Angela Diesch is a Partner in the firm’s Litigation and Regulatory practices. She counsels companies in the cosmetics, over-the-counter drug, and medical device industries on all aspects of regulatory compliance, product development, labelling, and marketing. Angela is particularly recognized for her expertise in the “natural” and “organic” sectors, helping clients responsibly launch innovative products that comply with FDA, FTC, and other federal and state regulations. 

Angela supports clients throughout the entire product lifecycle—from classification and formulation to labelling, claims substantiation, and quality systems. She frequently drafts and negotiates research and development, manufacturing, supply, and quality agreements, and assists clients in building effective SOPs and compliance programs under current Good Manufacturing Practice (cGMP) standards. She also assists clients with tracking and complying with states’ Extended Producer Responsibility rules and reporting.

As both a seasoned litigator and regulatory advisor, Angela represents companies in investigations and enforcement actions brought by the FDA, FTC, NAD, USDA NOP, state attorneys general and district attorneys, as well as private litigants. Angela’s practical, strategic guidance—grounded in her deep knowledge of the personal care industry—makes her an invaluable partner to clients, whether defending them in private litigation and class actions or responding to 483 observations, Warning Letters, and civil investigative demands.

As a recognized leader deeply committed to advancing the personal care industry, Angela plays a pivotal role in shaping industry standards through her leadership through NSF International. She chairs NSF’s Joint Committees on Organic Personal Care (NSF/ANSI 305), Good Manufacturing Practices for Cosmetics (NSF/ANSI 455-3) and OTC Drugs (NSF/ANSI 455-4), as well as NSF Guideline 527, Contents and Claims Certified for Cosmetics, and the new Joint Committee on Homeopathic Drugs. Through this work, Angela has been instrumental in helping to develop key auditing and certification standards that promote product integrity, consumer trust, and regulatory compliance. She is also the founding author of CosmeticsAndTheLaw.com and a frequent speaker at national industry conferences and client training programs.

Representative Experience

  •  Prepared, submitted, and continue managing cosmetics listings to the FDA for multiple cosmetic companies.
  • Prepared, submitted, and continue to manage labeler code requests and drug listings with the FDA for multiple domestic and international companies.
  • Act as U.S. Agent for multiple foreign cosmetic and drug manufacturers.
  • Advise and manage client reporting obligations under various states’ Extended Producer Responsibility rules.
  • Assist in the evaluation in determining recyclability of product packaging and compliance with California’s SB 343, Truth
  • Assisted international online retailer with developing procedures for vendor vetting and regulatory compliance for its expansion into selling cosmetics and personal care products.
  • Assisted cosmetic brand with $1.6M recall, including negotiating resolution with their third-party manufacturer for manufacturing defects arising from their failure to comply with good manufacturing practices.
  • Defended organic producer in class action alleging unfair competition claim regarding use of organic claims on labelling
  • Defended large cosmetic company against competitor alleging state unfair competition claims and Lanham Act claims regarding use of the phrase "100% organic"
  • Review product labelling for multiple large and small cosmetic companies for compliance with state & federal rules & regulations and claim substantiation.
  • Advise & counsel regarding marketing claims such as "organic," “natural,” “sustainable,” "Made in USA," "recyclable," and anti-aging claims.
  • Represent organic growers in appeals to, and mediation with, the California Dept. of Food and Agriculture and the USDA National Organic Program.
  • Conduct reviews of ingredients, formulations, and safety substantiation.
  • Defending multiple cosmetic brands from challenges to their labeling and advertising claims as implied drug claims 
  • Defending multiple cosmetics manufacturers in putative class action lawsuits regarding various “natural” claims on cosmetic products. 
  • Defended cosmetic manufacturer against deceptive business practices and false advertising claims regarding “all natural” claim on cosmetic products. Successfully negotiated a settlement for nationwide class relief that involved injunctive relief to the class with minimal payment of attorneys’ fees. 
  • Defended multiple cosmetics brands and dietary supplement companies against UCL claims involving "Made in the USA" claims. 
  • Defended organic producer in class action alleging unfair competition claim regarding use of organic claims on labeling. 
  • Represented large California based organic citrus grower against a challenge by its certifier to revoke its organic registration.
  • Defended large cosmetic company against competitor alleging unfair competition claims and Lanham Act claims regarding use of the phrase “100% organic.” 
  • Reviewed product labeling for multiple large and small cosmetic companies for compliance with Food & Drug Administration (FDA) regulations and U.S. Department of Agriculture’s (USDA) organic laws, and provided advice regarding “natural,” “sustainable,” and anti-aging claims on packaging. 
  • Advised multiple cosmetic companies regarding transitioning from cosmetic to OTC drug manufacturing and labeling. 
  • Represented organic growers before the California Department of Food and Agriculture (CDFA). 
  • Represented organic growers in dispute between grower and third-party certifier 
  • Defended multiple cosmetics companies against alleged slack-fill violations brought by individuals and California district attorneys. 
  • Defeated racial discrimination and harassment claims in litigation against a meat packing facility.
  • Defended wage and hour class action lawsuit against major telecom provider.
  • Drafted employee handbooks and company policies for multiple employers in California.
  • Represented multiple domestic worker referral agencies against EDD, Worker’s Comp, and DOJ Labor claims.
  • Drafted contracts and terms for domestic worker referral agencies, and advised one such company in the development of their app for care providers and care seekers.

Honors & Awards

  • Global Retailers and Manufacturers Alliance (GRMA), 2023 Ambassador of the Year
  • Super Lawyers' “Rising Stars” 2016, 2017, 2018

Publications and Speeches

PUBLICATIONS

SPEECHES

  • Panelist, Independent Beauty Association’s Cosmetic Technical Regulatory Forum – Convergence, US Cosmetics Safety Substantiation: Obligations To Prove Products Are Safe — Before the Regulators Ask, Fall 2025
  • Speaker, Society of Cosmetic Chemists, Regulatory Fundamentals in the U.S., November 2025
  • Speaker, Global Retailer and Manufacturers Alliance Annual Summit, “Regulatory Trends and Enforcement Issues,” December 2024.
  • Speaker, Society of Cosmetics Chemists California Chapter, Suppliers’ Day 2023, “Regulatory Updates
  • Speaker, Independent Beauty Association’s Cosmetic Technical Regulatory Forum, “What Does a Global Label Look Like,” Fall 2023
  • Webinar Instructor, hosted by Global Victoria and AUS Trade, “Part 1: MoCRA and Extended Producer Responsibility Rules in the US, and Other Key Updates,” 2023
  • Webinar Instructor, hosted by Global Victoria and AUS Trade, “Part 2: US Cosmetic Compliance Requirements: How to use the new FDA electronic submission portal,” 2024.
  • Speaker, ChiWip, “What is MoCRA? A Panel Discussion of the Modernization of Cosmetics Regulation Act”, November 2023
  • Speaker, PCPC Legal & Regulatory Conference, Quebec, Canada, May 2023
  • Co-Chair, ACI West Coast Edition, Annual Legal, Regulatory, and Compliance Forum on Cosmetics & Personal Care, April 2023
    • Workshop Instructor, Workshop B – MoCRA Compliance Working Group: A Practical and Tactical Guide to the Modernization of Cosmetics Regulation Act of 2022 (MoCRA)
    • Panelist, MoCRA Status Report: The Modernization of Cosmetics Regulation Act of 2022 and Industry’s Response
  • Speaker, PCPC Leadership Summit, State of the States,” September 2022
  • Speaker, “Green and Clean Marketing Claims,” Ecovia Natural Cosmetics Masterclass, Jan. 2020
  • Speaker, “Convergence in Global Regulatory Requirements Across Industries,” Veeva Quality & Regulatory Global Summit 2019
  • Speaker, “Regulatory & Labeling Regime: Pitfalls and Best-Practices”, Ecovia Natural Cosmetics Masterclass, January 2019
  • Speaker, “Made in the USA with Some Slack Fill”, NOHBA Webinar, April 11, 2018
  • Speaker, “Natural Marketing Claims & Labeling: Pitfalls and Best-Practices”, Ecovia Sustainable Cosmetics Summit, May 2, 2017
  • Speaker, “Marketing Claims: Hot Topics from Regulatory Requirements to Litigation Avoidance”, World of Wipes, June 2017
  • Speaker, “Greenwashing: FDA/FTC Investigations on the Rise – How to Safeguard Your Company” at Natural Products Expo West, March 11, 2017
  • Speaker, ““Natural,” “Made in USA,” and Nonfunctional Slackfill: Minimizing Risks”, NSF International, Inc.’s Sacramento CA Dietary Supplements Conference, Oct. 12, 2016
  • Speaker, ”‘Natural’ Where are we at?”, Organic Monitor’s Green Materials Masterclass, San Francisco, January 29, 2016
  • Webinar presenter, “HAIR LOSS: Does the technology exist to really beat it?”, CosmeticsdesignUSA, December 10, 2015
  • Speaker, “Substantiated Cosmetic Claims: Clarifying the Hard Evidence,” IQPC Global Cosmetics Compliance, Amsterdam, June 9, 2015
  • Speaker, “Impending Regulations: CARB & The Personal Care Products Safety Act. Where We Are & How Should Brands Be Prepared” California Society of Cosmetic Chemists Dinner, May 26, 2015
  • Speaker, “An Overview of EDD and Workers’ Compensation Audits for Domestic Referral Agencies,” California Coalition of Domenstic Referral Agencies, October 11, 2014
  • Speaker, “2014 Legal & Regulatory Outlook for Green Marketing,” Sustainable Cosmetics Summit, May 16, 2014
  • Speaker, “Current Status of Natural and Organic Cosmetic Claims,” Personal Care Products Council (PCPC) Webinar, October 29, 2013
  • Speaker, “Green Marketing Claims & Labeling: Pitfalls and Best-Practices,” Sustainable Cosmetics Summit, May 17, 2013
  • Speaker, “It Does What? Prove it! – The Growing Importance of Claim Substantiation up the Supply Chain,” SupplySide Marketplace: SupplySide Why, May 2, 2013
  • Speaker, “Marketing Claims for Natural Personal Care Products,” Natural Cosmetics Masterclass: Green Formulations, Organic Monitor, San Francisco, CA, January 24, 2013
  • Speaker, “Labor & Employment Update,” A CAPA-tol Idea: Invest in Yourself, 23rd Annual CAPA Educational Conference, Sacramento, CA, June 23, 2012
  • Panelist, “Organic Personal Care: COPA’s Impact,” Natural Products Expo West, Anaheim, CA, March 9, 2012

Civic Involvement

  • NSF International, Chair of NSF’s Joint Committee on Good Manufacturing for Cosmetics (NSF/ANSI 455-3)
  • NSF International, Chair of NSF’s Joint Committee on Good Manufacturing for Over-the-Counter Drugs (NSF/ANSI 455-4)
  • NSF International, Chair of NSF’s Joint Committee on Organic for Personal Care (NSF/ANSI 305)
  • NSF International, Chair of NSF’s Joint Committee on Homeopathic Drugs
  • NSF International, Chair of NSF’s Guideline 527
  • Treasurer, Truckee Soccer Association, Inc. 2022-present (mini-booster supporting Truckee High Soccer)

Memberships and Affiliations

  • eWomen Network
  • Technical Regulatory Committee, Independent Beauty Association
  • Liasson Member, NSF International Council of Public Health Consultants (CPHC)

News, Events & Insights

Education

  • University of the Pacific, McGeorge School of Law, J.D.
  • University of California, Davis, B.A.

Previous Experience

  • Amin Wasserman Gurnani, LLP
  • Greenberg Traurig, LLP

Admissions

  • California 
  • U.S. District Court for the Eastern District of California 
  • U.S. District Court for the Northern District of California 
  • U.S. District Court for the Central District of California 
  • U.S. District Court for the Southern District of California 

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