A federal court in California has dismissed putative class claims that Hain Celestial Group, Inc. misleads consumers by labeling its Alba Botanica® cosmetics line with the word “natural.” Balser v. Hain Celestial Grp., Inc., No. 13-5604 (U.S. Dist. Ct., C.D. Cal., decided December 18, 2013). According to the court, “it is undisputed that ‘natural’ is a vague and ambiguous term.”
While the plaintiffs alleged that “natural” means “existing in or produced by nature; not artificial,” the court found their definition “implausible as applied to the products at issue: shampoos and lotions do not exist in nature, there are no shampoo trees, cosmetics are manufactured. Thus Plaintiffs cannot plausibly allege they were deceived to believe shampoo was ‘existing in or produced by nature.’”The court observed that the defendant actively defines what “natural” means on its Website by stating “We make natural, 100% vegetarian personal care products . . . . This means we don’t use parabens, sulfates, or phthalates.”The company also lists on its Website those ingredi- ents not used in its Alba Botanica® products, and its product labels “include an explanation explaining what natural ingredients are added, what ingredients are excluded and a complete list of all ingredients.”
In the court’s view, “Read as a whole, no reasonable consumer would be misled by the label ‘natural.’” Because the complaint’s defects could not be cured by amendment, the court dismissed it with prejudice.