Mielle Organics is facing allegations in a new lawsuit that its cult-favored beauty products are not American-made or “natural” despite the company’s claims that they are. In a newly filed lawsuit, Sharon Allen alleges that Mielle Organics deceptively markets its products as “Made in the USA” and composed of “natural, organic ingredients” even though the Procter & Gamble-owned company sources many of the key components from outside the U.S. and formulates products with synthetic compounds. The complaint further challenges the brand’s marketing claims that its products boast an array of benefits, including that they boost hair growth – claims the plaintiff contends are unsubstantiated and misleading.
According to the proposed class action complaint, which was filed in the U.S. District Court for the Central District of California in February, Mielle Organics actively markets its Rosemary Mint Scalp & Hair Strengthening Oil, a product that surged in popularity thanks to TikTok virality and celebrity endorsements, as “Made in the USA.” The problem, per Allen, is that the company fails to disclose that many of its ingredients, such as tea tree oil, coconut oil, and murumuru seed butter, are not domestically sourced, thereby, violating federal regulations that require “all or virtually all” of a product’s components to be U.S.-sourced to bear such a label.
> The Federal Trade Commission’s Made in USA Labeling Rule “clearly defines the meaning of ‘Made in the United States,’ including synonymous phrases, as well as when it can be used without clear and adequate qualification notifying consumers that the good or service in question contains or is made with ingredients or components that are not made or sourced in the U.S.,” Allen argues.
At the same time, Allen takes issue in the lawsuit with Mielle Organics’ “natural” positioning, an increasingly powerful marketing tool in the $100 billion global hair care market, which she alleges is “materially false.” The brand prominently labels and promotes several of its products as natural, Allen argues, even though they are formulated with “synthetic, non-natural and non-organic ingredients.” Among some of the allegedly offending ingredients: benzyl nicotinate, ascorbic acid, stearalkonium chloride, phenoxyethanol, polysorbate 60, and cetrimonium chloride.
Mielle’s allegedly misleading marketing is not inconsequential, with natural ingredients being “material to [her] in making her decision to purchase” the products at issue. And beyond herself, Allen maintains that “consumers have been misled for years” by Mielle’s false advertising, “resulting in initial and repeat purchases of products they thought were indeed natural and that did not contain synthetically and chemically derived ingredients.”
The same goes for the company’s “Made in USA” claims, according to Allen, particularly as consumers “reasonably” relied on its marketing. Allen says her reliance on Mielle’s unqualified U.S. origin representations was reasonable, “as consumers are accustomed to seeing disclosures such as ‘Made in the USA with globally sourced ingredients’ or similar variations on product packaging – if and when such claims are made.” When consumers encounter an unqualified “Made in the USA” claim, “they reasonably assume that the product contains no foreign-sourced ingredients or components,” the complaint states.
Mielle’s representations as to the origin of its products were material to Allen and other consumers in making their decision to purchase the products at issue, as “consumers generally believe that ‘Made in the USA’ products are of higher quality than their counterparts that are made with foreign components.”
In short: Allen and similarly situated consumers believed and relied on Mielle’s allegedly erroneous claims about the nature and source of its products – with the claims being visible on major retailers’ platforms like Amazon and Target as of early 2025 – and paid more for the products than they would have had it not been for the alleged misrepresentations.
In addition to allegedly misrepresenting the origins and composition of the products, the suit asserts that Mielle makes unsubstantiated medical-style claims – suggesting that its Rosemary Mint Oil, for instance, increases blood circulation to the scalp, thereby promoting faster, thicker hair growth, and that it combats dandruff and supports scalp health through “over 30 essential oils and nutrients.” These statements, Allen argues, would classify the product as a drug under FDA standards – yet, Mielle has not obtained the requisite regulatory approval.
Allen is seeking certification of her proposed class action lawsuit, as well as monetary damages, restitution, and injunctive relief on behalf of a California-wide class of consumers. The complaint notably calls for an injunction barring Mielle Organics from using the challenged claims in future advertising and packaging without “clear and adequate qualification.”
THE BIGGER PICTURE: The lawsuit comes at a time when “Made in the USA” claims are under renewed consumer and regulatory scrutiny – particularly in the beauty and wellness industries, where country-of-origin can imply heightened safety, quality, and ethical manufacturing. The Federal Trade Commission has made it clear in cases across industries that such claims cannot be made lightly: unless all or virtually all ingredients or components are U.S.-sourced and processed domestically, companies are prohibited from using unqualified U.S. origin language.
The case also intersects with broader geopolitical and economic shifts, namely, the sweeping tariffs imposed – and subsequently halted (for the most part) – by the Trump Administration – a move that is expected to accelerate the nearshoring trend already gaining traction in CPG sectors. As nearshoring continues to gain momentum and regulatory frameworks tighten, brands making bold geographic claims may face more lawsuits like this one – or be forced to rework their labeling strategies altogether.
Mielle has not yet responded to the complaint.
The case is Allen v. Mielle Organics, LLC, 8:25-cv-00342 (C.D. Cal.).
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