John Paul Mitchell Systems, maker of the iconic Paul Mitchell and Tea Tree hair care lines, is facing a proposed class action lawsuit from consumers in Illinois and California who allege the company systematically misled them by labeling shampoos, conditioners, and styling products as “Made in the USA” despite the use of key foreign-sourced ingredients. The case, Lauer et al. v. John Paul Mitchell Systems (1:25-cv-02438), filed March 7, 2025, brings fresh scrutiny to how brands communicate product origins in a global supply chain.
Lawsuit Details: What Products and Claims Are Involved
According to court filings, Paul Mitchell’s best-sellers—including Tea Tree Lavender Mint Moisturizing Shampoo and Conditioner, Tea Tree Special Shampoo and Invigorating Conditioner, Tea Tree Lemon Sage Thickening Shampoo and Conditioner, and Tea Tree Grooming Pomade—are all marketed as “Made in the USA.” Yet, lead plaintiffs allege these products contain prominent ingredients like tea tree oil, jojoba, agave, and shea butter, none of which originate from the United States.
The lawsuit extends beyond Tea Tree: JPMS’s MITCH men’s hair care line is also targeted for using imported inputs but carrying the “Made in USA” claim. Plaintiffs say they purchased these items expecting exclusively domestic sourcing and manufacturing, paying a premium for what they believed to be U.S.-made products.
Legal Standards and FTC Guidance
Central to the dispute are regulations enforced by the Federal Trade Commission (FTC). The FTC requires that marketers ensure products labeled “Made in USA” are “all or virtually all” made from U.S.-sourced and U.S.-manufactured components. If not, clear disclaimers or qualifiers must be provided. The class action alleges JPMS failed to disclose its use of foreign inputs, violating both FTC rules and state consumer protection laws
State laws reinforce these expectations. California’s Business & Professions Code §17533.7 explicitly prohibits U.S. origin claims unless the product complies with strict sourcing standards, seeking to protect consumers from being misled when they purchase products in the belief that they are advancing the interests of the United States and its industries and workers.
Consumer Impact and Complaint Allegations
Plaintiffs argue that, “Given its expansive resources and operational sophistication, it is difficult to understand why JPMS so clearly violated the well-established laws, rules, and regulations surrounding the use of ‘Made in the USA’ or any derivative thereof, other than to deceive consumers and for its own personal financial gain.” Many buyers believe American-made products offer higher quality, and the supposed misrepresentation led them to pay more than they otherwise would have.
Market and Legal Trends: An Industry Reckoning
The Paul Mitchell case is one in a wave of class actions against CPG and beauty brands whose “Made in USA” and origin claims are being questioned in light of global supply practices. Legal analysts emphasize it is crucial for companies to audit their labels and advertising, reviewing both ingredient sourcing and messaging, to avoid legal exposure and consumer backlash.
The outcome of Lauer et al. v. John Paul Mitchell Systems may set new precedents on “Made in USA” standards for the beauty sector, highlighting the importance of transparency, accurate disclosures, and full compliance with FTC and state-level regulations.
