Regulatory Background: FTC Green Guides and Product Marketing Central to the case is the Federal Trade Commission’s (FTC) Green Guides, which caution that unqualified degradable claims for items customarily disposed of in landfills, incinerators, or recycling facilities are deceptive, since these environments do not provide conditions for complete decomposition within one year.

The lawsuit cites the FTC guidance to support the argument that Revlon’s marketing is misleading. The complaint maintains that had consumers known the pads and towelettes would not decompose in typical disposal environments, they either would not have bought the products, or would not have paid a premium for them.

Consumer Impact and Alleged Deceptive Practices The proposed class in the lawsuit consists of all California residents who purchased the identified Revlon makeup remover pads or towelettes marked as biodegradable during the relevant statute of limitations period.

Plaintiffs argue Revlon should have known its claims did not accurately reflect how the products behave in real-world disposal scenarios and, by omitting important context, misled environmentally conscious shoppers. The case asserts that…