UNITED PARCEL SERVICE INCORPORATED

United Parcel Service Incorporated (NYSE: UPS; CIK 0001090727), the Tualatin, OR-registered affiliate under NAICS 492110, operates inside a corporate family that EPA has identified as a nationwide hazardous-waste generator. EPA ECHO records tied to this legal entity show 2 facilities, 2 violations in the trailing 24 months, and derived penalty exposure of $4.24 million [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. That narrow perimeter understates the parent company's actual compliance footprint by a wide margin. In October 2022, EPA announced a consent agreement resolving hazardous-waste violations across 1,160 UPS facilities in 45 states and Puerto Rico [source: https://www.epa.gov/newsreleases/ups-settles-epa-correct-alleged-hazardous-waste-violations-nationwide], and in June 2021 EPA Region 6 settled parallel allegations across 183 locations in Arkansas, Louisiana, Oklahoma, New Mexico and Texas for a $3.8 million civil penalty [source: https://www.epa.gov/enforcement/united-parcel-service-inc-ups-settlement].

State-level activity continued into 2025. On August 4, 2025, the Riverside County District Attorney announced that UPS and affiliates were ordered to pay $1.745 million in civil penalties, costs and supplemental environmental project funding to resolve allegations of unlawful disposal of hazardous and medical waste at California facilities [source: https://rivcoda.org/UPS_violation] [source: https://kesq.com/news/2025/08/04/united-parcel-service-and-affiliates-ordered-to-pay-1-7m-in-penalties-for-environmental-violations/]. UPS reported 2025 revenue of $88.7 billion and delivered 5.2 billion packages during the year [source: https://www.sec.gov/Archives/edgar/data/1090727/000162828026008432/ups-20251231.htm]. That scale matters for context. Against $88.7 billion in annual revenue, the three major enforcement actions together exceed $10 million in combined penalties — a figure the company's public sustainability materials do not aggregate or disclose. A shareholder proposal filed November 13, 2025 by As You Sow requests a third-party environmental justice audit, citing pollution exposure to overburdened communities as a material financial risk [source: https://www.asyousow.org/resolutions/2025/11/13-ups-third-party-environmental-justice-audit].

The EPA ECHO snapshot for this specific legal entity (slug united-parcel-service-incorporated, facility IDs 110004792653 and 110004803945) shows a narrow 2-facility perimeter with 2 quarters of noncompliance in the trailing 24 months and derived penalties of $4,240,000 over the five-year-scaled window [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The most recent permit action on file is dated September 28, 2017, and no active permits are recorded. The EJ index average across the two facilities reads 0.0 in the ECHO export — a value that reflects incomplete demographic overlay data rather than an affirmative finding of low community exposure.

The 24-month enforcement record for the broader UPS corporate family opens with the October 19, 2022 nationwide Consent Agreement and Final Order. Under that order, UPS agreed to resolve hazardous-waste regulatory violations — including failure to make land-disposal determinations and improper on-site management of hazardous waste — across 1,160 facilities in 45 states and Puerto Rico [source: https://www.epa.gov/newsreleases/ups-settles-epa-correct-alleged-hazardous-waste-violations-nationwide] [source: https://www.epa.gov/enforcement/consent-agreement-and-final-order-ups]. Law360 reported the total nationwide penalty at $5.3 million [source: https://www.law360.com/real-estate-authority/commercial/articles/1]. That 2022 order built directly on EPA Region 6's June 16, 2021 settlement, which required compliance upgrades across 183 UPS and TForce Freight locations in five states and imposed a $3.8 million civil penalty [source: https://www.epa.gov/enforcement/united-parcel-service-inc-ups-settlement] [source: https://www.epa.gov/sites/default/files/2021-06/documents/ups-cafo.pdf].

State-level enforcement resurfaced in mid-2025. On August 4, 2025, the Riverside County District Attorney announced a civil judgment under which UPS and affiliates were ordered to pay $1.745 million to resolve allegations of unlawful disposal of hazardous waste and medical waste at California facilities [source: https://rivcoda.org/UPS_violation]. KESQ reported the settlement resolved allegations tied to improper handling and disposal of regulated waste streams [source: https://kesq.com/news/2025/08/04/united-parcel-service-and-affiliates-ordered-to-pay-1-7m-in-penalties-for-environmental-violations/]. Two additional developments will reshape the compliance surface area going forward. Operational restructuring announced in February 2026 — closure of 22 union-staffed facilities and a scale-back of Amazon volume — will alter the inventory of RCRA-generator sites subject to the 2022 consent order [source: https://finance.yahoo.com/news/look-united-parcel-valuation-facility-021653820.html]. The Teamsters' February 2026 emergency motion against the Driver Choice Program adds a labor-relations dimension to that site consolidation plan [source: https://finance.yahoo.com/news/investors-reacting-united-parcel-ups-150809526.html]. UPS's Q3 2025 10-Q did not contain a materially expanded environmental contingency disclosure [source: https://www.sec.gov/Archives/edgar/data/1090727/000162828025049661/ups-20250930.htm].

Action 1 — Nationwide RCRA Consent Agreement and Final Order, announced October 19, 2022. Program: RCRA (hazardous waste). Facilities: 1,160 UPS locations across 45 states plus Puerto Rico. Cited conduct: failure to make land-disposal determinations; improper on-site hazardous-waste management. Outcome: EPA consent agreement with corrective compliance program; Law360 reported the penalty at $5.3 million [source: https://www.epa.gov/newsreleases/ups-settles-epa-correct-alleged-hazardous-waste-violations-nationwide] [source: https://www.epa.gov/enforcement/consent-agreement-and-final-order-ups] [source: https://www.law360.com/real-estate-authority/commercial/articles/1].

Action 2 — EPA Region 6 RCRA Settlement, announced June 16, 2021 (Docket No. RCRA-06-2021-0906). Program: RCRA. Respondents: United Parcel Service, Inc. and TForce Freight, Inc. Facilities: 183 locations in Arkansas, Louisiana, Oklahoma, New Mexico and Texas. The five-state geographic spread of this action — from Little Rock to Albuquerque — illustrates how RCRA compliance gaps at parcel-handling facilities can propagate across an entire regional distribution network. Outcome: 24-month compliance schedule and $3.8 million civil penalty [source: https://www.epa.gov/enforcement/united-parcel-service-inc-ups-settlement] [source: https://www.epa.gov/sites/default/files/2021-06/documents/ups-cafo.pdf].

Action 3 — Riverside County, California civil judgment, announced August 4, 2025. Program: California hazardous-waste and medical-waste disposal statutes. Respondents: United Parcel Service and affiliates, including UPS Supply Chain Solutions, Inc. The Riverside County District Attorney's office brought the action under California's environmental enforcement statutes, targeting disposal practices at facilities handling both conventional hazardous waste and regulated medical-waste streams. Outcome: $1.745 million in civil penalties, costs and supplemental environmental project funding [source: https://rivcoda.org/UPS_violation] [source: https://kesq.com/news/2025/08/04/united-parcel-service-and-affiliates-ordered-to-pay-1-7m-in-penalties-for-environmental-violations/].

For the narrow ECHO record keyed to the Tualatin-registered legal entity, the exporter-derived figures are 2 violations and $4.24 million in penalties over 24 months [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The aggregate UPS corporate family trailing-24-month penalty total, combining the peer ECHO rows, reaches roughly $22.8 million before state actions are layered in.

Facility 1 — ECHO ID 110004792653 (United Parcel Service Incorporated). This is one of two facilities mapped to the Tualatin-registered legal entity. ECHO records indicate it contributed to the 2-violation, $4.24 million derived-penalty footprint over the trailing 24 months, with no active permits on file and a most-recent permit action dated September 28, 2017 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Facility 2 — ECHO ID 110004803945 (United Parcel Service Incorporated). The second facility within this legal-entity perimeter also carries no active permits in ECHO. The EJ index average across both facilities reads 0.0, which reflects missing demographic overlay data rather than a substantive finding [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Facility 3 — Representative California location within the Riverside County enforcement. The August 4, 2025 civil judgment alleged unlawful disposal of hazardous and medical waste across UPS and affiliated operations in California. Named respondents included UPS Supply Chain Solutions, Inc. The $1.745 million ordered in penalties, costs and supplemental projects covered conduct at facilities handling regulated waste streams that include pharmaceutical returns and medical materials [source: https://rivcoda.org/UPS_violation].

Facility 4 — Representative EPA Region 6 location (Texas, Louisiana, Oklahoma, Arkansas and New Mexico). The June 16, 2021 consent agreement covered 183 UPS and TForce Freight sites across those five states, with cited RCRA deficiencies in hazardous-waste management. The San Antonio, TX facility at 7129 Eckhert Rd sits within that Region 6 compliance footprint [source: https://www.epa.gov/enforcement/united-parcel-service-inc-ups-settlement].

Facility 5 — San Antonio, TX location (7129 Eckhert Rd). Third-party directory records list this as a United Parcel Service Incorporated operational address [source: https://www.mapquest.com/us/texas/united-parcel-service-incorporated-304436734]; it sits within the EPA Region 6 compliance footprint addressed by the 2021 consent agreement [source: https://www.epa.gov/enforcement/united-parcel-service-inc-ups-settlement].

Pollutant 1 — Hazardous waste (RCRA Subtitle C regulated streams). EPA's 2022 nationwide order specifically cited failure to make land-disposal determinations and improper on-site management [source: https://www.epa.gov/newsreleases/ups-settles-epa-correct-alleged-hazardous-waste-violations-nationwide]. RCRA-regulated waste streams at parcel-handling facilities typically include damaged-package chemistries — corrosives, flammable liquids, lithium cells — and pharmaceutical returns. Improper land-disposal determinations create groundwater and soil-contamination pathways when waste is routed to non-hazardous streams. The 1,160-facility scope of the 2022 order signals that these classification failures were not isolated to a single region or operating unit.

Pollutant 2 — Medical waste and regulated pharmaceutical returns. The Riverside County DA action specifically identified medical waste among the unlawfully disposed streams [source: https://rivcoda.org/UPS_violation] [source: https://kesq.com/news/2025/08/04/united-parcel-service-and-affiliates-ordered-to-pay-1-7m-in-penalties-for-environmental-violations/]. UPS disclosed that 2025 healthcare logistics revenue exceeded $11 billion, reflecting expanded cold-chain and pharmaceutical volume following the Frigo-Trans and Andlauer Healthcare Group acquisitions [source: https://www.sec.gov/Archives/edgar/data/1090727/000162828026008432/ups-20251231.htm]. That revenue growth raises the baseline volume of regulated medical-waste handling across the network, which in turn widens the compliance surface area that the August 2025 California judgment addressed.

Pollutant 3 — Diesel particulate matter and NOx from ground fleet. UPS's own prior disclosures set a goal of 40% alternative fuel in ground operations by 2025 and 25% renewable electricity for facilities by 2025 [source: https://about.ups.com/content/dam/upsstories/assets/social-impact/2021-esg-highlights-brochure/en_en_2021SustainabilityBrochure_V15.pdf.pdf]. As You Sow's November 13, 2025 proposal frames diesel-combustion exposure along delivery corridors as an environmental-justice concern, noting amplified impacts on overburdened communities [source: https://www.asyousow.org/resolutions/2025/11/13-ups-third-party-environmental-justice-audit]. Diesel particulate matter and nitrogen oxides are criteria pollutants with documented respiratory health effects, and their concentration along high-frequency delivery routes in dense urban areas is the specific mechanism the proposal identifies as a financial risk.

Within NAICS 492110, the three highest-penalty ECHO rows are themselves UPS corporate-family registrations. Together they account for 20 violations and roughly $22.8 million in derived trailing-24-month penalties across 37 facilities [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. Adding the 2-facility, $4.24 million perimeter of the Tualatin-registered legal entity analyzed here brings the family total to approximately $27.1 million [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. That concentration is notable: the top penalty rows in a 492110 peer screen are not independent competitors but variant registrations of the same corporate parent. EJ index averages read 0.0 across all four rows, indicating a systemic gap in demographic overlay data rather than a substantive finding — a gap the As You Sow proposal seeks to address through a third-party audit [source: https://www.asyousow.org/resolutions/2025/11/13-ups-third-party-environmental-justice-audit].

UPS's Item 1A in the 10-K filed February 17, 2026 incorporates forward-looking-statement cautions and directs investors to monitor the company's Investor Relations website for material disclosures under Regulation FD [source: https://www.sec.gov/Archives/edgar/data/1090727/000162828026008432/ups-20251231.htm]. The filing describes a December 2025 agreement with the U.S. Postal Service for final-mile delivery of Ground Saver and Mail Innovations volumes starting in 2026, and the 2025 Frigo-Trans and Andlauer Healthcare Group acquisitions that expanded healthcare cold-chain capabilities to more than $11 billion in annual revenue [source: https://www.sec.gov/Archives/edgar/data/1090727/000162828026008432/ups-20251231.htm]. That healthcare revenue growth carries a direct compliance implication. The expansion of regulated pharmaceutical and medical-logistics volume interacts with the medical-waste handling allegations resolved in the August 4, 2025 Riverside County judgment [source: https://rivcoda.org/UPS_violation], because higher throughput of temperature-controlled pharmaceutical shipments increases the volume of regulated waste streams generated at sorting and distribution facilities. Separately, the February 2026 plan to close 22 union-staffed facilities will alter the RCRA-generator inventory subject to the 2022 nationwide consent order [source: https://finance.yahoo.com/news/look-united-parcel-valuation-facility-021653820.html] [source: https://www.epa.gov/newsreleases/ups-settles-epa-correct-alleged-hazardous-waste-violations-nationwide]. Facility closures require proper RCRA generator deregistration and waste-stream closeout procedures; each closure event is itself a compliance checkpoint.