9.2 General Price List (GPL) Requirements
Key Takeaways
- The GPL is the cornerstone document: give it for the consumer to keep to anyone who asks in person about funeral goods, services, or prices, and offer it at the beginning of face-to-face discussion of disposition type, specific goods/services, or prices.
- A verbal “it’s available if you want to look” is not enough—physically offer a list the consumer may retain; you cannot charge for required price information.
- The GPL must include identifying information, six required disclosures (using Rule wording), and up to 16 required itemized price categories for goods and services the firm actually offers.
- Required categories include basic services of funeral director and staff, embalming, other preparation, viewing, funeral ceremony, memorial service, graveside service, transfer, hearse, limousine, casket price range or individual prices, OBC price range or individual prices, forwarding, receiving, direct cremation, and immediate burial.
- Exam traps: phone/mail inquiries do not by themselves require mailing a GPL; removal plus embalming-authorization-only can avoid GPL if no price/goods discussion occurs and embalming-not-required is disclosed; packages never erase itemization.
9.2 General Price List (GPL) Requirements
Quick Answer: The General Price List (GPL) is the Funeral Rule’s keystone. At a face-to-face inquiry or discussion about prices, specific goods/services, or the type of funeral/disposition, you must give a printed or typewritten GPL that the person may keep. It must show identifying information, the six required disclosures (exact Rule wording), and itemized prices for the required categories you actually offer—including basic services, embalming, other preparation, viewing/ceremony/memorial/graveside, transfer, hearse, limousine, casket and OBC prices or ranges, forwarding/receiving, direct cremation, and immediate burial.
Who Gets a GPL—and When
You must give the GPL to anyone who asks, in person, about funeral goods, funeral services, or the prices of such goods or services—and you must give it to keep. The requester need not be arranging a funeral today. Competitors, journalists, consumer groups, religious societies, and government representatives who inquire in person are included.
You need not hand out a GPL the second someone walks in the door. You must offer it when you begin to discuss any of the following:
- The type of funeral or disposition you can arrange;
- The specific goods and services you offer; or
- The prices of your goods and services.
Before that trigger, you may offer condolences and handle preliminary matters such as veterans’ benefits or death-certificate logistics. The trigger is a face-to-face meeting—at the funeral home, at the family’s home, at a hospital or nursing facility, or elsewhere. Staff who leave the building should carry extra GPLs.
Embalming-Authorization Exception at Removal
You are not required to offer a GPL if, while removing the deceased for transportation to the funeral home, you only request authorization to embalm—provided you:
- Disclose that embalming is not required by law (except in special cases, if relevant); and
- Refrain from further discussion of prices or selection of funeral goods or services during that removal contact.
Any further discussion of prices or goods/services triggers the GPL requirement.
Phone and Mail Inquiries
The Rule requires accurate telephone price disclosures from your price lists, but it does not require you to mail or send a GPL solely because someone called or wrote. If a phone or mail inquiry is followed by an in-person meeting, provide the GPL at that meeting. (Some states require mailing a list on request—always check state law.)
“To Keep” Means Physical Offer for Retention
A verbal offer is not enough. You cannot merely say a list is available for inspection, and you cannot wave a single binder that looks like the funeral director’s only copy. You must physically offer a GPL the consumer can take home. If the person refuses to accept or look at it, you need not force it—but you must not discourage review (for example, by saying it is unnecessary or too hard to understand). You cannot charge a fee for required price information.
Identifying Information on the GPL
The GPL should be printed or typewritten and must contain:
- Name, address, and telephone number of the funeral provider’s place of business (including branch locations where relevant);
- The caption: “General Price List”;
- The effective date of the price list.
Required Disclosures on the GPL (Six)
The Rule requires six disclosures, using the identical wording the Rule provides (you may not edit or paraphrase the FTC language). Conceptually for NBE:
| # | Disclosure theme | Placement / concept |
|---|---|---|
| 1 | Right of selection | Consumer may choose only desired items; non-declinable basic services charge will be included if applicable; legal requirements explained in writing on the Statement |
| 2 | Embalming | Law usually does not require embalming; may be needed for certain arrangements (e.g., viewing); if declined, consumer usually may choose arrangements that do not require paying for it (e.g., direct cremation or immediate burial). Place in immediate conjunction with the embalming price |
| 3 | Alternative containers | For direct cremation, alternative containers are available; describe materials concept and the firm’s containers. Place next to direct-cremation prices (omit if firm does not arrange direct cremations) |
| 4 | Basic services fee | Explains the professional services fee and, if non-declinable, that it is added to arrangements (and is already included in certain package-style charges such as direct cremation, immediate burial, and forwarding/receiving, per the disclosure wording) |
| 5 | Casket Price List | If using a separate CPL, state the casket price range and that a complete list will be provided at the funeral home |
| 6 | Outer Burial Container Price List | If using a separate OBCPL, state the OBC price range and that a complete list will be provided; OBC legal/cemetery disclosure applies on GPL or OBCPL as the Rule directs |
Basic services fee concept: The fee for basic services of funeral director and staff (arrangements conference, planning, permits, notices, coordination, ordinary sheltering, and often unallocated overhead) is generally the only non-declinable services/facilities/overhead fee the Rule allows (unless state/local law requires otherwise). A second non-declinable “facilities fee” or casket handling fee on top of the basic services fee violates the Rule’s framework.
Required Itemized Prices (The 16 Categories)
You must list the following if you offer them, with a price for each (order may vary). You need not list items you do not offer. You may list additional items (urns, acknowledgment cards, etc.) and may show packages in addition to—not instead of—itemized prices.
| # | Required category |
|---|---|
| 1 | Forwarding of remains to another funeral home (with services included for the price) |
| 2 | Receiving remains from another funeral home (with services included) |
| 3 | Direct cremation (price range; separate price where purchaser provides the container; separate prices including alternative container; describe services/container) |
| 4 | Immediate burial (price range; separate price where purchaser provides the casket; separate prices where you provide a casket/container; describe services/container) |
| 5 | Basic services of funeral director and staff (and overhead as allocated) |
| 6 | Transfer of remains to the funeral home |
| 7 | Embalming |
| 8 | Other preparation of the body |
| 9 | Use of facilities and staff for viewing |
| 10 | Use of facilities and staff for funeral ceremony |
| 11 | Use of facilities and staff for memorial service |
| 12 | Use of equipment and staff for graveside service |
| 13 | Hearse |
| 14 | Limousine |
| 15 | Casket — individual prices or range referring to the CPL |
| 16 | Outer burial container — individual prices or range referring to the OBCPL |
Direct cremation note: If you offer direct cremation, you must make an alternative container available and price pathways accordingly. Do not force a traditional casket for direct cremation.
“Free” required items: You generally cannot list required itemized categories as “free/no charge” in a way that buries their cost elsewhere and removes real choice—exam writers flag fake freebies that defeat itemization.
Printed Lists, Updates, Pre-Need, and Retention Awareness
- Keep the GPL current; show the effective date.
- Pre-need GPLs must still include required disclosures and itemized offerings; you cannot offer only packages to pre-need customers.
- Give a GPL when survivors modify pre-need selections or must pay additional sums.
- Recordkeeping: Keep price lists for at least one year from the date you last distributed them to customers (and keep completed Statements for at least one year from the arrangements conference) for FTC inspection.
Exam Traps: When the GPL Is / Isn’t Required
| Situation | GPL duty |
|---|---|
| In-person discussion of prices or specific goods/services | Required — offer for retention |
| In-person discussion of overall disposition/funeral type | Required |
| Competitor or reporter asks in person about prices | Required |
| Phone-only price question | Accurate phone info from lists; sending GPL not federally required |
| Mail-only inquiry | Sending GPL not federally required |
| Removal contact: embalming auth only + proper disclosure + no price/goods talk | GPL not triggered solely by that auth request |
| Removal contact that expands into package/price talk | GPL triggered |
| “They already know us” / “regular family” | Still required when triggers occur |
| Showing a binder “for my use only” | Noncompliant — must offer a list they can keep |
Scenario: At a nursing home, you discuss only transfer and ask for embalming authorization, disclose embalming is not required by law, and schedule arrangements for tomorrow. GPL not required at that moment. If the daughter then asks, “What does a full traditional funeral cost?” you must provide the GPL there.
NBE Traps for This Section
| Trap | Correction |
|---|---|
| GPL only at the funeral home | Face-to-face anywhere |
| Oral price tour replaces GPL | Written list for retention |
| Sixteen categories always printed even if not offered | List only what you offer |
| Basic services fee is always optional | Often non-declinable when structured as such under the Rule |
| Packages erase the 16 items | Itemization remains |
| Phone call alone requires mailing GPL | Federal Rule: phone answers from lists; retention GPL is face-to-face |
Bottom line: Know the GPL trigger events, the retention requirement, the six disclosures, the sixteen price categories, and the removal/phone exceptions cold. The GPL is the document every other Funeral Rule tool answers to.
When must a funeral provider offer the General Price List during a face-to-face encounter?
Which practice complies with the Funeral Rule’s GPL retention requirement?
Which set correctly reflects required GPL itemized categories when offered by the firm?
At a hospital removal, staff request only embalming authorization, disclose that embalming is not required by law except in special cases if relevant, and do not discuss prices or goods. Is a GPL required at that moment under the Funeral Rule?