Green Claims for US Hotel Amenities

Green claims on US hotel amenities, such as "recyclable", "made with recycled plastic", "eco-friendly" or "refillable", must be truthful, specific and backed by evidence. The FTC Green Guides set out how the Federal Trade Commission judges these claims, and California applies stricter rules, especially on when a package can be called recyclable or carry the chasing-arrows symbol.

Hotels face real pressure to show progress on waste, and amenities are among the most visible items in the room. That makes them a tempting place for green messaging, and an easy place to get it wrong. This guide covers the main claim types, the California position and how refill systems fit in. For state bottle laws, labelling and import, see our US hotel amenities hub.

The FTC Green Guides

The Green Guides explain how the FTC applies the law against deceptive advertising to environmental claims. They are not a regulation in themselves, but they show what the FTC is likely to treat as deceptive, and they are widely used by courts and state regulators. The FTC has been reviewing the Guides, so check for updates. The core principles are:

• Claims must be truthful and not misleading, judged by how a reasonable guest or buyer would understand them.
• Claims need competent and reliable evidence before they are made.
• Claims should say whether they refer to the product, the packaging or part of either.
• Qualifications must be clear, prominent and close to the claim.
• Comparisons must say what is being compared, such as less plastic than a named previous bottle, with evidence.

Common claims and how to handle them

Claim	Risk	Safer approach
"Eco-friendly", "green", "sustainable"	High: general benefit claims are hard to prove	Replace with a specific, provable claim
"Recyclable"	Medium to high: depends on access to recycling	Qualify unless access is broad; check California
"Made with recycled plastic"	Medium: needs records	State the percentage and what it applies to
"Biodegradable" or "compostable"	High: hard to substantiate for bottles	Avoid unless you hold strong evidence
"Refillable"	Low to medium: needs a real refill system	Describe the dispenser and refill system
"Less plastic"	Medium: needs a stated comparison	Name the baseline and the reduction

General environmental benefit claims

Words like "eco-friendly", "green", "earth-friendly" and "sustainable" suggest a broad environmental benefit that almost no product can prove. The Green Guides advise against unqualified general claims. If you want to signal progress, say what changed: "dispensers replace single-use minis in every room" is clearer and safer than "our amenities are eco-friendly". Avoid vague ocean-themed wording too, which is common in coastal markets such as Hawaii.

Recyclable claims

A package can be called recyclable without qualification only if recycling facilities that accept it are available to a substantial majority of the consumers or communities where it is sold. Where access is more limited, the claim must be qualified, for example by explaining that the item may not be recyclable in all areas. Every component counts: a bottle may be recyclable while its pump, label or sleeve is not, and the claim must make that clear.

Hotel amenities raise a particular issue. The person who disposes of a mini or dispenser bottle is usually housekeeping, using the hotel's waste contract, not a guest at home. Whether the item is actually collected and recycled depends on that contract. Base claims on the real disposal route.

Recycled-content claims

Recycled-content claims should only count material recovered or diverted from the waste stream, and should say how much, by stating the recycled percentage and what it applies to, rather than a bare "made with recycled plastic" if only part is recycled. Keep supplier certificates and batch records that support the percentage. Remember that recycled content can affect colour and clarity, which matters for premium decoration; our custom packaging team can advise on what is achievable.

California's stricter rules

California goes further than the Green Guides. Its 2021 law on recyclability claims, often referred to as SB 343, limits use of the word "recyclable" and the chasing-arrows symbol to materials that meet state criteria on collection and sorting across California. In practice many common small plastic items do not qualify, so a claim that may be acceptable elsewhere could be prohibited in California. California also has general rules on environmental marketing claims, including keeping documentation that supports them.

California, Oregon, Colorado, Maine and other states have also passed extended producer responsibility laws for packaging, which place obligations and fees on producers of packaging. Who counts as the producer for hotel amenities depends on each law; ask your adviser whether your packaging is covered.

Because hotel groups often use one artwork nationally, many decide to drop recyclability claims and the chasing arrows altogether, or to use a resin identification code without a recycling claim, after checking that the code itself is presented in the permitted form.

Refill systems

Dispensers refilled from bulk containers are the most credible environmental story most hotels can tell, and in several states they are also how hotels comply with small-bottle laws. We make dispenser bottles and 5 L refills for shampoo, conditioner, shower gel, 2-in-1, body lotion and hand wash.

Making refill claims carefully

• Only call a container "refillable" if it is actually refilled, for example by housekeeping from 5 L refills.
• If you claim a reduction in plastic, state the baseline and keep the calculation.
• Do not imply the refill container itself is recyclable unless the claim meets federal and state tests.
• Keep guest-facing messages short and factual, such as "Refilled in-house to reduce single-use bottles".

For how European rules approach the same questions, see our guide to sustainable hotel amenities in Europe, and for the plastics case more broadly, single-use plastic and hotel amenities.

A short checklist

1. List every environmental claim across labels, cards, websites and sales materials.
2. Replace general claims with specific, measurable ones.
3. Gather evidence for each claim before printing.
4. Check recyclability and symbol use against California rules if any product will reach California.
5. Have final wording reviewed by a legal or regulatory adviser.
6. Set a date to review claims again, because guidance and state laws continue to change.

Finally, keep claims consistent over time. If you switch bottle supplier, change resin or move from minis to dispensers, review every claim that depended on the old specification. Browse dispensers and refills in our hotel amenities collection.

Frequently asked questions

Can we call our hotel amenities eco-friendly?

Unqualified general claims like eco-friendly are hard to substantiate under the FTC Green Guides. Make specific, provable claims instead, such as a stated recycled-content percentage.

When can a bottle be labelled recyclable?

When recycling facilities that accept it are available to a substantial majority of consumers where it is sold. Otherwise the claim must be qualified. California applies stricter criteria.

Is "refillable" an environmental claim?

Yes. Only make it if there is a real system for refilling, such as dispensers topped up from 5 L refills, and explain how it works if it is not obvious.

Are the Green Guides law?

They are FTC guidance on how it applies the law against deceptive practices, and they have been under review. Some states, including California, write environmental claim rules into law.

Building a refill programme? Read about private-label hotel toiletries or go back to our US hotel amenities hub.