‘100% Mineral’ sunscreen class motion spotlights threat round absolute ingredient claims

Filed in California state courtroom in December 2025, the criticism alleges {that a} vary of Supergoop! sunscreen and SPF merchandise marketed as “100% Mineral” or “Mineral” create a deceptive impression that the whole components is mineral-based, when the merchandise allegedly comprise non-mineral or synthetically processed components.

Whereas the case facilities on sunscreen, the underlying points could lengthen properly past solar care, based on Laura Bentele, a companion and chief of the Agribusiness and Meals group at Armstrong Teasdale.

“This lawsuit is structured as a client safety class motion alleging that Supergoop! marketed a variety of merchandise as ‘100% mineral’ or ‘mineral’ in a method that created an general impression that the merchandise had been solely mineral or pure, regardless that (plaintiff alleges) the product formulation embody non-mineral and/or artificial/chemically processed components,” she stated.

What’s the lawsuit alleging?

On the core of the criticism is an idea steadily utilized in client safety litigation: the “web impression” created by product labeling.

“The plaintiff’s core concept issues the impression created by the ‘100% mineral’ language on a ‘affordable client,’” Bentele stated. “Particularly, plaintiff says that the impression created is that the whole components (not simply the lively UV filters) are mineral-based.”

In line with the criticism, the challenged advertising allegedly communicates that the merchandise “don’t comprise any non-mineral components—whether or not artificial, processed, chemically altered, or in any other case unnatural”.

The submitting lists a number of SKUs marketed with “100% Mineral” language throughout packaging and on-line descriptions, together with lotions, powders, sticks and child sunscreen merchandise.

From a model or formulator perspective, nonetheless, the terminology could also be used in a different way.

“Conversely, a model/formulator may use ‘mineral sunscreen’ as a class descriptor primarily tied to the kind of UV filter and with the expectation that the automobile for that filter (emollients, movie formers, preservatives, pigments) will embody non-mineral components,” Bentele defined.

In sensible phrases, the dispute could activate whether or not a courtroom finds {that a} “affordable client” would interpret “100% mineral” as making use of to the total ingredient listing, not simply the UV filters.

Why this issues past sunscreen

Bentele cautioned that even manufacturers that don’t manufacture sunscreen could need to concentrate.

“Even when a beauty or private care model doesn’t promote sunscreen, if the merchandise are adjoining sun-care/beauty codecs (e.g., mineral powders, mineral eye merchandise, mineral lip colour with SPF), they need to be conscious that there might be added consideration to their lively ingredient claims,” she stated.

Extra broadly, plaintiffs’ companies usually comply with tendencies in advertising language.

“Plaintiffs’ companies specializing in pursuing allegedly false and deceptive advertising claims are all the time on the lookout for the subsequent class of fashionable advertising phrases to focus on and high-profile instances can create a run to litigate in opposition to sure product varieties,” Bentele added.

Regulatory backdrop: the place federal regulation is available in

Mineral sunscreens are regulated as over-the-counter medication below the Federal Meals, Drug and Beauty Act. That regulatory framework could affect how the case develops.

“Extra instantly for the long-term viability of Plaintiff’s declare, it might not be shocking if a preemption argument is raised to defeat the lawsuit as a result of mineral sunscreens are regulated as over-the-counter medication as a result of as long as lively ingredient listing identifies solely zinc oxide or titanium dioxide, then a product may be thought of a mineral sunscreen,” Bentele stated.

On the identical time, the lawsuit displays a broader litigation technique.

“The lawsuit is making an attempt to make the most of a niche in client data and lack of particular regulatory necessities for the phrases used,” Bentele stated. “That is the overall technique for a lot of client fraud class actions.”

The place manufacturers usually run into bother

For producers and suppliers, the case underscores ongoing threat round absolute language and undefined advertising phrases corresponding to “100%,” “clear” and “pure.”

“In my expertise, the recurring drawback areas revolve round absolutist wording and undefined or inconsistently deployed advertising phrases,” Bentele stated.

“The extra absolute the advertising language, the simpler it’s for a Plaintiff to say a ‘affordable client’ can be confused or mislead.”

She added that regulatory compliance alone could not present a whole defend.

“And, within the absence of a regulatory definition for phrases or product requirements, manufacturers don’t get pleasure from regulatory compliance as a whole protection,” she famous.

Sensible risk-mitigation steps

For manufacturers reviewing their portfolios, Bentele recommends beginning with a structured claims audit.

“They need to audit any ‘absolutes’ of their product labeling (which matches past the packaging and contains statements made on their web sites and retail shops),” Bentele stated. “So, statements like ‘100%,’ ‘solely,’ ‘freed from,’ ‘pure,’ ‘nothing however,’ ought to be flagged and evaluated as as to whether the model can defend the probably client studying throughout all labeling channels.”

The place mineral claims are used, clarification could assist handle interpretation threat.

“For instance, if the product accommodates ‘mineral UV filters,’ possibly clarifying language is required on PDPs or elsewhere on the packaging to forestall an ‘whole components’ web impression,” she defined.

Nonetheless, some litigation publicity could stay.

“The very fact is, nonetheless, if advertising claims sit adjoining to unregulated phrases, then it actually comes all the way down to front-end evaluation of whether or not the advertising profit exceeds the litigation threat, as you will be unable insulate solely from a majority of these lawsuits,” Bentele stated.

She additionally suggested documenting processing and sourcing particulars for ingredient claims tied to “pure” or “derived from.”

“Additionally, for claims touching sourcing/processing (particularly ‘pure’ or ‘derived from’), processing steps ought to be documented in order that substantiation of claims is simple,” Bentele added.

What to look at subsequent

The case aligns with ongoing litigation concentrating on ingredient transparency and sustainability positioning.

“This case isn’t any completely different from longstanding assaults on use of ‘all pure’ advertising,” Bentele stated. “Within the coming 12 months, inexperienced/‘clear’ and PFAS-adjacent fits may even see some exercise.”

She added that sustainability and safety-focused claims are more and more being examined below state unfair competitors legal guidelines.

“Lawsuits that take a look at sustainability claims together with puffery security claims are definitely now within the UCL/UDAP (and their non-California counterparts) playbook,” Bentele stated.

The case is at the moment pending. CosmeticsDesign reached out to Supergoop! for remark, however no response was obtained on the time of publication.