It’s a fee! It’s not a punitive measure nor is it an indemnification for lost revenue or expenses incurred. It’s the price for a service rendered. As long as it is clearly disclosed, the property can set the cleaning fee in whatever amount it feels like. It’s more or less the same as late check-out fees—these aren’t due only if property demonstrates it suffered a loss of revenue or damages due to compensation given to incoming guests or because housekeeping had to be paid overtime. No, guest failed to checkout by 11am, property charges a clearly disclosed late check-out fee, even if the room sat empty for several days afterwards. Same with cleaning fee: property has a fixed fee for deep cleaning a non-smoking room where smoke was detected. It’s the price they charge for that service, regardless of any mark up in relation to the actual cost of the cleaning operations.