A new class action complaint accuses Ulta Beauty of “greenwashing” its flagship “Conscious Beauty® at Ulta Beauty®” program by marketing thousands of products as “clean” and compliant with its “Made Without List™” while allegedly selling items that still contain ingredients the retailer promised to exclude. The lawsuit argues that shoppers paid a premium for products they believed were formulated without certain health and environment‑linked chemicals, and are now seeking damages and changes to how Ulta Beauty markets “clean” and “conscious” products.
What the Lawsuit Alleges
The complaint, filed in July 2025 in the U.S. District Court for the Northern District of California, is brought by Margaret Peggi Louise Garvey, a California shopper suing on behalf of a proposed nationwide class. She claims Ulta Beauty misled consumers by certifying products as part of “Conscious Beauty® at Ulta Beauty®” and advertising them as made with “Clean Ingredients” that exclude anything on its “Made Without List™”, even though many of those products allegedly contain prohibited ingredients.
According to the filing, Garvey purchased multiple “Conscious Beauty” items on February/25/2025, from an Ulta Beauty store in Novato, California, including products from Dermalogica, Drunk Elephant, L’Oréal, and Ulta Beauty Collection, because she believed they were clean and free from ingredients linked to adverse health or environmental impacts. She says she would not have bought them, or would have paid less, if she had known they allegedly contained ingredients that appear on Ulta Beauty’s own exclusion list.
Inside Ulta’s “Conscious Beauty” and “Made Without List™”
Ulta Beauty launched “Conscious Beauty® at Ulta Beauty®” in October 2020 as what it called a first‑of‑its‑kind initiative to give guests more transparency and help them make “conscious” product choices. The program is built around five pillars — clean ingredients, cruelty-free, vegan, sustainable packaging, and positive impact — and spans categories from makeup and skin care to hair, body, fragrance, and nails.
Under the Clean Ingredients pillar, Ulta Beauty says brands certify that they comply with the retailer’s “Made Without List™”, a set of ingredient standards described as considering human and environmental health impacts. Archived versions of the list show that “clean” products were supposed to exclude categories like acrylates, alkylphenols and alkylphenol ethoxylates, aluminum compounds and aluminum salts, phthalates, sodium laureth sulfate (SLES), sodium lauryl sulfate (SLS), styrene and styrene oxide, and previously ethoxylated ingredients including PEGs and polysorbates.
The lawsuit notes that after Garvey sent a statutory notice letter, Ulta Beauty moved ethoxylated ingredients such as PEGs from the “Made Without List™” to a “limited use” category, saying they could be used within certain restrictions. Plaintiffs argue this shift highlights how fluid the standards can be, even as the retailer continues to promote Conscious Beauty as a simple shortcut for shoppers who want “truly” clean options.
Why Plaintiffs Call It Greenwashing
The complaint frames the case as a textbook example of “greenwashing,” where marketing overstates the environmental or safety profile of products to capture demand for “clean” and “eco‑friendly” beauty. It cites research showing that large shares of consumers across generations are willing to pay more for sustainable products and prioritize health, safety, and products free from certain chemicals when making purchase decisions.
Plaintiffs argue that by using seals, in‑store signage, and website messaging to assure shoppers that Conscious Beauty items are formulated without ingredients commonly associated with adverse health and environmental effects, Ulta Beauty created the impression of broad, substantiated benefits. The lawsuit points to Federal Trade Commission “Green Guides,” which warn that general environmental benefit claims can be deceptive if they suggest extensive or impact‑free benefits that marketers cannot fully substantiate.
Alleged Consumer Harm and Legal Claims
The proposed class says it paid a price premium for Ulta Beauty products labeled as “Conscious Beauty” and “Clean Ingredients” versus comparable items that did not carry those assurances. According to the complaint, the injury equals the full purchase price or the premium paid because the products allegedly were not as advertised on their “clean” and “made without” attributes.
The suit asserts multiple causes of action under California law, including the Consumer Legal Remedies Act, False Advertising Law, Unfair Competition Law, the Environmental Marketing Claims Act, plus common‑law fraud, negligent misrepresentation, and unjust enrichment. The filing also seeks a jury trial, damages, restitution, and injunctive relief that would bar Ulta Beauty from marketing products as compliant with the “Made Without List™” if they contain excluded ingredients or if standards are not clearly and consistently defined.
