Third Policy & Action Session under the Theme: “Access to Green Finance & Inclusive Circular Transitions”
Kenya Association of Waste Recyclers (KAWR) and Aspen Network of Development Entrepreneurs (ANDE) East Africa convened their third Policy Working Group Session on 20th February 2026.
Building on previous engagements that examined policy frameworks and implementation pathways under the Sustainable Waste Management Act, 2022, this session focused on measurable sector progress and implementation outcomes. Over the past months, KAWR has undertaken sustained engagements across county governments, national agencies, development partners, and private sector actors; translating the objectives of the partnership into tangible sector results.
Key Outcomes Achieved
Notable milestones realized in recent months include:
• Convening EPR cost validation workshops and technical working groups toward the development of an EPR Costing Module for the waste management sector, proposed for consideration by the National Environment Management Authority in the calculation of EPR incentives.
• Advisory support to county governments in domesticating the Sustainable Waste Management Act, 2022, into county legislation, including engagements with Nakuru County and Kisumu County, in compliance with statutory requirements.
• Technical participation in the development of national reusability guidelines under the Ministry of Environment Climate Change and Forestry.
• Contribution to the prototyping, review, and sector validation of the National Waste Management Information System.
• Regulatory engagement with the Kenya Revenue Authority on VAT treatment, input documentation recognition, and transitional compliance measures.
• Ongoing advocacy for harmonization and abolition of cess fees affecting cross-county waste movements.
• Formal sector submissions on draft regulations, including the Draft Electrical and Electronic Waste Management Regulations, 2025, and the Draft Environmental (Strategic Assessment, Integrated Impact Assessment and Audit) Regulations, 2025.
• Engagements addressing occupational health risks within the waste stream, including mitigation strategies for lead exposure.
• Participation in national roundtables linking circular economy reforms with investment ecosystems and capital markets.
• International collaboration centered around technical cooperation and knowledge exchange with Indian Plastic Institute.
These actions collectively reflect progress under key deliverables of the KAWR–ANDE partnership framework.
1. Advocacy for Policy Reforms
KAWR engagements under the partnership have contributed to:
• County-level legislative drafting aligned with national waste management laws.
• Submission of memoranda on draft County Sustainable Waste Management Bills.
• Structured proposals on EPR incentive and responsibility frameworks.
• Engagements aimed at regulatory clarity for electronic and hazardous waste streams.
2. Education, Communication & Awareness Creation
Through structured technical forums and sector outreach, KAWR has:
• Clarified compliance expectations under EPR 2024.
• Sensitized recyclers and waste actors on documentation standards and tax transition requirements.
• Engaged county governments on inclusive enforcement pathways.
3. Regulatory & Tax Framework Engagement
A green transition requires regulatory coherence to ensure investment certainty and sector stability.
KAWR’s engagements with:
• Kenya Revenue Authority
• National Environment Management Authority
have focused on:
• Transitional compliance mechanisms for waste sector actors under revised income validation frameworks.
• Recognition of alternative documentation models reflecting sector operational realities.
• Validation of EPR fee structures grounded in actual market cost indices.
Catalytic Finance and Climate Alignment
Kenya’s circular transition intersects directly with waste management reform, climate resilience, youth employment, and industrial competitiveness. The session also examined catalytic finance solutions designed to mobilize capital for circular enterprises. Discussions included impact-linked financing models and climate credit facilities, particularly in light of the operationalization of the Kenya National Carbon Registry on 17th February 2026.
This development presents a strategic opportunity for waste management enterprises to quantify and monetize their contribution to national climate objectives.
KAWR will continue working closely with ANDE East Africa to deliver practical, measurable impact for Kenya’s waste management sector.
The Kenya Association of Waste Recyclers (KAWR) is pleased to announce that its petition before the Environment and Land Court of Kenya (ELC Petition No. E026 of 2024 dated 3rd July 2024) has been successful. Judgment was delivered on 12th February 2026 in favour of the Petitioner against:
1) National Environment Management Authority – 1st Respondent
2) Cabinet Secretary, Ministry of Environment, Climate Change and Forestry – 2nd Respondent
3) Attorney General – 3rd Respondent
4) Council of Governors – 4th Respondent
5) Kenya Bureau of Standards – 5th Respondent
Background of the Petition
KAWR moved to court challenging the legality and constitutionality of a Public Notice dated 8th April 2024 issued by the 1st Respondent. The notice directed:
1) Mandatory segregation of waste across households, institutions, religious establishments, private and public functions and events;
2) Exclusive use of 100% biodegradable bin liners/garbage bags;
3) Immediate cessation of conventional plastic liners for organic waste collection; and
4) A requirement that county governments and licensed private waste service providers supply only 100% biodegradable garbage bags.
KAWR sought, among other reliefs, an order of certiorari to quash the Public Notice on grounds that it contravened constitutional provisions and waste management laws, was ultra vires, procedurally unfair, unconstitutional, and incapable of lawful implementation.
Court’s Determination
The Court found in favour of the Petitioner and quashed the impugned Public Notice.
Importantly, the Court further directed:
1. Establishment of the Waste Management Council The Cabinet Secretary, Ministry of Environment, Climate Change and Forestry (2ndrespondent)is required to establish the Waste Management Council as stipulated under Section 6 of the Sustainable Waste Management Act, 2022. The Council is to be chaired by a presidential appointee and must include representation from key stakeholders within the waste management space.
2. Operationalization of Material Recovery Facilities (MRFs) All the remaining forty three (43) County Governments are required to establish functioning Material Recovery Facilities (MRFs) within six (6) months of the ruling, in accordance with Sections 9 and 14 of the Sustainable Waste Management Act, 2022. This order of mandamus was issued by the court as a result of the petitioners concern that it was impossible to compel adherence to waste segregation obligations without proper infrastructure development at the county level.
Why This Matters
This judgment represents a significant victory for KAWR and, more broadly, for Kenya’s waste management and recycling sector.
It affirms that:
1) Environmental governance must adhere to constitutional standards, including legality, public participation, and proper regulatory process.
2) Policy implementation must follow the framework provided by statute rather than bypass it.
3) Institutional obligations under the Sustainable Waste Management Act, 2022 and other policy provisions are not optional.
KAWR is deeply grateful to the support from its membership towards this end and remains steadfast towards creating a more conducive and favorable environment to the entire waste management sector.
A delegation from the Kenya Association of Waste Recyclers (KAWR), led by the Secretary General, Mr. Richard Kainika (seated second from the right), held a meeting with a team from the Kenya Revenue Authority (KRA), led by Ms. Hakamba Wangwe, Chief Manager – eTIMS (seated third from the right), at JKUAT Towers, Nairobi, on 22nd January 2026.
The Kenya Association of Waste Recyclers (KAWR) held a consultative meeting with the Kenya Revenue Authority (KRA) at the KRA boardroom, JKUAT Towers, Nairobi, to discuss the impact of the KRA Public Notice of 7 November 2025 on the validation of income and expenses within the waste management and recycling sector.
The KAWR delegation was led by Secretary General Richard Kainika, accompanied by regional representatives Nicodemous Aono (Nairobi), Samuel Matimu (Rift Valley), and Rachel Kibali (Western), alongside Muhammed Iqbal, Lilian Ngibeyo, Joshua Obuya, Sylvia Ochiba, and Jacob Ondara. Chief Manager Etims KRA, Ms. Wangwe Hakamba opened the meeting and welcomed the delegation.
KAWR presented its position on the Public Notice, noting that while it supports KRA’s tax compliance and digitalization agenda, including eTIMS, the recycling sector operates through a fragmented value chain. Primary collection is largely informal, aggregation is conducted by micro-enterprises, and processing is undertaken by formal entities, resulting in most recyclable materials being sourced from suppliers who are neither VAT-registered nor eTIMS-enabled.
KRA Public Notice of 7 November 2025
KAWR cautioned that strict enforcement would lead to disallowance of raw material expenses, the sector’s largest cost component, thereby inflating taxable profits despite actual losses. Additional risks identified included VAT imbalances due to the inability to claim input VAT, cashflow constraints, market distortion favoring informal operators, and adverse social and environmental impacts, including reduced collector incomes and increased dumping.
The Association highlighted sector characteristics such as high transaction volumes with low unit values, thousands of micro-suppliers, daily cash transactions, and thin margins, noting that non-compliance by a single supplier can invalidate documentation across the value chain.
KAWR proposed a transitional period allowing recognition of alternative documentation, including petty cash records, delivery notes, aggregator or CBO receipts, supplier registers, and mobile money statements. It further recommended phased enforcement focused on education, simplified registration and eTIMS models for small collectors and aggregators, and issuance of sector-specific guidance on expense validation.
During the discussions, members sought clarification on the distinction between Value Added Tax (VAT) and Turnover Tax (TOT). Turnover Tax applies to businesses whose gross turnover exceeds KES 1,000,000 but does not exceed, or is not expected to exceed, KES 25,000,000 in any year of income. TOT is charged under Section 12(C) of the Income Tax Act (Cap. 470) and is payable at the rate of 1.5 percent of gross sales. Value Added Tax, on the other hand, is an indirect tax borne by the final consumer and is levied on taxable goods and services supplied in Kenya and on taxable goods imported into Kenya.
As a result of the discussions, KRA agreed to allow recyclers to proceed with filing their returns in March, as sector-specific issues continue to be addressed. Recyclers were advised to assess both VAT and Turnover Tax regimes and adopt the option most favorable to their business operations, subject to statutory eligibility. KRA acknowledged and appreciated the concerns raised by recyclers and committed to providing ongoing support to KAWR members to facilitate compliance with applicable tax requirements.
KRA advised KAWR to convene member sensitization forums with KRA participation and noted the importance of engaging associations during policy formulation.
From the left; Josphine Kawira(DRC), Hellen Chege(DRC), Yasin Abukar(My-Plastics Ltd.), Richard Kainika (KAWR), Dr. Sameer Joshi( IPI), Shabbir Noormohamed(My-Plastics Ltd.),Joan Maitai( DRC), Sharang Ambadkar (IPI).
Kenya Association of Waste Recyclers (KAWR) was honored to hold a working meeting with the Indian Plastics Institute (IPI) at the Double Tree by Hilton along Ngong Road, Nairobi. Registered in 1985, IPI is a professional body that brings together experts, industry players, and students involved in plastics and polymer technology. It focuses on strengthening skills through training, technical courses, seminars, and industry–academia collaboration. The institute also contributes to standardization efforts, quality control, and public awareness on plastics, their applications, and recyclability.
Also present at the meeting were representatives from the Danish Refugee Council (DRC) Kenya and My Plastics Limited.
The meeting concentrated on the shared objectives between KAWR and IPI—specifically opportunities and challenges within Kenya’s waste-management sector. Dr. Sameer Joshi, Chairman of the Indian Plastics Institute and a respected expert in plastic sustainability with over 30 years of experience, shared insights on India’s progress in plastic circularity. India has made notable strides by applying its strong technological capacity to develop solutions for low-value and hard-to-recycle plastics, including multilayer laminates. Through IPI’s work, such materials have been transformed into products such as planks, plywood alternatives, benches, tiles, and other utilities that replace higher-carbon-footprint materials. These solutions were further demonstrated by Mr. Sharang Ambadkar, a member of the IPI Environment & Ecology Committee and Sustainable Solutions for All.
This discussion was particularly relevant to Kenya, where hard-to-recycle packaging materials remain a persistent challenge. While local efforts exist, many of them require scaling to meet national needs.
From the left Richard Kainika (KAWR), Sharang Ambadkar (IPI), Shabbir Noormohamed (My-Plastics Ltd.), Joan Maitai ( DRC), Josphine Kawira (DRC), Hellen Chege (DRC), Kaguchia Anthony (KAWR), Yasin Abukar(My-Plastics Ltd.), Dr. Sameer Joshi( IPI).
India’s well-established Extended Producer Responsibility (EPR) framework also provides valuable insights. Its structure has supported the recycling ecosystem while considering the economic realities of different categories of enterprises. With Kenya’s renewed momentum following the lifting of the order affecting EPR implementation on 20th November 2025, such international perspectives can inform the country’s evolving EPR practices and strengthen its approach to inclusive and efficient implementation.
KAWR and IPI expressed their commitment to developing a memorandum of understanding focused on technical knowledge exchange. With IPI’s long-standing expertise, Kenya stands to benefit from innovative and practical solutions suited to its waste-management landscape. Additionally, leveraging IPI’s global networks may help elevate Kenya’s visibility in international sustainability platforms. There was also interest in exploring opportunities for Kenya to host major global forums on plastics.
Dr. Sameer encouraged KAWR to expand regional collaboration with similar bodies across East Africa. He emphasized that cooperation in market development, knowledge exchange, and capacity building would strengthen regional sustainability efforts and enhance Kenya’s leadership profile within the circular economy space.
The forthcoming non-profit memorandum of understanding will provide a structured framework for partnership, aimed at raising the capabilities, capacities, and overall quality of Kenya’s waste-management sector. The Secretary General of KAWR, Mr. Richard Kainika, reaffirmed the association’s commitment to working with institutions whose strategic objectives align with its mission of advancing sustainable waste management in the country.
KAWR held an EPR Compliance Workshop on 5th Dec 2025 at Best Western Plus Meridian Hotel, Nairobi. The Event, which was themed “Shaping the Future of EPR: Building Strong Systems and Clear Compliance Processes for Recyclers,” was convened in response to the evolving EPR landscape, which included the protracted legal case and the ensuing conservatory Order against EPR implementation, which was lifted on 20 November 2025.
The case (ELC EP PET/EOO3/2025), however, is still valid but transferred to the Nairobi Environment Court, where it is scheduled to be mentioned on 8th December 2025 for further directions. Against this backdrop, KAWR convened this session to align waste value chain players with the compliance requirements under the EPR Regulation (2024) and to embed clear structures in their businesses to ensure a systematic transition that will translate into long-term sustainability. The stakes couldn’t be higher; the recycling industry truly hinges on how well the sector will adapt to the EPR Framework.
In Photo; Dr. Ayub Macharia from NEMA making his presentation in the forum.
The National Environment Management Authority (NEMA), through the Director of Enforcement, Dr. Ayub Macharia, expounded in great depths the compliance requirements recycling businesses must have moving forward. From licensing requirements, digital traceability features for waste transport, transparent and auditable records, segregation requirements during waste transportation, and declaration obligations, the emphasis was clear: compliance is no longer optional. It is the yardstick that will determine the sector’s longevity and continued success, and it positions recycling as one of the most critical pillars in Kenya’s circular economy agenda.
However, despite the anticipated EPR Subsidies meant to support the actors in the waste management sector, the Dr. Macharia highlighted some key challenges that have hindered this, with the major one being the lack of commitment from producers to meet their EPR Obligation as provided in section 13 of the Sustainable Waste Management (SWM) Act, 2022. Though many producers have declared to fulfill these obligations via a compliance scheme (Producer Responsibility Organization), many remain freeloaders in these schemes, and their responsibility, consequently, is shouldered by a few responsible producers. NEMA, in response, have introduced more stringent measures which will include direct prosecution of retailers who shelve products from non-compliant producers. Advance warnings have been issued to major retail outlets, with crackdowns expected from 1st February, 2026.
The transition to the National Waste Information System as provided under section 8 of the SWM Act, 2022 which mandates NEMA to “Establish a national waste information system for recording, collecting, managing, and analyzing data, including the quantity and classification of waste, a register of licensed waste operators, status of waste management activities, impact on health and environment, county-level services, compliance information, and other data necessary for effective administration” was also an issue many players in the sector sought clarity on. Peter Gitonga, Managing Director CSharp Ngulu Limited; the entity appointed by NEMA to develop the system, shared the prototype specifications of the system. The comprehensive nature of the system was apparent which automates traceability of waste material flow right from the post-consumer stage right to the point of reintegration(for recyclables) and final disposal for non-recyclables. The system is inextricably linked with compliance at material flow traceability and reporting through the various waste management stages is only possible via compliant waste actor across the various jurisdiction. Since the system will be central to EPR subsidization processes, the need for strong organizational structures and compliance in waste-value chain businesses was further underscored.
And while some few components of the system remain unclear and exposed to risk of manipulation and erroneous data entry, especially at the consumer stage, its overall shape, structure, and comprehensive approach demonstrated the capacity to redefine the waste management sector for the better. Embracing technology and digitization in the waste management sector was a call repeatedly reiterated in the workshop.
The EPR Fee calculation published by NEMA listed some parameters to be included for EPR Fee determination. The general formula for calculating the EPR fee in Kenya could be simplified as follows:-
EPR fee = Cost of (waste handling + waste processing/product chemistry + waste disposal + Enablers) x Quantity.
For this formula to be representative and fair for the sector, it is imperative for the people who are in the waste management sector to interrogate the Market Cost Indexes, which will be used for EPR Fee calculation for the various waste fractions, in order to safeguard accuracy and precise representation. KAWR, as the national umbrella body for the entire waste value chain actors had been tasked by NEMA to develop accurate market indexes for various waste fractions for the said purpose. The session offered a crucial chance for participants to examine and interrogate the market indexes KAWR had developed, as well as complement and refine KAWR’s proposition to ensure the final submission would be an accurate representation of the sector.
The Association is still receiving responses from waste value chain actors regarding the stated objective. Any proposals on the Market Cost Indexes may be submitted to info@kenyarecyclers.co.ke no later than 11th December 2025. Additional details on the project can also be requested through the same contact.
JiPay, a fintech innovation company showcased their automated micro-savings platform designed to help users save seamlessly through routine mobile transactions. Their solution supports financial discipline and inclusion, particularly for individuals and small enterprises in informal sectors. Their presence added valuable insight into how technology can streamline financial flows within the waste value chain.
The Kenya Association of Waste Recyclers (KAWR) has placed recycling education and public sensitization at the core of its mandate. As the premier (BMO) business membership organization for Kenya’s private-sector waste management and recycling, KAWR works to empower the recycling value chain, advocate for supportive policies, and connect recyclers to markets. This focus on awareness and capacity building has positioned KAWR as a leader in advancing the country’s transition to a circular economy.
Against this backdrop, KAWR is joining the world in marking Global Recycling Week, an annual commemoration that amplifies the mission of reducing waste, conserving resources, and inspiring citizens to take responsibility for what they consume and discard. The week serves as a global platform to highlight innovations, celebrate grassroots recyclers, and rally public action toward a more sustainable future.
This year in Kenya, KAWR is championing the national rallying call:
This slogan underscores the fact that waste only becomes valuable when it is separated at source. Mixing destroys material value and clogs recycling systems, while sorting unlocks opportunities—jobs, cleaner neighborhoods, new enterprises, and a thriving circular economy. The call to “join the movement” extends beyond recyclers to every household, institution, and business, inviting all Kenyans to become active participants in transforming the waste landscape.
To bring this message to life, KAWR has lined up a week of activities aimed at sensitizing the public, training grassroots groups, and showcasing the economic potential of sorting at source. The kickoff took place on 23rd September 2025 with a KAWR team led by Sylvia Ochiba, KAWR’s Administration and partnership officer, who visited Mukuru Integrated CBO in Embakasi East. This community-based organization brings together 20 youth groups engaged in waste management at the source, demonstrating how local champions are converting challenges into opportunities despite threats of eviction and limited infrastructure.
Throughout Global Recycling Week, KAWR will continue to amplify stories like Mukuru Integrated CBO’s and roll out community engagement forums, media campaigns, and partnerships with local governments and private sector players to scale up source separation and recycling initiatives, culminating with a national virtual public townhall where experts will delve into the subject.
KAWR calls on all stakeholders—households, businesses, institutions, and government agencies—to rise up and join the recycling movement. By sorting at source, every Kenyan can play a role in reducing waste, creating livelihoods, and advancing a cleaner, greener, and more inclusive economy.
In the evolving landscape of waste management and circular economy, the credibility of a recycler has become more than a badge of honor—it is the very foundation upon which partnerships, investments, and producer responsibility organizations (PROs) build long-term collaboration. Recycling is no longer about simply diverting waste from landfills; it is about demonstrating responsible practice across multiple fronts, from compliance and fair trade to human rights and energy efficiency. The following themes provide a practical benchmark to guide recyclers toward practices that reflect sustainability expectations of the production industry and the wider society
Credibility in recycling cannot exist without strong compliance. At the very minimum, recyclers are expected to meet statutory benchmarks, including business registration, environmental permits, waste handling licenses, and tax obligations. But compliance goes beyond paperwork—it is about aligning daily operations with both local laws and internationally recognized standards. Adherence to Occupational Health and Safety (OHS) protocols, fair labourregulations, and environmental safeguards shows that a recycler values the people who work within their operations as much as the materials they process. Transparent documentation, regular audits, and demonstrable proof of compliance should not be viewed as an inconvenience but as a badge of integrity that earns trust from producers, PROs, investors, and the public.
A deeper layer of compliance involves sustainable power consumption and climate-conscious practices. In an industry where energy use often represents a significant cost and environmental footprint, credible recyclers must account for the source and efficiency of their energy. This means adopting renewable energy where possible, reducing dependency on fossil fuels, and integrating resource-efficient technologies. Likewise, aligning with global practice guidelines—such as the Basel Convention, ISO standards, or Extended Producer Responsibility (EPR) frameworks—positions recyclers as serious players in a global movement rather than as local operators chasing short-term gains. True compliance, therefore, is not about doing the bare minimum; it is about embedding accountability in every part of the recycling chain.
Scope of Practice
A recycler’s credibility is often reflected in the clarity and honesty of their scope of practice. Some recyclers take on only the most profitable fractions—such as PET, aluminum, or high-value polymers—while leaving low-demand materials like multilayer plastics or mixed packaging to less advantaged players. While this selective offtake may appear commercially sound, it skews the industry ecosystem and undermines holistic waste diversion goals. A transparent recycler acknowledges the limits of their operations but does so without creating systemic disadvantages for others.
Responsible scope of practice means being upfront with stakeholders about what materials are collected, how they are processed, and where they end up. It also means actively exploring innovations to handle hard-to-recycle fractions, whether through partnerships, joint ventures, or technology investment. By resisting the temptation to cherry-pick only high-margin materials, recyclers can contribute to a balanced market environment that fosters fair competition and sustainability. This is where credibility becomes measurable—not just in tons processed, but in the breadth and inclusiveness of materials managed.
Offtake and Uptake Transparency
The strength of a recycler is not only in the volumes they collect but in the credibility of their offtake channels and uptake markets. Transparent recyclers establish clear agreements with processors, manufacturers, or exporters, ensuring that recovered materials have a genuine second life rather than being stockpiled or informally dumped. This demands traceability systems that account for every fraction of waste, demonstrating accountability to producers and PROs who need evidence of real impact.
On the uptake side, credibility is tested by the recycler’s ability to integrate recovered materials into legitimate value chains. This requires market intelligence, networking, and sometimes even pioneering new applications for recycled content. When recyclers exaggerate demand or misrepresent uptake, they risk eroding trust not only in themselves but in the recycling sector at large. A transparent approach, where data and market realities are shared honestly, creates a healthier ecosystem that benefits recyclers, producers, and consumers alike.
Peer Interaction and Industry Conduct
Recycling is not a solo pursuit; it is an industry built on networks and partnerships. How a recycler interacts with peers, competitors, and associations is a key credibility marker. Credible recyclers foster collaboration rather than predation, respecting the role of community-based organizations, informal waste pickers, and small enterprises that form the backbone of many recycling systems. By building bridges rather than monopolizing supply chains, they contribute to an inclusive industry that distributes opportunities fairly.
This is also where integrity in competition comes into play. Practices such as using grants or donor incentives to artificially lower prices and edge out smaller recyclers create an uneven playing field. While grants and incentives can play a role in building capacity, credible recyclers avoid weaponizing them to distort markets. Instead, they use such resources responsibly, investing in efficiency, innovation, and shared growth, while recognizing the contributions of peers who may not have access to similar privileges.
Human Rights and Labour Practices
At its core, recycling is a people-driven industry. From waste pickers to plant operators, the human element defines the heartbeat of recycling. Credible recyclers commit to safeguarding human rights across their operations. This means eliminating child labour, ensuring fair wages, and providing safe working environments that respect human dignity. Compliance with OHS standards is non-negotiable, but beyond compliance lies a culture of respect, inclusion, and empowerment of workers.
Labour practices also determine how recyclers are perceived by communities and international partners. In today’s interconnected world, supply chains are scrutinized not just for outputs but for social conduct. Recyclers that uphold decent work principles position themselves as sustainable partners of choice for producers and PROs, while those that exploit vulnerable labourundermine both credibility and long-term viability.
Energy Integrity and Pricing Fairness
Energy consumption is one of the most telling reflections of a recycler’s integrity. Many recycling processes are energy-intensive, and how a recycler manages this demand can either strengthen or weaken their credibility. A responsible operator prioritizes energy efficiency, invests in renewable sources where possible, and avoids wasteful practices that inflate costs and carbon footprints. Energy integrity is not simply about reducing bills; it is about aligning with broader sustainability goals that seek to reduce greenhouse gas emissions and reliance on fossil fuels.
Equally important is pricing integrity. In competitive markets, recyclers may be tempted to undercut prices just to secure sales, sometimes even below the real cost of operation—especially when subsidized by external grants. Such practices may yield short-term advantages but harm industry sustainability by creating unrealistic benchmarks that smaller players cannot meet. Credible recyclers adopt pricing structures that reflect real market conditions, balancing competitiveness with fairness and ensuring that the sector grows on stable, sustainable foundations.
Investment Strength and Market Tolerance
Behind every recycler lies a financial backbone, and the caliber of investors often reveals much about a recycler’s resilience and credibility. Strong capital investment signals stability, the ability to weather market fluctuations, and a commitment to long-term growth rather than quick returns. However, credibility also comes from the tolerance and mindset of these investors. Those who understand the importance of inclusive market development are more likely to support practices that empower small players, rather than push them out.
The overreliance on grants and subsidies can become problematic when it shifts from enabling growth to fostering dependency. Credible recyclers demonstrate a capacity to operate on their own capital, treating grants as supplementary tools rather than the foundation of their existence. This balance between capital strength and ethical investor conduct helps create a recycling industry where competition is sustainable and legally sound, and where innovation thrives without disadvantaging vulnerable market actors.
Conclusion
The credibility of a recycler is multi-dimensional, touching on compliance, scope of practice, transparency, peer relations, labour standards, energy use, pricing fairness, and investment ethics. It is not a label claimed by self-declaration but a reputation earned through consistent conduct and verifiable practice. Producers, PROs, and policymakers increasingly seek recyclers who embody this holistic credibility because only then can recycling move beyond tonnage targets to create genuine environmental, social, and economic impact.
For recyclers themselves, embracing these benchmarks is not about perfection but about progress. By striving toward transparent, ethical, and inclusive practices, recyclers can build not just businesses, but legacies—driving a circular economy that is fair, credible, and sustainable for all.
Bringing Standards to Life These benchmarks are not abstract ideals—they are already being embedded into practice through sector-wide initiatives. The Joint Innovation Facility (JIF) project, co-developed by Kenya Association of Waste Recyclers(KAWR) and GFS East Africa, is digitizing recycler operations to enable traceability, efficiency, and compliance with EPR frameworks. At the same time, KAWR is developing a threshold and attestational instrument with PROs, designed to qualify recyclers for participation in EPR projects based on adherence to these very standards. Together, these initiatives transform credibility from principle into measurable practice—ensuring recyclers are not only service providers, but trusted partners in building a circular economy with real and lasting impact.
Nairobi, 8th July 2025 — A multisectoral policy working group convened yesterday in a high-level roundtable organized by the Kenya Association of Waste Recyclers (KAWR) and the Aspen Network of Development Entrepreneurs (ANDE), spotlighting Kenya’s transition to a circular economy and green financing opportunities under the Sustainable Waste Management Act (2022).
Held under the theme “Access to Green Finance & Inclusive Circular Transitions,” the forum brought together such as; policymakers, recyclers, Producer Responsibility Organizations, green technology experts, and development partners to unpack the implementation of Extended Producer Responsibility (EPR) and its ripple effects on SMEs, waste sector jobs, and climate goals. This was the second session with the first session having taken place on 22nd November 2024.
Key Highlights from the Discussion:
EPR in Action: The Act’s emphasis on producer responsibility, county-level materials recovery facilities, and waste-to-energy solutions holds significant potential for waste reduction, resource efficiency, and job creation. However, gaps in implementation, monitoring, and inclusive enforcement remain.
SME Constraints & Green Finance Gaps: Access to patient capital remains a key constraint for circular startups. Participants called for blended finance tools, credit guarantees, and impact-linked funding tied to climate goals.
Informal Sector at Risk: Without formal pathways, the shift to regulated waste systems risks excluding informal workers. Speakers pushed for legal recognition, cooperatives, and gender-inclusive roadmaps.
Policy Coherence and Urgency: The window to act is narrow. With supportive legislation already in place, stakeholders emphasized the need for fast-tracked implementation—particularly sector-specific EPR guidelines, green procurement standards, and the activation of a national waste data management systems.
Some of the Recommendations Moving Forward:
Operationalize EPR Guidelines and Monitoring Systems
Finance Innovation: Develop circular innovation clusters and financing instruments tailored to green SMEs.
Formalize the Informal: Protect livelihoods through training, social protections, and cooperative support.
Build County-Level Circular Hubs: Promote local waste-to-value ecosystems.
Intensified Public Awareness: The need to align the public with the requirements and provisions of guidelines such as EPR was identified as a critical priority in the sector.
Improving Waste Data Systems in the Country.
Targeted infrastructural development such as Material Recovery Facilities especially in counties
Addressing the regulatory barriers such as subsidies and incentives for circular businesses.
Alignment of recycled products with international standards
As Kenya grapples with rising waste, youth unemployment, and climate pressure, the circular economy offers a triple-win: economic renewal, environmental stewardship, and inclusive job creation. But policy inaction will be costly.
This policy dialogue also builds on groundwork laid earlier in April 2025, when KAWR and ANDE, under the auspices of SoteHub, hosted a series of interactive forums in the Coastal Region. These sessions spotlighted grassroots innovation in circular economy practices—ranging from Afya Duara CBO’s organic composting and youth training programs in Mtwapa, to plastic recycling and 3D printing innovations showcased by Twende Green, Tiki Post’s recycled plastics fencing alternatives at and other circular innovations the SoteHub Center in Nyali. The Coastal engagements emphasized real-world application of circular models and underscored the potential of SMEs and community-based enterprises to anchor Kenya’s green transition.
Notably, KAWR Secretary General Richard Kainika’s keynote in Mombasa set the tone for yesterday’s national dialogue—calling for regulatory reform, stronger EPR enforcement, financing for SMEs, and inclusion of the informal sector. In this sense, the 8th July Nairobi event served as a natural progression: from showcasing what’s possible on the ground, to building the policy and financing architecture needed to scale such innovations nationwide. Together, these engagements mark a coordinated push toward a more inclusive, resilient, and circular Kenyan economy
KAWR and ANDE East Africa remain committed drivers in the realization of Kenya’s Circular Economy Potential.
On 7th May 2025, the High Court in Nairobi issued conservatory orders in the constitutional petition Law Society of Kenya vs. National Environment Management Authority (NEMA) & Others. These orders temporarily halt the implementation of the Extended Producer Responsibility (EPR) Regulations 2024, which had been officially launched on 5th May 2025. The implementation of EPR in Kenya was expected to cause significant disruptions in the operations of the country’s waste recovery and recycling sectors, as manufacturers would now be legally responsible for the entire lifecycle of their products.
The Law Society of Kenya (LSK) filed a petition challenging recent administrative directions issued by NEMA. These directives, if enforced, would have:
Introduced abrupt new licensing and operational requirements,
Disrupted ongoing waste management activities, and
Lacked the necessary legal backing and public participation required under the Constitution.
LSK argued that the directives threatened constitutional rights and risked causing irreparable harm to affected parties, including businesses already licensed under existing environmental regulations.
The High Court of Kenya, through Hon. Mr. Justice Bahati Mwamuye, found merit in these aforementioned concerns and issued conservatory orders suspending NEMA’s directives on EPR implementation. This means:
The contested directives from NEMA are currently halted.
All stakeholders, including recyclers and waste handlers, may continue operating under the previous regulatory framework without any legal consequences. Compliance to the EPR directives
The case will be mentioned in court on 16th June 2025 to confirm compliance with the conservatory orders and to schedule an expedited hearing of the substantive matter.
What This Means for KAWR Members
For members of the Kenya Association of Waste Recyclers (KAWR), the ruling has several important implications/ramifications:
No Legal Obligations
You, by law, are not required to follow the provisions of EPR (2024) Regulations. However, while the court process has temporarily halted EPR enforcement, the Sustainable Waste Management Act (2022) and other applicable regulatory provisions remain in force.
2. Temporary Legal Shield
Until the case is heard and decided, NEMA cannot enforce the challenged rules. This protects your business from abrupt compliance demands, penalties, or suspensions stemming from the provisions of EPR (2024) Regulation.
Strategic Advocacy Window
This pause creates a valuable window for meaningful engagement and reflection on sector readiness in the event the conservatory order are lifted.
Kenya Association of Waste Recyclers encourages all its members to;
Continue Current Operations: Remain compliant with existing legal and licensing requirements.
Stay Informed: KAWR is closely monitoring the court proceedings and will issue updates as developments unfold. Any question, concern, or clarification can be addressed to info@kenyarecyclers.co.ke or our hotline number 0737 526 588
Prepare for Engagement: Be ready to provide input when public consultations or stakeholder meetings are announced.
Document Impacts: Maintain internal documentation on how the proposed directives would have affected your operations—this could be vital for future advocacy or legal support.
The matter is scheduled to return to court for mention on 16th June 2025.
The Conservatory Orders are shared below for your reference.
Environmental sustainability depends on efficient waste management, and producer subsidies are vital to the financing of waste management organizations (WMOs) in Kenya. However, preserving stakeholder trust depends on making sure these subsidies are used efficiently and openly. The Kenya Association of Waste Recyclers (KAWR) is dedicated to resolving these issues by implementing organized supervision procedures that support efficiency, justice, and accountability.
Enhancing Contractual Structures
Working together with WMOs and Producer Responsibility Organizations (PROs) to create standardized contracts is one of the main initiatives KAWR is pursuing. The terms, conditions, and intended use of subsidies are spelled out in these contracts. Additionally, they contain particular performance metrics and benchmarks to guarantee that funds are distributed and used.
Systems for Digital Tracking and Reporting
KAWR is promoting the use of digital platforms that monitor the transfer of subsidies from PROs to WMOs to increase transparency. These platforms give stakeholders access to real-time data on how funds are being spent, enabling them to keep an eye on developments and guaranteeing efficient use of subsidies.
Audits by Third Parties
To guarantee that subsidies are being used appropriately, independent verification is crucial. Third-party audits will be carried out regularly, according to KAWR. The results of these audits will be made available to the general public, enhancing stakeholder confidence and accountability.
Building WMO Capacity
Strong administrative abilities and financial awareness are necessary for efficient subsidy management. For WMOs, KAWR is planning training courses on compliance, reporting, and financial management. WMOs will be better able to fulfill their contractual responsibilities and follow best practices.
Public Disclosure and Involvement of Stakeholders
The foundation of accountability is transparency. PROs and WMOs are being urged by KAWR to release comprehensive reports on the use of subsidies, including costs and results. To promote trust and well-informed decision-making, these reports will be distributed to the public, PROs, and government authorities.
Mechanisms for Grievance Redress
Mechanisms for reporting instances of subsidy misuse or misallocation must also be part of a robust oversight system. To guarantee that complaints are handled quickly and that remedial action is done when required, KAWR is setting up avenues for stakeholders to voice concerns.
Cooperation with Regulatory Organizations
To ensure adherence to subsidy agreements, KAWR is collaborating closely with regulatory bodies including the National Environment Management Authority (NEMA). This entails creating policies and procedures that control the distribution and application of subsidies and guarantee that all stakeholders follow the strictest accountability requirements.
Rewards for Adherence
KAWR is looking into measures to reward WMOs that exhibit excellent compliance and efficient use of subsidies to promote adherence to transparency standards. Preferential access to upcoming financing possibilities or public acknowledgment of exceptional performance are two examples of incentives.
In conclusion
By putting these policies into place, KAWR hopes to guarantee that subsidies are put to better use—improving Kenya’s recycling and waste management systems. A sustainable and responsible waste management system is built on transparency and accountability, which are not merely legal obligations. Through these efforts, KAWR underlines its dedication to resource management and the advancement of a circular economy in Kenya.
