Filed in California state court in December 2025, the complaint alleges that a range of Supergoop! sunscreen and SPF products marketed as “100% Mineral” or “Mineral” create a misleading impression that the entire formula is mineral-based, when the products allegedly contain non-mineral or synthetically processed ingredients.
While the case centers on sunscreen, the underlying issues may extend well beyond sun care, according to Laura Bentele, a partner and leader of the Agribusiness and Food team at Armstrong Teasdale.
“This lawsuit is structured as a consumer protection class action alleging that Supergoop! marketed a range of products as ‘100% mineral’ or ‘mineral’ in a way that created an overall impression that the products were entirely mineral or natural, even though (plaintiff alleges) the product formulas include non-mineral and/or synthetic/chemically processed ingredients,” she said.
What is the lawsuit alleging?
At the core of the complaint is a concept frequently used in consumer protection litigation: the “net impression” created by product labeling.
“The plaintiff’s core theory concerns the impression created by the ‘100% mineral’ language on a ‘reasonable consumer,’” Bentele said. “Specifically, plaintiff says that the impression created is that the entire formula (not just the active UV filters) are mineral-based.”
According to the complaint, the challenged marketing allegedly communicates that the products “do not contain any non-mineral ingredients—whether synthetic, processed, chemically altered, or otherwise unnatural”.
The filing lists multiple SKUs marketed with “100% Mineral” language across packaging and online descriptions, including lotions, powders, sticks and baby sunscreen products.
From a brand or formulator perspective, however, the terminology may be used differently.
“Conversely, a brand/formulator might use ‘mineral sunscreen’ as a category descriptor primarily tied to the type of UV filter and with the expectation that the vehicle for that filter (emollients, film formers, preservatives, pigments) will include non-mineral ingredients,” Bentele explained.
In practical terms, the dispute may turn on whether a court finds that a “reasonable consumer” would interpret “100% mineral” as applying to the full ingredient list, not just the UV filters.
Why this matters beyond sunscreen
Bentele cautioned that even brands that do not manufacture sunscreen may want to pay attention.
“Even if a cosmetic or personal care brand does not sell sunscreen, if the products are adjacent sun-care/cosmetic formats (e.g., mineral powders, mineral eye products, mineral lip color with SPF), they should be mindful that there could be added attention to their active ingredient claims,” she said.
More broadly, plaintiffs’ firms often follow trends in marketing language.
“Plaintiffs’ firms that specialize in pursuing allegedly false and misleading marketing claims are always looking for the next category of popular marketing terms to target and high-profile cases can create a run to litigate against certain product types,” Bentele added.
Regulatory backdrop: where federal law comes in
Mineral sunscreens are regulated as over-the-counter drugs under the Federal Food, Drug and Cosmetic Act. That regulatory framework may influence how the case develops.
“More immediately for the long-term viability of Plaintiff’s claim, it would not be surprising if a preemption argument is raised to defeat the lawsuit because mineral sunscreens are regulated as over-the-counter drugs because so long as active ingredient list identifies only zinc oxide or titanium dioxide, then a product can be considered a mineral sunscreen,” Bentele said.
At the same time, the lawsuit reflects a broader litigation strategy.
“The lawsuit is trying to take advantage of a gap in consumer knowledge and lack of specific regulatory requirements for the terms used,” Bentele said. “This is the general strategy for many consumer fraud class actions.”
Where brands often run into trouble
For manufacturers and suppliers, the case underscores ongoing risk around absolute language and undefined marketing terms such as “100%,” “clean” and “natural.”
“In my experience, the recurring problem areas revolve around absolutist wording and undefined or inconsistently deployed marketing terms,” Bentele said.
“The more absolute the marketing language, the easier it is for a Plaintiff to claim a ‘reasonable consumer’ would be confused or mislead.”
She added that regulatory compliance alone may not provide a complete shield.
“And, in the absence of a regulatory definition for terms or product standards, brands do not have the benefit of regulatory compliance as a complete defense,” she noted.
Practical risk-mitigation steps
For brands reviewing their portfolios, Bentele recommends starting with a structured claims audit.
“They should audit any ‘absolutes’ in their product labeling (which goes beyond the packaging and includes statements made on their websites and retail stores),” Bentele said. “So, statements like ‘100%,’ ‘only,’ ‘free of,’ ‘pure,’ ‘nothing but,’ should be flagged and evaluated as to whether the brand can defend the likely consumer reading across all labeling channels.”
Where mineral claims are used, clarification may help manage interpretation risk.
“For example, if the product contains ‘mineral UV filters,’ maybe clarifying language is needed on PDPs or elsewhere on the packaging to prevent an ‘entire formula’ net impression,” she explained.
Still, some litigation exposure may remain.
“The fact is, however, if marketing claims sit adjacent to unregulated terms, then it really comes down to front-end analysis of whether the marketing benefit exceeds the litigation risk, as you will not be able insulate entirely from these types of lawsuits,” Bentele said.
She also advised documenting processing and sourcing details for ingredient claims tied to “natural” or “derived from.”
“Also, for claims touching sourcing/processing (especially ‘natural’ or ‘derived from’), processing steps should be documented so that substantiation of claims is straightforward,” Bentele added.
What to watch next
The case aligns with ongoing litigation targeting ingredient transparency and sustainability positioning.
“This case is no different from longstanding attacks on use of ‘all natural’ marketing,” Bentele said. “In the coming year, green/‘clean’ and PFAS-adjacent suits may see some activity.”
She added that sustainability and safety-focused claims are increasingly being tested under state unfair competition laws.
“Lawsuits that test sustainability claims along with puffery safety claims are certainly now in the UCL/UDAP (and their non-California counterparts) playbook,” Bentele said.
The case is currently pending. CosmeticsDesign reached out to Supergoop! for comment, but no response was received at the time of publication.
