$3.6 Million Unilever Dry Shampoo Settlement Aims to Resolve Lawsuit Over Alleged Benzene Contamination [UPDATE]
Last Updated on February 23, 2026
Little et al. v. Unilever United States, Inc.
Filed: September 21, 2022 ◆§ 3:22-cv-01189
A $3,625,000 settlement would resolve claims that Suave, TIGI, TRESemmé, Dove and Nexxus dry shampoos contained dangerous levels of benzene, a known human carcinogen.
Connecticut
February 18, 2026 — Benzene Settlement Update: Judge Asks Plaintiffs to Rework Proposed Class in Dry Shampoo Lawsuit
United States District Judge Michael P. Shea denied the plaintiffs’ motion for preliminary approval of the $3,600,000 Unilever settlement detailed on this page due to both the scope of the proposed settlement class and the length of the covered class period in the deal.
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In an 18-page ruling submitted on February 17, 2026, Judge Shea determined that the proposed settlement class would contain members who would lack Article III standing—effectively a personal stake in the outcome of the suit related to a concrete injury suffered with direct causation. Similarly, Judge Shea found that the proposed date range of the settlement class period “extends well beyond” the period of alleged benzene contamination determined by third-party laboratory testing.
Although the plaintiffs sought to represent a class comprised of all natural persons who, between January 1, 2014 and December 31, 2022, purchased in the U.S. any covered Unilever-brand dry shampoo, including Suave, TIGI, TRESemmé, Dove and Nexxus, Judge Shea pointed out several issues with the proposed class.
First, the judge determined that the start of the proposed class period, in January 2014, which was supposedly when the plaintiffs started making dry shampoo purchases, was illogical, considering the results of the third-party testing.
“[T]he class period cannot be defined by the date a particular plaintiff began purchasing a product unless there are allegations in the complaint, or evidence in the record, to suggest that the product was contaminated at that time,” the ruling reads. “Here, there are no allegations or evidence to suggest that the contamination extended as far back as January 1, 2014.”
As such, Judge Shea felt that the class action settlement would encompass class members and lead plaintiffs who lacked proper standing.
Cited heavily in Judge Shea’s ruling was John v. Whole Foods Market Group, a 2017 case that was ultimately dismissed by the Second Circuit Court of Appeals but set standards for the specific evidence of injury-in-fact necessary to establish standing in a class action lawsuit, particularly for claims reliant on third-party testing.
In John, the plaintiff alleged that he was short-changed by Whole Foods on his “monthly” purchases of prepackaged cheese and cupcakes based on a New York City Department of Consumer Affairs report that found the retailer routinely inflated the weight on its prepackaged food labels. The Second Circuit found that, as a result, it was plausible that the plaintiff had overpaid for a product based on the “frequency of his purchases and the systematic overcharging” done by Whole Foods.
Judge Shea noted that one named plaintiff in the case sufficiently alleged Article III standing based on the frequency of her purchase of products that were systemically afflicted, as demonstrated by independent testing, reiterated under John.
However, this was not the case for the other named plaintiffs, who Judge Shea said gave “no indication” of how many purchases they actually made. Instead, the judge found that they only alleged to have purchased a particular Unilever-branded dry shampoo, without factual specificity.
“Though I find that [Plaintiff Barnette] has standing to represent a settlement class, I cannot approve the proposed class because, as defined, it is impermissibly broad,” Judge Shea wrote. “That’s not to say that Barnette could not represent a narrower class defined in a manner that would allow for the Court’s certification.”
Judge Shea denied the motion without prejudice, meaning the plaintiffs will have the opportunity to rework their claims, and asked that they file a status report by March 3, 2026.
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The plaintiffs in a proposed class action lawsuit against Unilever have asked the court to preliminarily approve a $3,625,000 settlement to resolve claims that Suave, TIGI, TRESemmé, Dove and Nexxus dry shampoo products contained dangerous levels of benzene, a known human carcinogen.
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The proposed settlement looks to cover all individuals who, between January 1, 2014 and December 31, 2022 and while in the United States, purchased any Unilever dry shampoo products sold under the Suave, TIGI, TRESemmé, Dove or Nexxus brands for personal, family or household use and not resale.
If the Unilever dry shampoo settlement receives preliminary court approval, class members who submit a timely, valid claim form will be eligible to receive refunds for product purchases.
Eligible individuals can file a Unilever claim form by mail or online through the court-approved settlement website once it is established.
ClassAction.org will update this page if and when the official Unilever dry shampoo settlement website is launched.
Class members who submit a valid claim form with proof of purchase can receive a full refund for each covered dry shampoo they bought.
Those who file a claim without proof of purchase can receive $3 for each covered dry shampoo they bought. Class members without proof can receive refunds for up to four products per household.
If you submitted a claim in connection with Unilever’s October 2022 recall of Dove, Nexxus, Suave, TIGI and TRESemmé dry shampoos due to potential benzene contamination, your settlement payout will be reduced by the amount of cash or voucher payments you received from the recall reimbursement program.
All payments may be subject to a pro-rated increase or decrease depending on the total number of valid claims submitted.
Related Reading: Unilever Dry Shampoos Contain Known Human Carcinogen Benzene, Class Action Says
Notice of the deal will be emailed to eligible class members within 30 days of the settlement’s preliminary approval, court documents indicate.
The initial Unilever lawsuit was filed after independent laboratory testing found that the dry shampoos contained undisclosed benzene at levels significantly exceeding guidelines established by the U.S. Food and Drug Administration. According to the case, benzene exposure is known to cause leukemia and other cancers.
Two additional settling defendants include Unilever’s suppliers, Voyant Beauty, LLC and Aeropres Corporation.
Looking for current class action lawsuits to join? Check out ClassAction.org’s class action lawsuit list.
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