Labelling Hotel Amenities for the US Market

A US label for hotel shampoo, shower gel or lotion must show what the product is, the net contents in both US customary and metric units, the name and place of business of the manufacturer, packer or distributor, an ingredient declaration and any required warnings. Imported products also need country of origin marking such as "Made in India", and MoCRA added a contact point for adverse event reports.

Cosmetic labelling in the US comes mainly from the Federal Food, Drug, and Cosmetic Act and the Fair Packaging and Labeling Act, with FDA regulations setting the detail, and MoCRA adding new elements. Hotel amenities raise particular questions because packs are small, dispensers are refilled, and products are given rather than sold. This guide walks through each element. For the wider US picture, see our US hotel amenities hub.

The principal display panel

The principal display panel is the part of the label most likely to be seen, usually the front of the bottle or tube. Two elements belong there: the statement of identity and the net quantity of contents. The other information can usually go on an information panel, often the back.

Statement of identity

The statement of identity tells the guest what the product is, in plain words: "Shampoo", "Conditioner", "Shower Gel", "Body Lotion", "Hand Wash". It should be prominent and readable. A scent name or brand name alone is not enough; "Bergamot & Cedar" means nothing in a shower unless it sits next to "Shampoo".

For hotels this element doubles as guest service. Dispensers in a row look alike, so make the product type the largest text after the logo.

Net quantity of contents

Net quantity is declared in both US customary and metric units. Liquids are declared by volume, for example "1 fl oz (30 mL)" for a mini or "16.9 fl oz (500 mL)" for a dispenser bottle. The declaration sits in the lower part of the principal display panel, in a type size that rises with panel size. Make sure the figures match the actual fill, and that rounding follows the rules your label adviser applies.

5 L refills and other containers that guests never see still need accurate net contents for the buyer, and they may be checked by inspectors. "5 L" alone is not a full US declaration; add the US customary equivalent.

Ingredient declaration

Ingredients are listed in descending order of predominance, with ingredients at or below one per cent allowed in any order after the others, and colour additives listed at the end. Use the names FDA rules require, which draw on recognised ingredient dictionaries; in practice most suppliers work from INCI names. Fragrance can usually be declared as "fragrance", although MoCRA directed the FDA to propose rules on declaring certain fragrance allergens, so leave room for that change. We supply full ingredient lists for every formula.

Free amenities and small packages

FDA's ingredient labelling rules are framed around products distributed to consumers for personal care. Whether any exemption applies to complimentary hotel amenities depends on how the products are distributed, and most hotel brands declare ingredients on every pack anyway because guests ask about allergies. FDA rules also allow alternative placement for very small packages, for example on outer packaging or accompanying labelling, under defined conditions. Confirm any reliance on these provisions with a regulatory consultant.

Name and place of business

The label must name the manufacturer, packer or distributor, with its place of business. If the named company is not the manufacturer, add a qualifier such as "Manufactured for" or "Distributed by". For private-label hotel products this is usually the hotel brand owner or distributor, who is normally also the MoCRA responsible person. Harrods Health does not appear unless you choose to name us.

MoCRA also requires a domestic address, domestic phone number or electronic contact, such as a website, through which the responsible person can receive adverse event reports. Many labels combine this with the "Distributed by" line.

Warnings

Some cosmetics need specific warnings, for example certain aerosols, and any product whose safety has not been substantiated must carry a warning to that effect. Standard rinse-off and leave-on hotel liquids rarely need special warnings, but many brands add simple precautions such as "For external use only. Avoid contact with eyes." State rules can add requirements; in California, Proposition 65 may require a warning depending on ingredients. See our California page.

Country of origin

Imported goods must generally be marked with their country of origin, in English, legibly and as permanently as the article allows, so that the ultimate purchaser knows where they were made. Our products are marked "Made in India". Who counts as the ultimate purchaser for hotel amenities, and whether marking the container or the outer carton is enough, are questions for your customs broker.

Label checklist

Element	Where	Hotel note
Statement of identity	Principal display panel	Make product type the clearest word on a dispenser
Net quantity, fl oz and mL	Lower part of principal display panel	Refills need full dual-unit declarations too
Ingredients	Information panel	Declare even on minis where space allows
Name and place of business	Information panel	Usually brand owner or distributor with a qualifier
Adverse event contact	Information panel	Domestic address, phone or website
Warnings	Information panel	Prop 65 in California if applicable
Country of origin	Article or container	"Made in India"

Dispensers, refills and minis

Dispensers create a labelling question that minis do not. The guest sees the dispenser; the refill carries the batch. A common approach is a guest-facing dispenser label with identity, brand, scent and key information, and a full regulatory label on the refill container, with clear links between them. Decide this with your adviser before printing.

Minis and sachets have the opposite problem: very little space. Shorter brand marks, smaller but legible type, back-of-pack panels and peel-open labels can all help. Our custom packaging team manufactures and decorates packaging in-house, so we can test layouts on real bottles before a run.

Claims on the label

Words on a label can change a product's legal category. "Antibacterial" on hand wash makes it an OTC drug. "Recyclable" or "eco-friendly" falls under the FTC Green Guides. "Dermatologically tested" should be backed by a test report; our formulas can be supplied as dermatologically tested with reports on request. Certification marks, such as Halal, should only appear where the product is covered; see our Halal hotel toiletries guide.

Browse formats in our hotel amenities collection, and confirm final artwork with a regulatory consultant and your customs broker before production.

Frequently asked questions

Do US hotel toiletries need both ml and fl oz?

Yes. Net quantity on US consumer cosmetic packaging is declared in both US customary units, such as fl oz, and metric units, such as mL.

Does the manufacturer's name have to appear on the label?

No. The label must name the manufacturer, packer or distributor. Private-label products usually show the brand owner or distributor with a qualifier such as "Distributed by".

Do free hotel amenities need an ingredient list?

Most hotel brands declare ingredients on every product. Whether a specific exemption applies depends on how the product is distributed, so confirm with a regulatory consultant.

Where does "Made in India" go?

Country of origin marking must be legible and reasonably permanent, on the article or its container. Your customs broker will confirm what is needed for your packaging.

Ready to design labels? Read about private-label hotel toiletries or go back to our US hotel amenities hub.