In 2018, Kroger announced its intent to phase out all single-use plastics shopping bags by 2025.¹ In March 2025, Kroger provided an update on the Company’s single-use plastics reduction goal. Kroger cited pandemic setbacks and local legislation as the Company’s reasons for failing to achieve its stated goal: “We originally aimed to achieve our bag-reduction goal in 2025; however, due to our current rate of progress, the high cost of all-paper bags to both our business and the planet, our customers’ feedback from multiple pilots across the country, and an anticipated slowdown in legislative action, we are extending our timeline for phasing out single-use plastic bags.”² The March 2025 single-use plastics update and Kroger’s 2025 Responsible Business Report failed to demonstrate how this goal was based on NPV and ROI.³ Sustainability goals ought to be evaluated in light of fiduciary duties to shareholders. Production of single-use plastics contributes to around 1.7% of global greenhouse gas (GHG) emissions.? Given that the complete elimination of single-use plastics from Kroger’s stores would have only an infinitesimal effect on global waste reduction, continued pursuit of this objective should be evaluated through the lens of ROI and opportunity cost.? The Company’s ongoing efforts to phase out single-use plastics apparently lack supporting financial data: 1. Innovation efforts for bag alternatives and other bag systems.? 2. Conducting multiple tests at Kroger-operated stores in different geographies “to test solutions, including bag incentives and fees, and listen to our customers’ feedback about the type of bags being provided…”? 3. Participation in the Consortium to Reinvent the Retail Bag’s Bring Your Own Bag pilots “to test whether consistent signs, marketing, and prompts could help customers build the habit of bringing their bags whenever they shop.”? 4. Kroger is expending resources on campaigns promoting reusable bags and higher-cost paper bag alternatives.? Kroger admitted that its efforts to phase out single-use plastics come at a high cost to the Company’s business. Kroger is delaying full implementation of its single-use plastics goal due to the significant financial burdens that accompany such a goal. Kroger can perform a cost-benefit analysis of the Company’s plastics goal and has the structural ability to adjust course. Kroger risks legal, reputational, and financial setbacks if the Company continues to expend resources toward achieving an outdated sustainability goal. “A company’s sustainability practices don’t count as noble if the company’s success and revenue have to suffer to make them a reality.”¹? For these reasons, we request that Kroger issue a report assessing the ROI and NPV of the Company’s single-use plastics reduction initiative.