Rael, Inc. told shoppers their panty liners were made with “100% Certified Organic Cotton from Texas” — a California court record shows those liners contained just 20% organically grown cotton.

This is the story of a company that built a premium brand around one of the most intimate and trust-dependent product categories in existence — feminine hygiene — and allegedly filled that brand with a lie printed directly on the box. The Environmental Democracy Project (EDP), a California nonprofit dedicated to protecting consumers from deceptive environmental claims, filed suit against Rael, Inc. to force the company to stop selling these products under false organic labeling claims in California.

What followed was a legal fight that reveals how corporations exploit regulatory gaps, how trial courts can get it completely wrong, and how a state appellate court can still hold the line. The California Court of Appeal reversed the lower court’s dismissal on November 26, 2025, ruling that California’s organic products law applies to every product sold as organic in the state — period products included.

The ruling is a win. But Rael’s products were on shelves the entire time the case wound through the courts, with packaging that a court record now describes as legally fraudulent.

What Rael Actually Put in Those Boxes

Rael marketed three specific products at the center of this case: organic cotton cover period underwear, organic cotton cover pads, and organic cotton cover panty liners. Each product carried prominent “organic” branding on its principal display panel — the front-facing label that shoppers read in the store aisle.

The court document describes the underwear as carrying advertising copy stating it is “made with certified Texas organic cotton” and a “100% Certified Organic Cotton Cover Sheet.” The pads were advertised as made with “plush organic cotton” and “Made With… organic cotton.” The panty liners were advertised as made with “100% certified organic cotton from Texas.”

California law requires a product to contain at least 95% certified organic materials to be sold as “organic,” and at least 70% certified organic materials to be sold as “made with organic” ingredients. EDP alleges all three Rael products fell below both thresholds. The panty liners, according to the complaint, contained just 20% organically grown cotton.

Beyond the raw percentages, EDP’s complaint identifies specific prohibited materials found in Rael’s products: Natural Wood Pulp Core with Super Absorbent Polymers, Polyethylene, Polypropylene, Elastics, and Waterproof Backing. These are not fringe ingredients; they are structural components of the products. Under both federal National Organic Program (NOP) standards and California’s COFFA law, nonagricultural and nonorganic materials that are not expressly permitted cannot appear in products marketed as organic.

Rael built a company identity around clean, organic, body-safe ingredients — particularly targeting consumers who were switching away from conventional period products out of health and environmental concerns. The gap between the brand promise and the alleged product reality is not a technicality. It is the entire business model of a product category built on trust.

The Non-Financial Ledger: What Money Doesn’t Measure

Period products are uniquely intimate consumer goods. Unlike a mislabeled bag of granola or a falsely advertised cleaning spray, the products at the center of this case are worn against the body’s most sensitive tissue for hours at a time, month after month, for decades of a person’s life. When someone chooses an “organic” pad or period underwear, they are making a deliberate health decision — often motivated by documented concerns about the synthetic chemicals, chlorine bleaching agents, and pesticide residues found in conventional period products. Rael’s alleged deception does not just pick their pockets. It reaches inside the decision they made about their own body.

The consumer who paid a premium for Rael’s panty liners — trusting that “100% Certified Organic Cotton from Texas” meant what it said — received a product that, according to the court filing, was only 20% organically grown cotton. The other 80% of that product’s composition is unaccounted for by the label they were shown. That consumer made a health-informed purchasing decision based on a claim that the appellate court record suggests was legally false. They cannot un-wear those products. They cannot reclaim the months or years of exposure. And they almost certainly did not know.

The power dynamic at work here is total. Rael controlled every word on every package. Rael’s marketing team chose the phrases “certified Texas organic cotton” and “100% Certified Organic Cotton Cover Sheet.” Rael’s design team put those words on the principal display panel — the most prominent face of the product — where shoppers make split-second trust decisions. The consumer had no independent means of verifying those claims without access to the supply chain documentation Rael alone possessed. This is the asymmetry that organic labeling law exists to correct: the producer knows exactly what is in the product; the buyer has only the label.

What this case also exposes is the emotional labor placed on consumers who are already trying to navigate a health decision. The organic feminine hygiene market exists precisely because a segment of the population has grown skeptical of conventional products and has decided to spend more — sometimes significantly more — to reduce their exposure to synthetic materials. Rael positioned itself as the answer to that skepticism. The company marketed directly to that health-conscious consumer, used the vocabulary of safety and purity, and allegedly delivered something far different from what was promised. The betrayal is structural: it exploits the very trust that motivated the purchase.

The non-financial cost accumulates invisibly. It lives in the confidence a consumer loses when they find out the brand they switched to was allegedly no cleaner than what they left behind. It lives in the unpaid time spent researching safer alternatives, the frustration of having to start over, and the corrosive realization that “organic” on a label can mean almost anything if companies face no real consequence for misusing it. That is the ledger that never appears in a settlement fund.

Legal Receipts: What the Court Record Actually Says

The following passages are drawn directly from the California Court of Appeal’s published opinion in Environmental Democracy Project v. Rael, Inc., filed November 26, 2025. These are the court’s own words and its summaries of the complaint.

Societal Impact: Who Pays When Labels Lie

The consumer who chooses organic period products is typically making a deliberate health calculation. A growing body of consumer health advocacy has raised concerns about synthetic materials, plastics, and chemical residues in conventional menstrual products — materials worn against mucous membrane tissue, which absorbs substances differently than external skin. Rael’s product line contained Polyethylene, Polypropylene, and Super Absorbent Polymers — synthetic petroleum-derived plastics — in products it labeled as organic. Consumers seeking to reduce their exposure to exactly these materials were, according to the court record, receiving them anyway.

The appellate court’s opinion explicitly names the breadth of this public health concern when it lists the categories of products that would fall outside organic labeling protections under Rael’s preferred legal theory: “Bug spray. Laundry detergent. Clothing. Body soap. Tobacco products. Even personal lubricants and condoms.” These are all products applied to or worn on the human body. The court found it legally absurd that guinea pig pellet manufacturers would face stricter organic labeling enforcement than manufacturers of products people wear against their skin every day.

The panty liner at the center of this case advertised “100% Certified Organic Cotton” coverage while allegedly containing only 20% organically grown cotton. For a consumer managing a condition like vulvodynia, endometriosis, or a chemical sensitivity — people who specifically seek fragrance-free, pesticide-free, minimally processed materials — that gap between label and reality is a health decision made on false information. The court record does not quantify how many consumers this affected. It does not need to. Rael sold these products statewide in California.

Organic feminine hygiene products carry a significant price premium over conventional alternatives. A consumer paying that premium is, by definition, spending more money specifically for the assurance the “organic” label provides. If that label is false — if the product contains less than 70% certified organic materials while advertising itself as organic — the consumer paid the premium price for a conventional product. That is money taken directly from people who were already making a sacrifice to afford a product they believed was safer.

Period poverty is a documented economic reality. Menstruating people in lower income brackets already face documented hardship affording period products at all. The organic premium market is, by nature, a market serving those with enough disposable income to prioritize label claims. But that does not make deceptive pricing acceptable — it makes it a targeted extraction. A consumer who stretched their grocery budget to buy Rael’s organic pads instead of conventional pads received, if the allegations hold, the conventional product at the organic price. The company captured the price difference. The consumer carried the loss.

The market incentive for this kind of mislabeling is stark. If a company can market a product as organic while sourcing and manufacturing it at conventional material costs, the premium it charges becomes almost pure margin. California’s organic labeling law exists specifically to prevent that extraction. The trial court’s original ruling — that the law did not even apply to period products — would have made that extraction permanently legal in an entire product category. The appellate court’s reversal closes that loophole, but only going forward. Every sale made before this ruling stands.

The Cost of a Lie: By the Numbers

What Now: Who Watches the Watchmen

The appellate court reversed the trial court’s dismissal and sent the case back to proceed. But a reversal at this stage means the underlying lawsuit — EDP’s claim that Rael violated California law — still has to be litigated. Rael has not admitted wrongdoing. No penalty has been assessed. No settlement has been paid. The court has only ruled that the law applies; it has not yet ruled on whether Rael broke it.

The Corporate Roles to Watch

• Rael, Inc. — the defendant; the company that manufactured and sold the three products at issue and has fought this lawsuit since 2022.
• Environmental Democracy Project (EDP) — the California nonprofit plaintiff that brought this suit and is pursuing the case on behalf of California consumers.

Regulatory Bodies with Jurisdiction

What You Can Do Right Now

File a complaint with the California Department of Public Health and the CDFA if you purchased any Rael product in California marketed as “organic” or “made with organic” materials. Document your purchase: keep your receipt, your packaging, and any advertising copy you saw. Share this story with anyone you know who buys organic period products — the premium they are paying may be for a promise the company does not keep.

Support organizations like the Environmental Democracy Project that bring these cases without the resources of a corporation behind them. This litigation exists because one nonprofit chose to fight a well-funded company through years of courts, not because any government regulator stepped in first. Mutual aid and direct support for consumer watchdog organizations is how the next Rael gets caught before it sells millions of mislabeled products.

Demand legislative clarity. The appellate court itself closed its opinion by inviting the California Legislature to clarify COFFA’s scope — specifically, the registration requirements and the calculation methodology for non-food organic products. Contact your California state assembly member and state senator and tell them you want the Legislature to act on the court’s invitation: tighten the registration requirements, close the labeling loopholes, and extend clear enforcement authority to all personal care products without ambiguity.