Sustainable Hotel Amenities in Canada: Plastics, EPR and Green Claims

Canada's federal Single-use Plastics Prohibition Regulations cover six categories of items, namely checkout bags, cutlery, certain foodservice ware, ring carriers, stir sticks and straws, and do not list hotel toiletry bottles. Many Canadian hotels are moving to dispensers and refills anyway. Provincial extended producer responsibility programs and the Competition Act's rules on environmental claims still apply.

This guide covers what the federal rules do and do not do, how to choose between minis and dispensers, how provincial packaging programs work, and how to talk about sustainability without overclaiming. It is general information, not legal advice; confirm the current rules with your importer or a regulatory consultant. For regions and products, see our Canada hotel amenities hub.

What the federal single-use plastics rules cover

The Single-use Plastics Prohibition Regulations target six categories: checkout bags, cutlery, certain foodservice ware made from problem plastics, ring carriers, stir sticks and straws. They restrict manufacture, import and sale of those items in Canada, with some exceptions.

Hotel shampoo, conditioner and shower gel bottles are not on that list. The regulations have also faced a court challenge, so check the current status with your adviser. Separately, the federal government has set up a Federal Plastics Registry that requires some businesses to report plastics they place on the Canadian market; ask your importer whether it applies to them.

Provincial and municipal rules

Provinces and municipalities can make their own rules on single-use items. Some cities have bylaws on single-use items in food service, and policies change. Before you choose formats for a property, check the rules where it operates. Do not assume that because a federal rule does not apply, nothing does.

Why hotels are moving to dispensers anyway

Even without a federal ban on toiletry bottles, many Canadian properties have moved to wall dispensers and bulk refills. The reasons are practical: less packaging per guest, fewer half-used minis thrown away, simpler housekeeping and guest expectations, particularly in markets such as British Columbia where dispensers are already common.

Format	Where it fits	Points to weigh
Wall dispensers with 5 L refills	City, airport and resort rooms; public washrooms	Least packaging per guest; needs refill hygiene and tamper-resistant fittings
Larger bottles on a bracket	Boutique hotels, inns, B&Bs	Branded look with less waste than minis
Tubes and minis	Suites, special requests, take-home items	Highest packaging per guest; easiest to give away
Sachets	Motels, remote lodges, emergency stock	Light and compact; small to label and hard to recycle

We make all of these formats, so a single signature scent can run across them. Many properties use dispensers in rooms and keep a small stock of minis for specific uses. See the hotel amenities range.

Refill hygiene

Dispensers only work if the product stays clean. Sealed cartridge systems are the simplest to manage. Where housekeeping refills from a 5 L container, use clean, dedicated equipment, do not top up partly used dispensers with a different batch without cleaning, and keep refills sealed until use. Check whether local public health guidance applies to your property.

Provincial extended producer responsibility

Packaging recycling in Canada is increasingly run through provincial extended producer responsibility (EPR) programs. Under EPR, the businesses that supply packaging into a province, rather than municipalities alone, are responsible for funding or running its collection and recycling. British Columbia has had a packaging program for many years. Ontario and Quebec are moving their curbside systems to producer responsibility, and other provinces, including Alberta and several Atlantic provinces, are at different stages.

Who counts as the obligated producer differs by province. It is often the brand holder if it is resident in Canada, and otherwise the importer or another business in the chain. For hotel amenities, how the rules treat packaging supplied to a hotel and used by guests is a question for your importer or a consultant.

What we can do is supply the data these programs need. Because we manufacture and decorate packaging in-house, we can give material types and weights for bottles, caps, pumps, labels and cartons. Plan the packaging with that in mind on our custom packaging page.

Environmental claims under the Competition Act

The Competition Act prohibits false or misleading representations to the public, and that includes environmental claims. Amendments made in 2024 added two specific requirements:

• A claim about the environmental benefits of a product must be based on adequate and proper testing.
• A claim about the environmental benefits of a business or its activities must be substantiated in accordance with internationally recognized methodology.

The Competition Bureau has published guidance on how it reads these provisions. For hotels and their suppliers, the risk sits in phrases like "eco-friendly", "sustainable", "plastic-free", "recyclable" and "carbon neutral".

Writing claims you can support

• Be specific. "Bottle made with recycled plastic" is better than "eco bottle", and only if you can document the content.
• Match the claim to the guest's location. "Recyclable" depends on what local programs accept.
• Do not imply the whole product is green because one part has changed.
• Keep evidence on file: material specifications, test reports and supplier declarations.
• Apply the same discipline to websites, signage, sales sheets and booking-site descriptions.

Claims about the hotel as a whole, such as reduced plastic use across a group, fall under the business-activity limb and need sound methodology. If you are in doubt, describe what you did rather than what it means for the planet.

A practical plan for one property

1. Check federal, provincial and municipal rules for the property's location.
2. Decide formats room by room: dispensers where possible, minis where they earn their place.
3. Ask your importer how provincial EPR applies and what packaging data it needs.
4. Choose packaging materials and get specifications on file.
5. Write claims from the evidence, not the other way round, and have them reviewed.
6. Train housekeeping on refill hygiene and track waste before and after the change.

Measuring what changed, such as the number of minis no longer bought, gives you a factual basis for anything you later say to guests.

Learning from other markets

Europe is phasing out many hotel miniatures under its packaging regulation, and the US relies on FTC guidance and state laws for recyclability claims. If your group operates across markets, see our guides to the end of hotel miniatures in Europe and green claims for US hotel amenities. Canadian rules differ, but the direction is similar.

Frequently asked questions

Are hotel miniatures banned in Canada?

The federal Single-use Plastics Prohibition Regulations cover six categories and do not list hotel toiletry bottles. Provincial or municipal rules may differ, so check locally.

Who is responsible for packaging under provincial EPR programs?

It varies by province. Programs can place obligations on brand holders, importers or others in the supply chain. Ask your importer or a consultant which applies to your amenities.

Can we call our bottles recyclable?

Only if you can support the claim for the places your guests are. Under the Competition Act, environmental claims about products need adequate and proper testing. Keep wording specific.

Are dispensers always better?

They usually use less packaging per guest, but they need good refill hygiene and tamper-resistant fittings. Many properties use dispensers in rooms and keep minis for specific uses.

Moving to dispensers or refills? Start a brief on our private-label hotel toiletries page.