A Word about Refilling Dispensers

For reasons of economy refilling dispensers is common practice in the hospitality industry. However our advice is that this is not best practice for the following reasons.

Batch Traceability

Article 19 of Regulation (EC) No 1223/2009 (“The Cosmetic Regulations”) states that all cosmetic products must clearly display the production batch number so that full traceability can be maintained throughout the supply chain. If dispensers are refilled then, unless strict batch control procedures have been followed, it is inevitable that batches will be mixed thus erasing batch traceability in contravention of Article 19. It is our opinion that this shifts the onus of responsibility for the safety of the cosmetic product from the supplier to the hotel.


Article 19 further requires that every cosmetic product must display a list of ingredients. This is of particular importance to those individuals who have allergies. Unless strict procedures are followed it is very possible that a dispenser could be refilled with the wrong product (e.g. shower gel instead of liquid soap) which would contravene both the labelling and batch traceability regulations.


In the factory the cosmetic products are made and filled in very hygienic conditions. It is unlikely that such conditions would be replicated on site meaning that every time a dispenser is refilled in a hotel bathroom there is the possibility that the product could be contaminated by bacteria or other germs.

Labour Cost

While refilling is cheaper in terms of product the cost of labour is often overlooked. Opening the dispenser, refilling and cleaning is time consuming and can be messy. When this time is multiplied over the year it can represent a significant cost.

Environmental Impact

Even though refilling reduces the number of dispensers entering the waste stream it is important to remember that this benefit is almost always offset by the need to use a plastic bulk container.

Our dispensers are made from recyclable PET which means that they can be used to create new dispensers or alternatively to convert waste into energy. In order to further minimise our environmental impact we will soon be able to supply dispensers made from PCR (post-consumer) / PIR (post-industrial) recycled plastic or from plant based sources such as “bagasse” which is a waste product produced from refining sugar cane.