Class Action Against Ulta Beauty Over 'Clean Ingredient' Claims Advances

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Top Class Actions reported on Oct. 28, 2025, that a nationwide class action was filed in California alleging Ulta Beauty's Conscious Beauty program includes products containing ingredients that are prohibited according to Ulta's own "made without" list.

Plaintiff Margaret Garvey claimed she purchased Ulta products believing they were clean and environmentally friendly, only to find they contained blacklisted ingredients — and had she known this, she would not have purchased the products.

Initially the suit was filed on July 15, 2025; as of October, it has progressed within the legal system with details concerning the allegations and specific ingredients. (See Pace Monitor for a step-by-step account.)

Conscious Beauty Program Purpose

Per Ulta's website, the Conscious Beauty at Ulta Beauty program is a way of empowering consumers with transparency and choices. "You'll be able to identify clean ingredients, cruelty free, vegan and sustainable packaging brands and products," the company states. The program is based on these four pillars plus a fifth: positive impact.

Products in the Conscious Beauty program do not necessarily need to meet the requirements for all five pillars, however. Eco Enclose explained, "Brands must meet the requirements of at least one pillar ... to be featured. Brands meeting all five pillars are highlighted under the 'Brands That Do It All' category." Those that are aligned with fewer pillars are labeled as such; e.g., "Clean Ingredients, "Cruelty Free," "Vegan," etc.

Clean Ingredient Pillar

According to Ulta, brands participating in the clean ingredient pillar "all formulate their hair, skin, makeup, body and fragrance products to the 'Made Without List' standards — which prohibit or limit the use of certain ingredients."

Products sold under the program, for example, must exclude acrylates, phthalates and parabens, and limit the use of aluminum compounds, talc (with Asbestiform), zinc oxide and other ingredients "in accordance with the corresponding restricted limits, grade requirements and/or regulated standards."

The products Garvey purchased, according to the court filing, included the following; notably, all are highlighted on Ulta's site (as of Oct. 29, 2025) for "Clean Ingredients." (See the table beginning on Page 53 of the court document for the full list of products alleged to contain prohibited ingredients).

  • Ulta Beauty Dermalogica - MultiVitamin Power Recovery Mask: cited for PEG-100 Stearate, Sodium Polyacrylate, Polysorbate 20, Propylene Glycol and Phenoxyethanol;
  • Drunk Elephant - A-Passioni Retinol Cream: cited for phenoxyethanol, ceteareth-20, laureth-23, steareth-20, polysorbate 20 and phenoxyethanol;
  • L'Oréal - Revitalift Triple Power Anti-Aging Face Moisturizer: flagged for aluminum starch octenylsuccinate, polyethylene, phenoxyethanol, PEG-100 stearate, laureth-7, PEG-30 dipolyhydroxystearate and ceteareth-6;
  • Ulta Beauty Collection - Apple Cider Vinegar & Kaolin Clay Mask: for polysorbate 20, PEG-100 stearate and phenoxyethanol; and
  • Ulta Beauty Collection - Tinted Self Tan Mousse: called out for propylene glycol, PEG-6 caprylic/capric glycerides, dihydroxypropyl PEG-5 linoleammonium, chloride, PEG-7 glyceryl cocoate and phenoxyethanol. 

The class action alleges violations of California’s Consumer Legal Remedies Act, False Advertising Law, Unfair Competition Law and Environmental Marketing Claims Act. It also alleges fraud, negligent misrepresentation and unjust enrichment. According to Truth in Advertising, the lawsuit is still pending.

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