KAWR convened an EPR Compliance Workshop on 5 December 2025 at the Best Western Plus Meridian Hotel, Nairobi. The event was held under the theme “Shaping the Future of EPR: Building Strong Systems and Clear Compliance Processes for Recyclers.”

The workshop was organized in response to the rapidly evolving Extended Producer Responsibility (EPR) landscape, following a prolonged legal process that resulted in a conservatory order halting the implementation of EPR regulations. This order was lifted on 20 November 2025, creating renewed momentum for sector-wide compliance and engagement.

While the legal case (ELC EP PET/003/2025) remains active, it has since been transferred to the Nairobi Environment and Land Court, where it is scheduled for mention on 8 December 2025 for further directions.

Against this backdrop, KAWR convened the workshop to align waste value chain actors with the compliance requirements outlined in the EPR Regulations (2024). The session also aimed to support recyclers in embedding clear operational structures within their businesses to enable a smooth, systematic transition toward compliance—one that ultimately fosters long-term sustainability.

The stakes could not be higher. The future of Kenya’s recycling industry will largely depend on how effectively stakeholders adapt to and implement the EPR framework.

The National Environment Management Authority (NEMA), through the Director of Enforcement, Dr. Ayub Macharia, provided an in-depth overview of the compliance requirements that recycling businesses must meet going forward. These include licensing obligations, digital traceability mechanisms for waste transportation, transparent and auditable record-keeping, waste segregation during transit, and mandatory declaration requirements. The message was unequivocal: compliance is no longer optional. It is now the benchmark by which the sector’s sustainability, credibility, and long-term viability will be measured, firmly positioning recycling as a cornerstone of Kenya’s circular economy agenda.

Despite the anticipated EPR subsidies intended to support waste management actors, Dr. Macharia highlighted several challenges that have hindered their effective rollout. Chief among these is the lack of commitment by producers to meet their EPR obligations, as stipulated under Section 13 of the Sustainable Waste Management (SWM) Act, 2022. While many producers have nominally committed to fulfilling their obligations through compliance schemes—namely Producer Responsibility Organizations (PROs)—a significant number remain non-compliant, effectively free-riding on the contributions of responsible producers.

In response, NEMA has introduced more stringent enforcement measures, including the direct prosecution of retailers that stock products from non-compliant producers. Major retail outlets have already received advance warnings, with enforcement crackdowns expected to commence on 1 February 2026.

The transition to the National Waste Information System (NWIS), established under Section 8 of the SWM Act, 2022, was another key area of discussion. The Act mandates NEMA to establish a centralized system for recording, collecting, managing, and analyzing waste data, including waste quantities and classifications, a register of licensed waste operators, compliance status, county-level waste services, and the environmental and public health impacts of waste management activities.

Mr. Peter Gitonga, Managing Director of CSharp Ngulu Limited—the firm appointed by NEMA to develop the system—presented the system’s prototype and technical specifications. The comprehensive nature of the NWIS was evident, with automated traceability of waste materials from the post-consumer stage through to reintegration (for recyclables) or final disposal (for non-recyclables). The system is intrinsically linked to regulatory compliance, as material-flow traceability and reporting across the waste management lifecycle will only be possible through licensed and compliant actors across jurisdictions. Given that the NWIS will be central to EPR subsidy disbursement, the importance of robust organizational structures and full compliance across the waste value chain was strongly underscored.

While some components of the system—particularly at the consumer interface—remain vulnerable to risks such as data manipulation or erroneous entries, its overall architecture, scope, and ambition demonstrated strong potential to transform Kenya’s waste management sector. The workshop repeatedly emphasized the need to embrace technology and digitization as enablers of transparency, efficiency, and accountability.

The workshop also examined NEMA’s proposed EPR fee calculation framework, which outlines key cost parameters for determining EPR fees. The general formula can be simplified as:

EPR Fee = (Cost of waste handling + waste processing/product chemistry + waste disposal + enablers) × Quantity

The workshop also featured JiPay, a fintech innovation company, which showcased its automated micro-savings platform designed to enable seamless saving through routine mobile transactions. The solution promotes financial discipline and inclusion, particularly for individuals and small enterprises operating within informal sectors. JiPay’s participation offered valuable insight into how financial technology can streamline payments and improve financial flows within the waste value chain.

For this framework to be equitable and reflective of market realities, stakeholders were encouraged to closely interrogate the Market Cost Indexes that will inform EPR fee calculations across different waste fractions. KAWR, as the national umbrella body representing waste value chain actors, has been tasked by NEMA with developing accurate and representative market indexes for this purpose. The session provided a critical platform for participants to review, challenge, and refine KAWR’s proposed indexes to ensure that the final submission accurately reflects sector dynamics.

KAWR continues to receive feedback from waste value chain actors in line with this objective. Stakeholders are invited to submit their proposals on the Market Cost Indexes to [email protected] no later than 11 December 2025. Additional information regarding the project may also be requested through the same contact.