Audit Phase: V-ECON
Target: Heinz / The Kraft Heinz Company (NASDAQ: KHC)
Audit Date: 2026-05-01
Kraft Heinz is one of the world’s largest processed food and condiment manufacturers, with tomato-based products (ketchup, paste, sauces) forming a core product pillar. The primary Israeli-relevant input categories where sourcing exposure could theoretically arise include tomatoes and tomato paste, paprika, specialty produce, and preserved goods. No verified, named contractual relationship between Kraft Heinz and specifically identified Israeli agricultural exporters — including Mehadrin, Hadiklaim, Galilee Export, or any documented successor to the former Agrexco state-backed export enterprise — has been identified in publicly available corporate disclosures, SEC filings, ESG reports, or trade press as of the audit date.14
Heinz’s tomato supply chain is documented primarily through procurement from California (USA), Portugal, Italy, Spain, China, and Turkey. Israeli tomato paste is not identified in Heinz’s publicly disclosed procurement records or supplier lists.1 No public evidence has been identified of Kraft Heinz directly procuring Medjool dates, avocados, citrus, fresh herbs, or potatoes from Israeli or West Bank-origin suppliers for use in branded products.520
Agrexco, the Israeli state-backed agricultural exporter, ceased operations and entered liquidation in 2011. Its successor entities — including Mehadrin Export and CAL Cargo Air Lines (logistics) — have not been documented in connection with Kraft Heinz procurement in any available public record.5
Kraft Heinz operates a decentralised regional subsidiary structure. In the UK and EU, it operates through Kraft Heinz Foods Company (UK) Ltd and related entities registered with Companies House.17 No public evidence has been identified of a dedicated wholly-owned subsidiary or joint venture established specifically as importer of record for Israeli-origin goods.117 No joint venture or dedicated import entity for Israeli-region sourcing has been identified.
No public evidence has been identified of recurring seasonal procurement from Israeli suppliers during counter-seasonal windows (December–April) or otherwise.
Kraft Heinz uses third-party ingredient brokers and commodity traders for various input materials globally. The use of such intermediaries could in principle obscure the ultimate geographic origin of commodity ingredients such as tomato paste or paprika. However, no public evidence directly links Kraft Heinz to Israeli-origin commodity procurement via third-party resellers.141520 This constitutes an evidence gap inherent to public disclosure norms for large FMCG companies rather than a confirmed finding in either direction.
No public NGO investigation — including those conducted by Who Profits Research Center, Corporate Occupation, or the American Friends Service Committee (AFSC) — and no regulatory citation, DEFRA/customs audit, or news report has been identified specifically documenting Kraft Heinz or Heinz-branded products as carrying “Produce of Israel” labelling on goods subsequently found to originate from the West Bank, Jordan Valley, or Golan Heights.5610
The UN Human Rights Council’s 2020 database of businesses with activities in Israeli settlements (commonly referred to as the “UN Blacklist”) does not include Kraft Heinz or any Kraft Heinz subsidiary.6 It should be noted, however, that this database was last substantially updated in 2020, meaning post-2020 commercial developments are not captured within its scope. Who Profits Research Center’s published database does not, based on available records, list Kraft Heinz as a profiling subject.5
No documented government enforcement actions, regulatory citations, or compliance proceedings against Kraft Heinz regarding country-of-origin labelling for settlement-produced goods have been identified in UK (DEFRA/Trading Standards), EU, or US regulatory records.1211 EU guidelines on the labelling of products from Israeli-occupied territories (2015, as updated) impose obligations on retailers and importers operating within the EU; no Kraft Heinz-specific non-compliance event has been documented under those guidelines.11
No public evidence has been identified of a specific, publicly stated Kraft Heinz corporate policy addressing the sourcing or labelling of goods from occupied or contested territories. Kraft Heinz’s published ESG and supplier code of conduct documentation addresses human rights in supply chains in general terms but does not reference occupied or contested territories specifically.4
No public evidence has been identified of Kraft Heinz direct capital investment in Israel or the occupied territories in the form of acquisitions, manufacturing facilities, data centres, logistics infrastructure, or real estate holdings. Kraft Heinz’s disclosed global manufacturing footprint — approximately 75–80 plants as of 2023 — does not include any facility identified as located in Israel.1 H.J. Heinz Company, the pre-merger predecessor entity, similarly does not appear in historical SEC filings as having Israeli operational investments.1
No public evidence has been identified of Kraft Heinz R&D facilities, technology partnerships, innovation labs, or accelerator programmes operating within Israel. Kraft Heinz’s disclosed innovation hubs are located primarily in the United States (Pittsburgh, PA; Chicago, IL), the Netherlands (Nijmegen), and Brazil.14 Israel operates a well-documented food-technology ecosystem (including entities such as Strauss Group and FoodTech IL initiatives), but no Kraft Heinz participation in Israeli food-tech accelerators or incubators has been identified in any public filing, press release, or investment disclosure.
Kraft Heinz’s two largest institutional shareholders are Berkshire Hathaway (Warren Buffett; approximately 26–27% stake as of 2023–2024) and 3G Capital (approximately 22–24% stake as of 2023).892
No public evidence has been identified of Kraft Heinz or its direct parent entities holding Israeli-domiciled company shares, Israeli sovereign bonds, or Israel-focused investment funds as disclosed portfolio holdings in SEC filings, annual reports, or proxy statements.12
Heinz-branded products (ketchup, condiment sauces, baked beans) are distributed and sold within the Israeli consumer market through local import and distribution partners.1819 No evidence has been identified of Kraft Heinz operating a wholly-owned sales office, warehouse, support centre, or retail location inside Israel or the occupied territories.18 The Israeli-market distribution structure appears consistent with Kraft Heinz’s documented approach in smaller international markets globally — namely, the use of third-party local import and distribution companies — though the specific identity and corporate structure of Kraft Heinz’s Israeli market distributor(s) has not been confirmed from publicly available records.18
No public evidence has been identified of Kraft Heinz directly employing staff in Israel or being registered as an employer with Israeli tax authorities.19 A distribution-model market presence, absent a directly employed Israeli workforce or locally incorporated operating subsidiary, would not typically generate direct Israeli payroll tax, corporate tax filing, or social insurance obligations for Kraft Heinz itself.
Israel does not appear as a named market in Kraft Heinz’s disclosed geographic segments in its SEC filings or investor presentations. Kraft Heinz reports geographic performance across two primary segments: North America and International (encompassing EMEA, Latin America, and Asia Pacific).116 Israeli market sales would be subsumed within the International/EMEA segment without separate disclosure, precluding any Israel-specific revenue, volume, or market share attribution from public records.16
H.J. Heinz Company was founded in 1869 in Sharpsburg, Pennsylvania, USA, by Henry John Heinz. It has no founding or incorporation history connected to Israel or any Israeli antecedent entity.1 Kraft Foods Group traces its origins to James L. Kraft (1903, Chicago, Illinois) and subsequent consolidations within the US food industry, with no Israeli-origin operations or brand identity.1 The Kraft Heinz Company was formed on 2 July 2015 through the merger of Kraft Foods Group and H.J. Heinz Company, orchestrated by 3G Capital and Berkshire Hathaway.9 No Israeli founding connection, origin-entity linkage, or Israeli incorporation feature is present at any structural level.
Kraft Heinz Company is incorporated in Delaware, USA, and maintains dual operational headquarters in Chicago, Illinois, and Pittsburgh, Pennsylvania.13 No Israeli domicile, legacy headquarters, or registered office in Israel has been identified.
No public evidence has been identified of Israeli state ownership stakes, Israeli government board appointees, Israeli government contracts, or any designation of Kraft Heinz as critical national infrastructure by any Israeli governmental body.19
No public evidence has been identified of golden shares, founder shares, charter restrictions, or other governance mechanisms structurally tying Kraft Heinz’s operations or mission to the Israeli state or its policy objectives. Kraft Heinz’s charter and governance documents reflect standard US public company governance under Delaware incorporation.2
Israel is not disclosed as a separate revenue market in Kraft Heinz’s SEC filings, investor materials, or segment reporting.116 Any Israeli market revenue is subsumed within the International/EMEA reporting segment. No Israel-specific revenue figure has been publicly disclosed, and no basis exists for estimating one from available public records.16
Given the distribution-model structure — with no identified Israeli subsidiary, manufacturing plant, or direct local workforce — profit flows associated with Israeli market sales follow a standard importer/distributor margin model. The Israeli local distributor would capture a local margin; Kraft Heinz would receive export revenue from an upstream international entity (UK, Netherlands, or US subsidiary acting as product exporter). Under this structure, profit does not appear to repatriate to Israel; the economic flow runs outward from Israel (local distributor to Kraft Heinz’s international subsidiaries) rather than inward. No evidence to the contrary has been identified.118
No public evidence has been identified of any Israeli government designation, industry report, or economic assessment characterising Kraft Heinz as a key employer, sector anchor, critical supplier, or infrastructure provider within the Israeli economy. Heinz is present in Israel as an imported consumer brand rather than as a domestic economic actor generating direct employment, capital formation, or tax base contribution within Israel.
https://www.sec.gov/cgi-bin/browse-edgar?action=getcompany&CIK=0001637459&type=10-K&dateb=&owner=include&count=40 ↩↩↩↩↩↩↩↩↩↩↩↩↩
https://www.sec.gov/cgi-bin/browse-edgar?action=getcompany&CIK=0001637459&type=DEF+14A&dateb=&owner=include&count=40 ↩↩↩↩
https://ir.kraftheinzcompany.com/overview/default.aspx ↩
https://www.ohchr.org/en/hr-bodies/hrc/regular-sessions/session46/list-of-issues ↩↩
https://unctad.org/system/files/official-document/tdb70d4_en.pdf ↩
https://www.sec.gov/cgi-bin/browse-edgar?action=getcompany&CIK=0001067983&type=10-K&dateb=&owner=include&count=40 ↩↩
https://www.wsj.com/articles/3g-capital-kraft-heinz-1490737201 ↩↩↩
https://investigate.afsc.org/ ↩
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:C:2015:375:TOC ↩↩
https://www.gov.uk/guidance/country-of-origin-labelling-for-food-and-food-products ↩
https://www.hadiklaim.com/ ↩
https://oec.world/en/profile/country/isr ↩
https://comtrade.un.org/ ↩
https://www.macrotrends.net/stocks/charts/KHC/kraft-heinz/revenue-by-segment ↩↩↩↩
https://find-and-update.company-information.service.gov.uk/ ↩↩
https://www.tase.co.il/en/market_data/security/1082855/company-profile ↩↩↩
