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Every day in Kenya, millions of plastic bottles are purchased, used, and discarded. To most
consumers, the story of a bottle ends the moment it is thrown away. But in reality, that is where a
much longer journey begins — a journey that involves thousands of people working across the
recycling value chain.
Understanding this journey is important because it reveals a fundamental truth: while many
businesses benefit from packaging placed on the market, the responsibility and cost of recovering
that packaging has historically fallen on the shoulders of the recycling sector.
This is the story of what happens to a PET bottle after it is discarded.

1: The Consumer
The journey begins when a consumer purchases a beverage packaged in a PET plastic bottle.
After use, the bottle is discarded. In most cases in Kenya, waste is mixed together rather than
separated at source, meaning recyclable materials are often mixed with organic waste and other
contaminants.
At this point, the bottle has lost its immediate commercial value. Without intervention, it is likely
to end up in a dumpsite, drainage system, or the environment.

2: The Waste Reclaimer (Picker)
The first person who restores value to that bottle is often a waste reclaimer.
Across cities and towns in Kenya, thousands of informal waste collectors recover recyclable
materials from households, streets, markets, and dumpsites. These workers manually identify,
collect, and sort valuable materials such as PET bottles, aluminium cans, and paper.
Waste picking is physically demanding work that often takes place in difficult conditions. Yet
waste pickers play a critical role in keeping recyclable materials within the economy rather than
allowing them to become environmental pollution.
At this stage, the bottle begins its transition from waste to resource.

3: The Aggregator or Buy-Back Centre
Once collected, the bottle is sold to an aggregator or buy-back centre.
Aggregators play a vital role in the recycling ecosystem. They purchase recyclable materials
from waste pickers, on unit kilogram basis, they segregate and consolidate volumes from
multiple collectors, and perform preliminary sorting and storage, as well as primary processing
for the few with space and equipment. Many aggregators operate micro enterprises that provide
working capital to sustain material recovery activities.
This stage helps ensure that enough material is accumulated to make transportation to processing
facilities economically viable.

4: Transport and Logistics
Recyclable materials must then be transported from aggregation centres to processing and value
addition facilities.
In Kenya, recycling infrastructure is still developing, and processing plants may be located far
from where materials are collected. This means recyclables often travel long distances before
reaching a facility capable of processing them.
Transport costs, fuel, handling, and storage all contribute to the overall cost of recovering
packaging materials.

5: Sorting and Pre-Processing
Before recycling can take place, materials must be sorted, cleaned, and prepared.
At this stage, recyclers remove contaminants, separate different types of plastics, and process
materials through shredding or baling. Contamination and material losses are common,
especially when waste has been mixed at the point of disposal.
These processes require equipment,space, labour, compliance and infrastructure, all of which
involve significant investment.

6: Recycling and Manufacturing
Finally, the PET bottle reaches a recycling facility.
Here, it is processed into plastic flakes or pellets that can be used as secondary raw material in
manufacturing. These recycled materials can then be used to produce new products such as
packaging, textiles, or other plastic goods.
At this point, the bottle has completed its transformation from waste into a valuable input for
industry.
Who Bears the Cost of This Journey?
While the recycling value chain generates economic value, it also carries substantial costs.
In Kenya today, many of these costs are absorbed by:

• Waste pickers through labour-intensive collection work
• Small aggregators through working capital and market risks
• Processing and Recycling enterprises through investments in equipment, logistics,
  and processing
  Yet the packaging that ultimately becomes waste originates from products placed on the market
  by producers and brand owners.
  Why Extended Producer Responsibility Matters
  This imbalance is one of the reasons why many countries around the world have adopted Extended Producer Responsibility (EPR) policies.
  EPR systems require producers to take responsibility for the end-of-life management of the packaging they introduce into the market. The goal is not to penalize producers but to ensure that the environmental cost of packaging is fairly shared across the value chain.
  Globally, EPR fees typically represent a very small portion of product cost — often well below two percent of the retail price — while helping to finance systems that collect, sort, and recycle packaging materials.
  Building a Fair Circular Economy
  Kenya’s recycling sector already performs an essential environmental service by recovering valuable materials that would otherwise pollute the environment.
  Strengthening this system requires collaboration across the value chain — from producers and policymakers to recyclers and consumers.
  By recognizing the full journey of a PET bottle, we can better understand the importance of building systems that ensure packaging does not end its life as waste, but instead returns to the economy as a resource.
  That is the essence of a circular economy.
  Richard Kainika
  Nairobi
  March 2026

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 (2^ndrespondent)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.