As a repackager of APIs, we use an expiry date only when one is given by the manufacturer. However, in a recent inspection, the investigator insisted that all APIs should have an expiry date. We believe this to be incorrect and would like to know what argument we should use to defend the fact that most APIs do not have an expiry date.
It would be recommended to say that you have a retest date, not an expiry date. Following Q7A, you should indeed have that date either on the label or on your certificate of analysis.