National Legal and Policy Center (“NLPC”) urges shareholders of Mondelēz International, Inc. to vote FOR Item 4 on the 2026 Proxy Ballot, a shareholder proposal asking the Board to commission and publish an independent report evaluating the Company’s plastics packaging policies based on non-biased, scientifically accurate, and economically rigorous research.
In support of this shareholder proposal, NLPC has published an exempt solicitation report (PDF) to explain the need for this policy:
Mondelēz adopted sweeping plastics sustainability commitments in 2018 and 2021 — including making all packaging recyclable by 2025 and reducing virgin plastic use by up to 25 percent in rigid packaging by the same deadline. The Company has met none of them. Its own 2024 “Snacking Made Right” sustainability report reveals that recyclable packaging design stagnated at 96 percent for three straight years against a 98 percent target,¹ virgin rigid plastic use fell only 1.4 percent against a 25 percent goal,² and recycled plastic content reached just 1.6 percent against a 5 percent target.³ Within months of publishing these results, Mondelēz quietly departed the U.S. Plastics Pact — the very accountability framework it had joined to demonstrate commitment to these goals.⁴
These are not abstract shortfalls. They represent real costs that the Company has been absorbing — and passing on to consumers — in pursuit of activist-driven targets that had no rigorous scientific or economic foundation. Consider the timing: Mondelēz Chair and CEO Dirk Van de Put spent much of 2025 and early 2026 explaining to shareholders that volume declines, a 4.6 percent volume/mix drop in Q3 2025 alone, and a 14.6 percent decline in full-year adjusted EPS were the result of record cocoa inflation, weak consumer confidence, and macroeconomic headwinds.⁵ ⁶ These are real external pressures. But Van de Put has not similarly disclosed the self-inflicted costs of the Company’s plastics posture: EPR fees accumulating across seven states,⁷ recycled feedstock price premiums over virgin resin, and the compliance burden of coordinating across dozens of state and international regulatory frameworks — none of which the Company controls.
The scientific case for aggressive plastic reduction is also weaker than the advocacy literature suggests. A landmark 2024 peer-reviewed study in Environmental Science & Technology found that in 15 of 16 product categories, plastic products produce fewer lifecycle greenhouse gas emissions than alternatives.⁸ Meanwhile, a major January 2026 investigation by The Guardian found that numerous high-profile studies claiming to detect microplastics in human organs “have been thrown into doubt by scientists who say the discoveries are probably the result of contamination and false positives” — the very science advocacy groups have cited to pressure companies like Mondelēz.⁹
There is also legal exposure the Board has not addressed. A multistate coalition of attorneys general — growing from five states in October 2025 to ten in February 2026 — formally warned the companies associated with the U.S. Plastics Pact, the Consumer Goods Forum, and the Sustainable Packaging Coalition that coordinating uniform packaging standards across competitors may violate federal and state antitrust laws.¹⁰ Mondelēz was explicitly named among the nearly 80 corporate recipients.¹¹ The Board’s own opposition statement to NLPC’s proposal does not mention any of this.¹²
NLPC’s proposal asks for one thing: an honest, independent, quantifiable evaluation of whether these policies serve shareholders. The Board says it already conducts such analysis — but its opposition statement cites a single pro-packaging-industry source. Our full exempt solicitation report, available at the link below, cites 39 endnotes drawn almost entirely from peer-reviewed science, respected industry publications, and the Company’s own disclosures. We urge you to compare the two.
Please Vote FOR Item 4.
Download the Full ReportENDNOTES
- “Mondelez, General Mills, Cotopaxi Report Progress,” Resource Recycling, April 30, 2025. See https://resource-recycling.com/plastics/2025/04/30/mondelez-general-mills-cotopaxi-report-progress/
- Ibid.
- Ibid.
- Maria Rachal, “Nestlé, Mondelēz Leave the US Plastics Pact,” Food Dive, June 2, 2025. See https://www.fooddive.com/news/us-plastics-pact-member-departures-walmart-mondelez-mars-nestle/749468/
- Mondelēz International, Inc., “Mondelēz International Reports Q3 2025 Results,” October 28, 2025. See https://ir.mondelezinternational.com/news-releases/news-release-details/mondelez-international-reports-q3-2025-results
- Russell Redman, “Mondelēz Offers Cautious Guidance for 2026,” Food Business News, February 5, 2026. See https://www.foodbusinessnews.net/articles/29751-mondelez-offers-cautious-guidance-for-2026
- “Seven States and Counting: The 2025 Guide to EPR Packaging Compliance,” Proskauer Rose LLP, Oct. 13, 2025. See https://www.proskauer.com/alert/the-2025-guide-to-epr-packaging-compliance
- Fangyue Meng, Miguel Brandao, and Julian M. Cullen, “Replacing Plastics with Alternatives Is Worse for Greenhouse Gas Emissions in Most Cases,” Environmental Science & Technology 58(6), Jan. 30, 2024, pp. 2716-2724. See https://pubs.acs.org/doi/10.1021/acs.est.3c05191
- Damian Carrington, “‘A Bombshell’: Doubt Cast on Discovery of Microplastics Throughout Human Body,” The Guardian, January 13, 2026. See https://www.theguardian.com/environment/2026/jan/13/microplastics-human-body-doubt
- “Attorney General James Uthmeier Leads Multistate Coalition in Calling Out Radical Environmental Groups for Antitrust Violations,” Office of the Florida Attorney General, October 29, 2025. See https://www.myfloridalegal.com/newsrelease/attorney-general-james-uthmeier-leads-multistate-coalition-calling-out-radical
- “Attorney General James Uthmeier Leads Multi-State Coalition Putting Corporations on Notice Over Involvement with Anticompetitive Environmental Groups,” Office of the Florida Attorney General, February 10, 2026. See https://www.myfloridalegal.com/newsrelease/attorney-general-james-uthmeier-leads-multi-state-coalition-putting-corporations-notice
- “Notice of 2026 Annual Meeting of Shareholders and Annual Proxy Statement,” Mondelēz International, April 3, 2026, pp. 111-113. See https://www.sec.gov/Archives/edgar/data/1103982/000162828026023640/mdlz-20260403.htm
(Post references PX14A6G Notice of exempt solicitation)
