Environmental Democracy Project v. Rael, Inc.

Summary

The California Court of Appeal held that the California Organic Food and Farming Act applies broadly to all products sold as organic or represented as containing organic materials, including feminine hygiene products. The court reversed the trial court’s judgment on the pleadings for Rael, Inc., which had concluded that the statute did not cover personal care products. The appeal concerned the statutory scope of the Act, not the merits of the alleged labeling violations.

Holdings

1. COFFA applies to all products sold as organic or containing organic materials within its territorial scope, including personal care products and the feminine hygiene products alleged in the complaint.
2. COFFA adopts the multi-tier organic product-composition and labeling standards specified in the federal NOP regulations and applies those standards to all products governed by COFFA, not only products regulated under federal organic law.
3. The trial court erred by granting judgment on the pleadings on the ground that COFFA does not apply to feminine hygiene products.

Questions Presented

1. Whether COFFA applies to personal care products, including feminine hygiene products, that are sold, labeled, or advertised as organic or made with organic ingredients.
2. Whether COFFA incorporates the federal NOP product-composition and labeling standards for all products within COFFA's coverage, rather than only products subject to federal organic regulation.
3. Whether the trial court properly granted judgment on the pleadings based on its conclusion that COFFA did not apply to Rael's feminine hygiene products.

Disposition

reversed