Paul Mitchell “Made in the USA” Class Action Narrowed, but Consumer Fraud Claim Can Be Refiled

A federal judge in Chicago on December 4, 2025, partly dismissed a proposed class action over “Made in the USA” labels on John Paul Mitchell Systems hair care products, while giving the plaintiff a chance to refile his main claims, VitalLaw reported.

The case

In Lauer v. John Paul Mitchell Systems, No. 1:25-cv-02438 (N.D. Ill.), the plaintiff bought six Tea Tree line products labeled “Made in the USA” between August 2024 and February 2025. He alleges that tea tree oil, the line’s key ingredient, is native to Australia, and that jojoba seeds used in some products are not grown commercially in the USA. The complaint also targets more than 200 other products and cites the FTC rule that an unqualified claim requires “all or virtually all” ingredients to be made and sourced in the USA.

The ruling

• The plaintiff can pursue claims for products he did not buy for now. The court said that question belongs at class certification.
• The court found he adequately alleged damages by claiming he paid a price premium.
• The Illinois deceptive trade practices claim, which only allows an injunction, was dismissed with prejudice because he is now aware of the issue and cannot show future harm. A negligent misrepresentation claim was also dismissed with prejudice.
• The consumer fraud, unjust enrichment and intentional misrepresentation claims were dismissed without prejudice for lack of detail, with leave to amend by January 9, 2026.

“Uncertainty alone is a far cry from a concrete harm.”

The court’s opinion, as quoted by VitalLaw

Why it matters for Made in USA

Personal care products often contain ingredients that cannot be sourced in the USA, such as tea tree oil. For those products, an unqualified “Made in the USA” label is risky under the FTC rule. A qualified claim such as “Made in USA with imported ingredients” is safer.

The ruling also shows that courts will require plaintiffs to name which products contain which foreign ingredients.

FAQ

What is the Paul Mitchell lawsuit about?

It claims “Made in the USA” labels on Tea Tree products are false because tea tree oil comes from Australia.

Was the case dismissed?

Partly. Two claims were dismissed with prejudice, and the rest can be refiled with more detail.

What does the FTC require for Made in USA?

All or virtually all ingredients or components must be made and sourced in the USA.