or provides written confirmation for that exact format.
Record whether the date comes from the physical package, outer carton, certificate, batch record excerpt, manufacturer response, retailer image, or another source. A seller page can show an illustrative package that differs from delivered stock. A COA issue date documents the report, not automatically the beginning or end of a product period. When two sources conflict, retain both values and their provenance. The correct evidence state is unresolved until an authoritative record links the code, batch, and date meaning.
Match the date to the exact batch and package
For MIHEN's comparison, connect a date statement to the product name, item code, lot or batch value, package format, market version, and responsible company only when those fields are shown. U.S. dietary-supplement batch records and traceability requirements support keeping batch and packaged-lot relationships distinct. A general company statement that a product has a two-year shelf life does not disclose which event starts the period or whether it covers every formula and package revision.
Use field-level match states for product, lot, item, package, and date format. An exact lot code with a conflicting product code requires clarification. A matching product name with no batch identifier supports only a general product-level statement, not a lot-specific date. Preserve leading zeros and prefixes because they can encode plant, line, or sequence information. Do not infer a production facility or chronology from a code pattern unless the issuer's controlled documentation supplies that interpretation.
Separate a printed date from its supporting data
FDA's dietary-supplement labeling guide says expiration dating is not required, but a firm that includes it may do so when valid data support the statement so it is not false or misleading. FDA's CGMP small-entity guide likewise distinguishes optional shelf-life dating from the records retained when such dating is used. A printed date is therefore not a public copy of the supporting data. MIHEN should state whether it reviewed only the label, a company explanation, or an attached technical record.
If a company supplies a file it calls a stability summary or supporting rationale, record only metadata and fields actually visible: document identifier, named product or batch, named package when present, stated conditions, dated observations, stated specifications, conclusion wording, issue date, and authorization field. This list is MIHEN's extraction template, not a representation that U.S. dietary-supplement rules mandate a particular public report anatomy. Do not infer a missing protocol, raw dataset, deviation record, or approval step, and do not judge study sufficiency from undisclosed material.
Transcribe disclosed tables without inferring a study design
When a disclosed file contains a table, preserve the issuer's column labels and row relationships. Record a condition, time value, method, result, unit, specification, qualifier, or status only when printed. Do not call a scheduled value an actual test date unless the document does so, fill an unreported interval, calculate a trend from selected rows, or convert a conforms entry into an efficacy claim. Part 111's specification framework does not by itself define a public dietary-supplement stability-table format.
If the issuer uses terms such as long-term, accelerated, intermediate, or ongoing, quote that terminology as document text without applying drug-product stability guidance or assuming how the categories relate. The cited dietary-supplement sources here do not establish a standardized study design, required time-point schedule, interpolation method, or extrapolation rule for this public review. A chart without underlying values and units remains a graphic summary; MIHEN should not estimate numerical points from it or claim access to undisclosed observations.
Keep package and condition statements attached to their source
When a supporting record names a bottle, blister, sachet, cap, liner, desiccant, light barrier, storage condition, or label condition, capture the wording as a field from that source. If it does not name the package, record package not stated rather than selecting a configuration from the product photograph. FDA's CGMP guide has specific container-closure and holding provisions for reserve samples; those provisions should not be misrepresented as a complete dietary-supplement stability-study standard.
Compare the named product, batch, and package fields only to determine whether the disclosed record identifies the item under review. Do not infer that evidence for one package applies to another, or that any formulation, supplier, process, package, or specification change required a particular new study. Those judgments need the company's controlled records and qualified review. MIHEN can report that a current-package link is stated, missing, or conflicting without inventing a change-control history.
Publish the documentation state and its limits
A public summary can list the printed date wording and code, exact package and lot fields, source of any decoded meaning, disclosed supporting-file type, named batch or package, conditions or dated observations actually shown, issuer conclusion, revision, and review date. Use states such as date transcribed, code meaning confirmed by issuer, supporting file supplied, or current-package link unresolved. Do not say full protocol not public unless the issuer identifies a fuller protocol that was not supplied.
Do not translate a printed date or stability status into advice about taking, discarding, replacing, storing, or expecting a result from a supplement. Do not state that a document proves effectiveness throughout a period. The guide's boundary is narrower: it explains how a date claim is represented, what documentation was disclosed, how identifiers connect, and what remains unknown. Recheck revised labels and replacement reports while preserving dated versions, because a transparent chronology is more useful than a permanent undifferentiated shelf-life badge.
- Transcribe the exact date label, code, location, and source.
- Keep manufacture, packaging, release, test, retest, and shelf-life dates separate.
- Decode a code only from an issuer-published key or documented confirmation.
- Match product, item, lot, package, market, and responsible company fields.
- Separate the printed date from any supporting file the company discloses.
- Record technical fields only when they are present and keep issuer terminology.
- Do not infer a study type, schedule, interpolation rule, trend, or change-control history.
- Publish missing evidence and version history without use or efficacy advice.
Limitations
- A report issue date is not automatically a manufacture, release, or shelf-life date.
- A general product statement does not establish support for a specific lot or package revision.
- The cited U.S. supplement sources do not define a standardized public stability-report anatomy or study schedule.
- This guide documents date and stability evidence without advising product use or interpreting efficacy.
MIHEN / Sources
Sources
Sources mapped to the sections in this guide.
- Dietary Supplement Labeling Guide: Chapter I: General Dietary Supplement LabelingU.S. Food and Drug Administration
- Small Entity Compliance Guide: Current Good Manufacturing Practice in Manufacturing, Packaging, Labeling, or Holding Operations for Dietary SupplementsU.S. Food and Drug Administration
- Current Good Manufacturing Practice in Manufacturing, Packaging, Labeling, or Holding Operations for Dietary SupplementsElectronic Code of Federal Regulations
