Plastic Rules and Refillable Amenities in Japanese Hotels: The Plastic Resource Circulation Act, Dispensers, Refills and Onsen Wash Stations

Japan's Plastic Resource Circulation Act, in force since April 2022, requires businesses that provide certain specified single-use plastic products to reduce them. For hotels and ryokan the list includes toothbrushes, hairbrushes, combs, razors and shower caps. At the time of writing, shampoo and conditioner bottles are not on it, yet many properties have moved to dispensers and refills anyway.

Hotel buyers sometimes hear that "Japan banned plastic amenities". That is not quite right, and the details affect what you buy. This guide explains what the law targets, what it leaves out, how dispensers and refills work in rooms and onsen, and how packaging recycling duties fit in. For formats and scents across the country, see our hotel amenities supplier page for Japan.

It is general guidance. Confirm current obligations with your marketing authorisation holder, importer or a regulatory consultant.

What the Plastic Resource Circulation Act does

The Act takes a whole-life approach to plastics: product design, reduction, collection and recycling. For businesses that hand out free single-use plastic items, it defines a list of specified products and requires providers to take steps to reduce them. The list covers items from three settings: food service (such as cutlery and straws), laundry and dry cleaning (such as hangers and clothing covers), and accommodation.

For accommodation, the specified items are:

• toothbrushes;
• hairbrushes;
• combs;
• razors;
• shower caps.

Measures providers can use include charging for items, offering them only on request, rewarding guests who decline them, using lighter or alternative materials, and offering reusable options. Larger providers can face closer government scrutiny. Many properties now place these items at the front desk or an amenity bar rather than in every room.

Harrods Health does not make toothbrushes, combs, razors, shower caps or other accessory kits. We make the liquid toiletries.

Where shampoo and conditioner bottles stand

At the time of writing, shampoo, conditioner, shower gel, lotion and hand wash bottles are not among the specified products under the Act. A hotel can still legally put minis in rooms. But several forces push the other way:

• hotel groups' own sustainability targets and reporting;
• guests, especially overseas visitors, who expect refillable amenities;
• cost per use, which is usually lower with refills;
• less packaging waste for the property to sort and pay to dispose of.

Policy can change, so check the list again before committing to a large stock of minis. It is also worth asking your marketing authorisation holder or industry association whether any voluntary commitments in the hotel sector go further than the law, since guests and corporate clients often judge a property against those rather than against the legal minimum. A range that already runs on dispensers is easy to defend whichever way the rules move.

Comparing formats for Japanese properties

Format	Where it fits	Points to weigh
Minis	Luxury rooms, suites, guest kits	Guest appeal; more packaging per use
Tubes	Body lotion, travel kits	Good print area for Japanese text
Sachets	Capsule hotels, day-use guests	Single use; small label area
Dispenser bottles	Most rooms, wash stations, changing areas	Less waste; needs a refilling routine
5 L refills	Housekeeping stores	Compact storage; lot tracking

Our guide comparing miniatures, dispensers and bulk refills goes deeper into cost and guest perception.

Ryokan and onsen wash stations

Japanese public baths were refill-based long before the Act. At each wash station, where guests wash seated before entering the bath, shampoo, conditioner and body wash sit in dispensers that serve guest after guest. The change the Act brought to these settings was mostly about accessories: combs, razors and shower caps once set out at every station are now often available on request.

For the liquids, the priorities are reliable pumps in steam, labels guests can tell apart, and a hygienic refill routine. See our page on ryokan and onsen amenities.

Refilling well

A dispenser is only as good as the routine behind it. Topping up a half-full bottle indefinitely mixes old and new product and can compromise hygiene. A better routine is to empty, clean and dry the dispenser, refill from a freshly opened container, and record the lot number. Our refilling SOP guide sets out the steps. Sealed cartridge or pouch systems reduce handling further, if your dispenser supports them.

We fill refills to match your dispensers and label each one clearly in Japanese so night staff pick the right product. Browse bulk packs and refills.

Resort and climate considerations

In humid places such as Okinawa, dispensers sit in warm, wet bathrooms and outdoor showers. Choose pumps and closures that seal well and labels that stay legible when wet. Our page on Okinawa resorts covers this setting.

The Containers and Packaging Recycling Act

A separate law, the Containers and Packaging Recycling Act, places recycling obligations on businesses that use containers and packaging for the goods they sell, or that import packaged goods. These duties are generally met by paying for recycling through a designated system, and some smaller businesses are exempt. For hotel toiletries brought in from India, the importer or marketing authorisation holder is usually the business concerned. Ask how they handle it, and factor the cost into pack choices: lighter bottles, fewer components and refills all reduce the packaging volume.

Japan also requires recycling identification marks on certain plastic and paper packaging. Your holder will confirm which apply, and we add them to the artwork.

What it means for different buyers

Hotel groups usually set one policy across the portfolio: dispensers as standard, minis by exception, specified items on request. Their main task is consistency, with the same scent and the same labels in every property.

Management companies running business hotels and serviced apartments side by side often need two dispenser sizes and a hand wash for kitchens. A single refill size that fits both simplifies stock.

Ryokan owners already run wash-station dispensers, so the decision is mostly about in-room baths and how accessories are offered. Many keep a small branded set for rooms with private baths and refills for the public bath.

Amenity distributors and trading companies supply many properties and often act as, or work with, the marketing authorisation holder. A base formula in several refill sizes, with property-specific labels, lets them serve both sustainability-minded hotels and properties that still want minis.

Designing a lower-waste range

1. Use dispensers for shampoo, conditioner, body wash and hand wash in most rooms.
2. Reserve minis or tubes for suites and guest kits where they add value.
3. Choose fewer packaging components: avoid unnecessary over-caps and cartons.
4. Pick refill sizes your housekeeping team can lift and store.
5. Keep one signature scent across formats so the experience is consistent.

Our custom packaging options cover bottles, tubes and decoration made in-house.

Frequently asked questions

Has Japan banned shampoo minis in hotels?

No. At the time of writing, the Plastic Resource Circulation Act targets items such as toothbrushes, hairbrushes, combs, razors and shower caps in accommodation. Shampoo bottles are not on that list.

What must hotels do about the specified items?

Take steps to reduce them, for example offering them on request, charging, rewarding guests who decline, or switching to lighter or alternative materials.

Who handles Containers and Packaging Recycling Act obligations?

Generally the business that uses or imports the packaged goods, often the importer or marketing authorisation holder. Confirm with them.

Do you make bamboo toothbrushes or combs?

No. We make shampoo, conditioner, shower gel, 2-in-1, body lotion and hand wash only.

Explore our hotel toiletries range and refill formats.