Film, colour and tubes, not tonnage, decide what state EPR charges Kraft Heinz, General Mills, Colgate-Palmolive, Kimberly-Clark and Walmart

What the five report, and what they leave out

Each company counts its packaging its own way, and the boundaries matter more than the percentages (Exhibit 1).

Kraft Heinz. The 2025 ESG Report, covering fiscal 2024, is still the latest; SPI found no 2026 ESG report by 29 October 2026, and the company said in that report that it would not set new time-bound targets because of the then-planned separation, which its Board paused on 11 February 2026 (SPI Buyers Database profile). The data table gives total packaging of 1,207,000, 1,116,000 and 1,067,000 tonnes for 2022 to 2024, and plastic of 293,000, 235,000 and 222,000 tonnes. By SPI’s calculation plastic was 20.8% of 2024 packaging weight. Recyclable, reusable or compostable packaging was 86%, against a goal of 100% by 2025, and recycled or renewable content was 22%. The report does not split the remaining 845,000 tonnes by material.

General Mills. Its release for the 2026 Global Responsibility Report, dated 15 April 2026, states that 95% of packaging was recyclable or reusable by weight. The packaging page describes packaging that is primarily fibre, with smaller amounts of plastic, steel and other materials, and, in a passage on store drop-off for plastic film, says items such as cereal bag liners and bar wrappers are not eligible for curbside pickup but can be recycled. SPI has not yet confirmed a tonnage or a material split for General Mills from the full report.

Colgate-Palmolive. The 2025 Sustainability & Social Impact Report gives 27% PCR plastic, up from 21% in 2024, a 32% cut in virgin plastic against 2019, 96% of packaging recyclable, reusable or compostable and 1.1% reusable or refillable by weight (pp. 10, 39 and 40). About 97% of North American toothpaste SKUs use its recyclable tube (p. 40). SPI has not yet confirmed a packaging tonnage in the report.

Kimberly-Clark. The 2025 Sustainability Report, published in June 2026, puts the plastics footprint 16% below 2019 against a 50% cut by 2030, and recycled content at 18% across plastic packaging against a 20% goal for 2025 (pp. 8 and 12). It gives no packaging tonnage and no recyclability figure. Its tissue joint venture with Suzano closed on 1 July 2026, with Kimberly-Clark keeping 49% (Form 10-Q, quarter to 30 June 2026), and North America stays with Kimberly-Clark.

Walmart. The FY2026 waste and circularity page, published on 29 July 2026, covers private brands only: 64.3% of global private-brand packaging recyclable, reusable or industrially compostable, 81.1% of private-brand plastic packaging designed for recycling, an estimated 12.0% PCR in North America private-brand plastic packaging, up from 8.2%, and virgin plastic 4.12% above FY2021. National brands on its shelves sit outside those numbers and, under state EPR, usually on their brand owners’ invoices.

Which state programmes send an invoice in 2027

SPI’s Regulation Tracker holds seven state packaging EPR laws (Exhibit 2). Only three have a 2027 price, and only two of those are final.

The calendars and the thresholds are set out in the US state EPR overview, so this piece uses only what changes the five companies’ bills. Three points matter.

First, California is the biggest market and the least settled price. CAA resubmitted its programme plan to CalRecycle on 13 October 2026 after a 60-day comment period that drew over 2,400 comments, and CalRecycle has 75 calendar days to respond, which by SPI’s calculation runs to 27 December 2026. CAA’s schedule says the 2027 rates are non-binding until then. The draft plan of 15 June 2026 projected a programme budget of up to USD 1.87 billion for 2027 (Packaging Dive, 16 June 2026).

Second, California’s plastic lines carry a second layer. Each plastic line has a base fee plus a reuse investment fee of 3 cents a pound of plastic component and a PPMF weight fee of 26 cents a pound, with a PPMF component fee of USD 0.001 per unit on top (CAA 2027 California schedule). CAA’s fee page forecasts that 49 cents of each 2027 dollar goes to the Plastic Pollution Mitigation Fund, the USD 500 million a year that SB 54 requires from July 2027 (PR-US-004).

Third, exemptions differ. Oregon exempts Bottle Bill beverage containers, drug packaging and infant formula packaging (Oregon DEQ summary), which matters for Walmart’s private-brand water. SPI has not yet confirmed how SB 54 treats CRV beverage containers from CalRecycle’s pages; those bottles are already subject to California’s AB 793 recycled-content rule, PR-US-009, at 25% from 2025.

The 2027 rate card for the formats these companies name

The five companies’ reports and SPI profiles name about a dozen US formats: Kraft Mayo’s recycled PET bottles, Heinz squeeze bottles, Oscar Mayer Deli Fresh trays and lids, cereal cartons, Progresso steel cans, cereal liners and bar wrappers, Colgate tubes, Fabuloso and Softsoap bottles, Hill’s bags, Huggies film packs, wipes tubs, Kleenex cartons and Walmart’s private-brand bottles, jugs, clamshells and shipping cases. Exhibit 3 gives the 2027 rate for the CAA category each would most likely report under.

Three patterns stand out. Oregon’s 2027 rates sit low because CAA is returning about USD 80 million of programme reserves through reduced rates, which is why natural HDPE bottles carry a credit and glass is free; the base column before drawdowns is higher on every line, as SPI’s line-by-line reading shows. Colorado has no reserve cushion, so its film and laminate lines are the dearest of any state. And California is cheap on fibre, metal and glass, at 1 to 3 cents a pound, but dear on every plastic line once the add-ons are counted.

A framework: four fee profiles

SPI groups the five by where their state bill concentrates (Exhibit 4). The grouping comes from the formats each company names and the worked examples below, not from the companies’ own categories.

The profiles explain why a single national packaging metric hides the cost. General Mills’ 95% recyclable share and Kimberly-Clark’s 18% recycled content tell a reader nothing about Colorado’s 62-cent film line, which is where Kimberly-Clark’s money goes. The worked examples that follow apply the same method to each company in turn.

Method for the worked examples

Each example takes an illustrative 1,000 tonnes supplied into a state, split across the formats the company names, and prices it on that state’s 2027 schedule. The splits are SPI assumptions, chosen to reflect each company’s own description of its packaging, for example General Mills’ mainly fibre packaging and Kimberly-Clark’s film-based portfolio. They are not company data. The 1,000 tonnes is a unit for comparison, not an estimate of any company’s sales in any state. States are priced one at a time and never added; cells are rounded to whole dollars, so rows may not add exactly.

Kraft Heinz: rigid plastic in a mostly non-plastic portfolio

Kraft Heinz’s SPI profile names Heinz squeeze bottles and Oscar Mayer Deli Fresh trays and lids as covered packaging in Oregon, Colorado and California, and New Jersey’s rigid-container rule, PR-US-010, as a recycled-content duty. The ESG report describes the move of Kraft Mayo, Miracle Whip and NotMayo bottles to 100% recycled PET, about 14 million pounds of virgin plastic, and a new peel and reseal Deli Fresh lid worth 1.8 million pounds.

Plastic is 55% of the weight in this mix and 89.0% of the Oregon bill, 73.6% of Colorado’s and 95.9% of California’s, by SPI’s calculation. The recycled PET move does not change any of these lines, because none of the three schedules prints a recycled-content discount in its passive columns. Colorado’s active incentives for recycled content are claimed separately through CAA’s portal, and SPI has not yet confirmed their 2027 values.

General Mills: fibre-heavy, with a costly last 5%

General Mills’ SPI profile names cereal cartons, Progresso steel cans, film liners and Blue Buffalo pet food bags as covered materials in the three states, and California’s SB 343 labelling rule, PR-US-011, as a test for film that relies on store drop-off, though its enforcement has been enjoined since 14 July 2026.

Colorado is the exception for a fibre-led portfolio. Its paperboard line is 9 cents a pound, against 5 cents in Oregon and 2 cents in California, so paperboard alone costs USD 109,129 there on SPI’s mix, more than the whole film line. That reflects Colorado’s statute, which ties dues to 100% of net recycling costs, rather than anything General Mills could design out. The paper and board piece shows how differently European schemes price the same fibre.

Colgate-Palmolive: tubes, colour and pouches

Colgate-Palmolive’s SPI profile names toothpaste tubes, Fabuloso bottles and Hill’s bags in the three states, and Softsoap and Fabuloso bottles under New Jersey’s rigid-container rule, PR-US-010, which steps from 10% recycled content to 20% in 2027 for containers of 8 fluid ounces to 5 gallons (NJDEP FAQ).

The recyclable tube is a design success that the schedules do not yet reward. Colorado prices HDPE squeeze tubes at 69 cents a pound on its Additional Material List, against 27 cents for a pigmented HDPE bottle, so 15% of the weight carries 29.5% of the Colorado bill. Hill’s laminate bags carry 32.1% of the Oregon bill and 33.3% of Colorado’s. The company itself names Hill’s pet food film as hard to recycle, and its report says Hill’s is a founding partner of the U.S. Flexible Film Initiative (p. 40).

Kimberly-Clark: film is the bill

Kimberly-Clark’s SPI profile names Huggies film packs, wipes tubs and Kleenex cartons as covered materials, notes that Colorado dues started in January 2026, and adds New Jersey’s rule for plastic bags, which steps to 40% recycled content for plastic carryout bags in 2027 (NJDEP FAQ). SPI has not yet confirmed whether Kimberly-Clark’s film overwraps fall within New Jersey’s bag categories.

Film is 65.1% of the Oregon bill, 81.6% of Colorado’s and 82.8% of California’s on this mix. The spread between Oregon and Colorado comes almost entirely from that one line: Oregon’s film rate fell to 12 cents for 2027 after a reserve drawdown of 17 cents from a 29-cent base, while Colorado’s rose to 62 cents.

Walmart: producer for private brands and for the box

Walmart’s SPI profile treats it as the likely producer for Great Value, Equate and Member’s Mark under the three state laws, links its private-brand drinks bottles sold in California to AB 793, PR-US-009, and notes its How2Recycle claims under SB 343, PR-US-011. As a retailer that packs and ships online orders, it also carries the shipping packaging: Oregon’s law makes the packer and shipper of remote sales the producer of that packaging (Oregon DEQ summary), and Colorado’s uses the same test (PR-US-003).

Corrugated is 30% of the weight here but only 7.5% of the Oregon bill and 3.9% of California’s, by SPI’s calculation, because both states price consumer corrugated at 2 to 3 cents a pound. Oregon also sets transport corrugated that never reaches a consumer at zero. The big swing is the natural HDPE jug: a credit of USD 13,228 in Oregon against a charge of USD 72,752 in Colorado on the same 150 tonnes.

The same mix, one state: Colorado

Because Colorado has no reserve drawdown and final rates on every line, it is the cleanest single state for comparing the five profiles (Exhibit 10).

Kraft Heinz comes out lowest in Colorado despite the most rigid plastic, because Colorado prices clear PET bottles at 18 cents and PP bottles at 21 cents, below its film and laminate lines. Colgate-Palmolive and Kimberly-Clark come out highest because tubes, laminates and film are the three dearest categories in the state. SPI analysis: in Colorado, a portfolio’s flexible and tube share predicts its per-tonne bill better than its plastic share does.

Scenario: what General Mills' last 5% is worth, state by state

Exhibit 11 takes General Mills’ illustrative mix and moves its 70 tonnes of laminate to mono-material HDPE/LDPE film, the kind of change a 100% recyclable goal implies.

The assumptions are deliberately simple: the same weight, no change in recycled content and no active incentive. A real switch might add weight for barrier performance, which would erode the Oregon gain. The point of the scenario is direction. Oregon’s 2027 schedule rewards the move strongly because it prices film at 12 cents a pound and laminate at 56 cents; Colorado rewards it modestly; California’s preliminary schedule prices the two lines a cent apart, so the plastic add-ons dominate and the switch saves nothing.

Reading the results: three cautions

The worked examples are built to compare formats, and three cautions keep them from being read as forecasts.

First, the weights are not the companies’. A company that sells 1% of its US volume into Oregon and 2% into Colorado will see bills in that ratio, not the ratio in Exhibits 5 to 9. SPI’s profiles record each company’s North American sales, but none of the five publishes Oregon, Colorado or California supply. Oregon DEQ says rates follow reported supply and change every year, so a producer’s own filings, not this article, are the basis for a budget.

Second, the mapping of packs to categories is a judgement. Colorado prints a squeeze tube line and Oregon and California do not; Heinz’s squeeze bottle polymer and Deli Fresh tray polymer are not stated in the 2025 ESG Report; and Hill’s bags may be laminate or mono-material by product. A different category can move a line by a factor of two or more, as the gap between Colorado’s 21-cent PP bottle line and its 78-cent laminate line shows.

Third, 2027 is an unusual year in Oregon. CAA describes the roughly USD 80 million reserve return as a 2027 measure, and the Oregon base column is higher than the final column on every line in Exhibit 3. On base rates, Kimberly-Clark’s illustrative film line alone would cost USD 287,703 in Oregon rather than USD 119,049, by SPI’s calculation at 29 cents a pound. The Oregon advantage in Exhibits 8 and 11 is therefore partly a timing effect, and the line-by-line fee piece sets out what a 2028 without the drawdown could look like.