Key Takeaways:
The $8.1 billion “clean” beauty market has found itself in murky waters once again. On October 28, 2025, Ulta Beauty felt the brunt of the lack of US regulations surrounding “clean” beauty, facing a class action lawsuit in a similar case to Sephora’s saga of legal drama in 2024.
Plaintiff Margaret Garvey filed the complaint against Ulta Beauty in the US District Court of Northern California. The nationwide class action lawsuit alleges that Ulta Beauty (formerly known as Ulta Salon, Cosmetics & Fragrance Inc.) marketed products under its "Conscious Beauty” banner containing some of the ingredients that the retailer's own “Made Without List” promises to exclude, including acrylates, phthalates, and various aluminum compounds.
The legal claims span California’s Consumer Legal Remedies Act, its False Advertising Law, Unfair Competition Law, and the Environmental Marketing Claims Act, as well as common-law claims of fraud, negligent misrepresentation, and unjust enrichment. Garvey claims in the filing that she and other consumers have “suffered an injury in the amount of the purchase price and/or premium paid.”
An Ulta Beauty spokesperson told BeautyMatter in an email that the retailer is dedicated to Conscious Beauty, noting that transparency remains central to the program. The company said it aims to clearly communicate how products are formulated, packaged, and verified across its Conscious Beauty Pillars, allowing shoppers to make informed purchasing decisions. “We are proud of the progress we have made since launching Conscious Beauty five years ago and remain committed to furthering transparency and positive change in the beauty industry."
At first glance, the filing echoes the one leveled against Sephora in 2022, when plaintiffs accused the retailer of “greenwashing,” misleading shoppers with its Clean at Sephora seal. However, Ulta Beauty's case has an important distinction: It does not center on brand-specific packaging claims; rather, it targets the interface of a retailer-created certification system, a nuance that could have far-reaching implications for the entire clean-beauty ecosystem.
A Shifting Legal Landscape
In March 2024, it was considered a win for the industry when a federal judge dismissed the Sephora “clean” beauty case. The court ruled that Sephora had clearly outlined its program's criteria and had never made a promise that “Clean at Sephora” products were free of all synthetic or potentially harmful ingredients. As BeautyMatter wrote at the time, the ruling established an early precedent: Transparency, not purity, is what protects a retailer in court.
In regard to the Ulta Beauty case, a judge's dismissal may not be as easy to come by. While Sephora’s clean label was created in defined standards and disclosures (the court emphasized that the claimant did not plausibly allege that Sephora promised “no synthetic or harmful ingredients”), Ulta Beauty's “Made Without List” could be interpreted as a more absolute promise, declaring that certain ingredients were entirely excluded from named products.
In a broader context, the class action once again exposes a persistent industry-wide tension: The absence of a regulatory definition of “clean” beauty forces retailers to take the reins as the standard-setters. As a result, the likes of Sephora and Ulta Beauty are left to assume both marketing advantage and legal risk. What initially began as a consumer education tool has spiraled into a certification system that is coming under increasing scrutiny in court.
What “Clean” Means Now
Even if Ulta Beauty's case is dismissed as Sephora's was, it once again highlights the fragility of the clean-beauty movement's self-regulation model. The situation also raises the question: Has "clean" beauty lost its meaning? What started as a cry for transparency has become a greenwashing marketing ploy so ubiquitous that its credibility is wearing thin and eroding consumer trust. Without an approved regulatory framework, the term “clean” remains open to individual interpretation, and therefore legal challenge.
Even as Ulta Beauty defends its efforts for transparency, the surrounding terrain remains unclear as there is no regulatory definition of “clean” in beauty, meaning many claims rely on cherry-picked or inconsistent science rather than a standardized benchmark. For example, Ulta Beauty's own “Made Without” list flags ingredients such as phenoxyethanol, a preservative allowed in the US in the same concentration permitted in the EU. In calling out phenoxyethanol alongside other ingredients, Ulta Beauty is tapping into consumer anxieties, yet the regulatory record shows the ingredient has been assessed as safe for use at regulated levels of up to 1% concentration.
For Ulta Beauty, the case could be a reputational test of how seriously the retailer enforces its own standards. For the broader industry, it's yet another warning sign. As “clean” beauty continues to evolve from a trend to an expectation, the lines between marketing, compliance, and ethics are blurring. Going forward, “clean” must either mature into a rigorously defined standard or fade into another buzzword undone by its own popularity.
At press time, Plaintiff Margaret Garvey’s attorney declined to comment.
