Cosmetics Licensing and Labelling for Hotel Toiletries in India

In India, hotel shampoo, conditioner, shower gel, body lotion and plain hand wash are cosmetics. They are regulated under the Drugs and Cosmetics Act, 1940 and the Cosmetics Rules, 2020, must be manufactured under a licence from the State Licensing Authority, and must carry the label details those rules require. Legal Metrology declarations such as MRP and net quantity are a separate question that hotels should confirm for their complimentary amenities.

This guide is for procurement managers, compliance teams and owners buying amenities for Indian hotels. It explains the framework in plain terms and lists what to ask a supplier. It is general information, not legal advice. For an overview of supplying Indian hotels, see our India hotel amenities hub.

Are hotel toiletries cosmetics?

Broadly, a cosmetic under the Drugs and Cosmetics Act is a product intended to be applied to the human body for cleansing, beautifying, promoting attractiveness or altering appearance. Shampoo, conditioner, shower gel, 2-in-1, body lotion and a plain hand wash fit that description. Being given free to a guest does not change what the product is.

The picture changes if a product claims to treat, cure or prevent a disease, or makes certain germ-kill claims. Such claims can bring a product closer to the definition of a drug, with a different licence and different rules. That is why hotel amenities are normally formulated, labelled and marketed as cosmetics, and why claims need care. A hand wash described as cleansing is a cosmetic; one labelled as killing germs may not be.

The Cosmetics Rules, 2020

The Cosmetics Rules, 2020 were made under the Drugs and Cosmetics Act and brought cosmetic rules into a separate set of regulations. They cover manufacture, import, labelling, standards and record-keeping. Two points matter most to hotel buyers.

Manufacture needs a state licence

A company that manufactures cosmetics in India needs a manufacturing licence from the State Licensing Authority of the state where the factory is located. The licence relates to the premises, the categories of products made and the people responsible for manufacture and testing. Its number appears on the label, which gives you a simple way to check that a product was made by a licensed manufacturer. Harrods Health holds a state FDA cosmetic manufacturing licence for its facility in Ambala, Haryana.

Imported cosmetics need registration

Cosmetics imported into India must be registered with the Central Drugs Standard Control Organisation (CDSCO) before import. This matters only if you are comparing imported amenities with domestic ones: an imported range carries registration requirements, customs clearance and duty, while a range made in India does not need import registration.

What the label must show

The Cosmetics Rules set out particulars that cosmetic labels must carry. Keep the following list as a working checklist and ask your supplier to confirm how each point is handled for your packs.

Label element	What it means for hotel amenities
Name of the product	For example, shampoo or body lotion, alongside your hotel's branding
Manufacturer's name and address	The licensed manufacturer must be identifiable, even on a private-label pack
Manufacturing licence number	Links the product to the licensed premises
Batch number	Allows traceability if a guest raises a concern
Date of manufacture	Helps housekeeping rotate older stock first
Use-before date, where required	Depends on the product and the rules that apply
Ingredients	A list of ingredients
Net content	Volume or weight in the pack

Hotel branding sits alongside these details, not in place of them. A pack can lead with your hotel name and design while the regulatory text appears on the back or side. Our hotel amenity packaging guide covers how to lay out small packs.

Small packs and sachets

Minis and sachets have very little space. The rules make some provision for small containers, but the details matter, so ask your supplier how each particular will appear on each pack size before artwork is approved. Outer cartons often carry information that does not fit on a sachet.

Legal Metrology and complimentary amenities

The Legal Metrology (Packaged Commodities) Rules govern declarations on pre-packed goods, including the maximum retail price (MRP), net quantity, and the name and address of the manufacturer or packer. They apply most clearly to retail packages sold to consumers.

Hotel amenities are usually bought by the hotel and given to guests rather than sold. The rules distinguish retail packages from packages meant for institutional consumers, and the declarations can differ. Whether your amenities fall into one category or the other depends on the facts: how they are packed, who buys them and whether any are ever sold, for example in a hotel shop or by the minibar.

Do not assume an exemption. Confirm with your legal or compliance adviser how your complimentary amenities are classified, and give your supplier a clear instruction on which declarations to print. It is easier to agree this before artwork is fixed than to reprint later.

Claims to avoid on hotel amenities

• Disease and treatment claims. Words such as cures, heals, treats or prevents suggest a drug, not a cosmetic.
• Germ-kill claims on hand wash. Antibacterial or kills 99.9% of germs claims may bring a product under drug rules. Describe a cosmetic hand wash as cleansing.
• Unsupported test claims. Say dermatologically tested only when a test has been done and a report exists.
• Ayurvedic medical claims on a cosmetic. Herbal ingredients can be named, but a cosmetic should not be presented as an Ayurvedic remedy.

What to ask your supplier

A short request list will tell you most of what you need to know about a manufacturer's compliance.

1. A copy of the cosmetic manufacturing licence, showing the premises and product categories.
2. Specimen labels for each pack size, showing where each required particular appears.
3. Ingredient lists for each formula and scent.
4. Manufacturing documentation, including batch records and how batches are traced.
5. Test reports, if formulas are described as dermatologically tested.
6. Quality certificates such as ISO certification or Halal certification, with dates and scope.
7. Their position on Legal Metrology declarations, and confirmation that they will print what your adviser instructs.

Harrods Health supplies ingredient lists and manufacturing documentation on request, and formulas can be supplied as dermatologically tested with test reports. Our facility is ISO certified, GMP-compliant, Halal certified and US FDA registered, and we hold an AYUSH licence for Ayurvedic manufacturing. Note that US FDA facility registration is a listing with the US regulator, not an approval of individual products. Details are on our quality and certifications page.

If you are running a formal tender, our tender and RFP specification checklist shows how to build these requests into the specification.

A note on Indian Standards

The Bureau of Indian Standards publishes Indian Standards for many cosmetic product types. Some buyers reference them in specifications. Treat them as a reference point for quality discussions, and ask a supplier how its formulas compare, rather than assuming certification is required.

Putting it into practice

For most hotels the sequence is simple. Choose formulas and formats from the hotel amenities collection, confirm Legal Metrology treatment with your adviser, approve specimen labels that combine your branding with the required particulars, and keep the supplier's licence and documents on file. We design and print labels in-house; see custom packaging.

Frequently asked questions

Does our hotel need a cosmetic licence to give guests branded toiletries?

Manufacture requires a licence, and that sits with the manufacturer whose licence number appears on the label. If your hotel is presented as the brand, confirm with your adviser whether any obligation falls on you as the brand owner.

Do complimentary amenities need an MRP?

Not necessarily in the same way as retail packs, but do not assume an exemption. The answer depends on how your amenities are classified under the Legal Metrology rules, so confirm it before artwork is approved.

Can our hand wash say antibacterial?

We recommend against it. Germ-kill and antibacterial claims may bring a product under drug rules. A cosmetic hand wash should be described as cleansing.

Do imported amenities follow different rules?

Yes. Imported cosmetics need registration with CDSCO before import, as well as customs clearance and duty. Domestically made amenities do not.

Ready to specify a compliant range? Explore our private-label hotel toiletries service.