The Northern District of California is the latest court to rule that a consumer product company does not have an obligation to affirmatively disclose information on packaging about supply chain labor practices. Plaintiffs in Hodsdon v. Mars, Inc. claimed that Mars had an obligation to state on the label that chocolate products like M&Ms, Snickers, and Milky Way may contain cocoa beans picked by child or forced labor, and that the omission of that information from the packaging violated California’s False Advertising Law (“FAL”), Unfair Competition Law (“UCL”), and Consumers Legal Remedies Act (“CLRA”). Plaintiffs argued that consumers were willing to pay more for ethically sourced chocolate and would not have purchased or paid as much for the chocolates had the labels included information about the suppliers’ labor practices. The court held that Mars had no duty to disclose this supply chain information and granted Mars’ motion to dismiss without leave to amend because amendment would be futile. In doing so, the court questioned whether the safe harbor doctrine might also bar the claims, but did not resolve the issue.