An Open Letter to the FDA, the Food Industry, and Every Brand Selling Avocado Oil
From Wayne Adams, CEO, Adams Group
I have spent my entire life in this industry, as did my father, his father, and the two generations before them. I know how supply chains work, how margins get squeezed, and how corners get cut. I also know that what’s happening in the bulk avocado oil category right now is not a gray area. For decades, companies have used the lack of a standard of identity to cheat the system, cutting pure product with less expensive seed oils for better margins under the assumption that consumers wouldn’t know any better. It is a systemic failure, and it’s time we called it what it is.
The 2026 UC Davis Study confirms what many of us have suspected for years: 93% of chips labeled “Made with Avocado Oil” were found to be adulterated. Mayonnaise fared no better — 71% failed the same promise but look closer at the U.S.-made data specifically, and that number climbs to 100%. Salad dressings were 100% adulterated, across the board. The FDA has repeatedly flagged avocado oil as one of the most frequent targets for economically motivated adulteration due to avocado oil being up to 5x the cost of seed oils. Class action lawsuits followed the 2020 study. And still, the products on shelves claiming 100% avocado oil continue to cheat.
Consumers are being lied to. Not misled. Not confused by labeling technicalities. Lied to. 100% pure avocado oil means one thing – the oil contained in the product is 100% pure avocado oil, not 90% or 50%.
At Adams Group, we have built our entire business on the belief that integrity is not a competitive advantage; it is a baseline obligation. In 2020, our retail brand, Marianne’s Avocado Oil, was one of only two brands that tested 100% pure in UC Davis’s first study on avocado oil purity. In 2026, Marianne’s Avocado Oil was the benchmark for 100% pure avocado oil. We are one of the largest purchasers of avocado oil worldwide, and we know the importance of purity. We were the first to bring Regenerative Organic Certified™ avocado oil to retail. We take purity to the next level. Most brands test only one CODEX marker, a threshold loose enough that oil can be adulterated up to 40% and still pass a single-marker test. We test all three: fatty acid profile, sterol composition, and tocopherol levels. The result: our bulk avocado oil is 100% pure. We third-party test every single load for purity, every single time. Not because it’s good marketing. Because it’s the right thing to do.
We are not writing this letter to celebrate our own track record. We are writing it because the problem is bigger than any one brand, and the solution has to be too.
To the FDA:
The avocado oil category needs enforceable standards, not just guidance. Economically motivated adulteration is not a niche concern. It is widespread, tested, documented, and ongoing.
We are calling on the FDA to adopt a formal Standard of Identity for avocado oil that enforces the full Codex Alimentarius purity standard across all three components: fatty acid profile, sterol composition, and tocopherol levels. Currently, many brands test only for fatty acids, which can be done in-house and are easy to manipulate. An adulterated product can contain up to 40% non-avocado oil and still pass a fatty acid test alone. Sterol and tocopherol testing requires third-party verification and is significantly harder to manipulate, which is exactly why it must be required, not optional.
A proper standard would require all three markers, third-party verified, every time.
Consumers deserve protection built for the realities of how adulteration actually happens, not a standard bad actors already know how to pass.
To our industry peers:
We know third-party testing costs money. We know that seed oils are roughly 1/4 the cost of avocado oil. We know that sourcing truly pure avocado oil at scale is hard. We know building direct farm relationships takes time. We’ve done all of it, and we’re asking you to do the same. But using the lack of a federal Standard of Identity as an excuse to look the other way is no longer acceptable. The class action law suits that followed the 2020 and 2023 UC Davis studies were a preview. What comes next will be harder to survive. Consumers are tired of being lied to for the sake of corporate profits. More importantly: your customers trusted you. That matters more than the margin.
To every brand selling avocado oil:
We are calling on you to take the Avocado Oil Purity Pledge: third-party test your products and demand the same of your suppliers. If your oil is pure, prove it. If you can’t prove it, work with a supplier that can.
The 2026 UC Davis Study is not a crisis for Marianne’s because we have always been 100% pure. Our margins have been smaller as a result, but our integrity is intact. It is a crisis for an industry that has allowed consumer trust to erode in silence.
Read the full 2026 UC Davis study and click on the media kit to see the full list of brands tested with results.