Lawsuit highlights risk of ‘100% Mineral’ sunscreen claims

A recent class-action lawsuit targeting Supergoop! has ignited a debate around the accuracy of ingredient claims in the beauty industry. The lawsuit, filed in December 2025 in a California state court, alleges that various Supergoop! sunscreen and SPF products labeled as “100% Mineral” or “Mineral” are misleading consumers by implying that the entire formula is mineral-based when it actually contains synthetic or non-mineral ingredients. While this case specifically focuses on sunscreen products, it has broader implications for other cosmetic brands, particularly those in the sun-care/cosmetic category.

Laura Bentele, a partner and Agribusiness and Food team leader at Armstrong Teasdale, highlighted the potential repercussions of this lawsuit beyond just sunscreen. She explained that the lawsuit accuses Supergoop! of marketing their products as entirely mineral-based, even though they allegedly contain non-mineral or chemically processed ingredients. This consumer protection class action lawsuit revolves around the concept of the “net impression” created by product labeling, where the plaintiff argues that the term “100% mineral” conveys a message that the entire formula, not just the active UV filters, is mineral-based.

The lawsuit points out several SKUs marketed with “100% Mineral” language across various Supergoop! products, from lotions to powders to baby sunscreen. Bentele noted that while brands may use the term “mineral sunscreen” as a descriptor tied to the type of UV filter, consumers may interpret it differently. The lawsuit raises questions about whether a “reasonable consumer” would understand “100% mineral” to apply to the full ingredient list or just the UV filters.

This case serves as a cautionary tale for all cosmetic brands, not just those selling sunscreen. Bentele advised that even adjacent sun-care/cosmetic products like mineral powders or lip color with SPF should be mindful of their active ingredient claims to prevent similar lawsuits. She explained that plaintiffs’ firms often target popular marketing terms, and high-profile cases can trigger a wave of litigations against similar product types.

Mineral sunscreens fall under the regulation of the Federal Food, Drug, and Cosmetic Act as over-the-counter drugs. Bentele suggested that the regulatory framework could influence the outcome of the case, potentially leading to a preemption argument to dismiss the lawsuit. However, the lawsuit exposes a gap in consumer knowledge and regulatory requirements, allowing plaintiffs to challenge marketing claims.

To mitigate the risk associated with absolute language and undefined marketing terms like “100%,” “clean,” and “natural,” Bentele recommended brands conduct a thorough claims audit. By evaluating absolutes in product labeling and clarifying mineral claims to manage interpretation risk, brands can protect themselves from potential lawsuits. However, regulatory compliance alone may not offer complete protection, emphasizing the importance of carefully scrutinizing marketing claims to avoid misleading consumers.