EPR Registration in Kenya: A Step-by-Step Guide for Producers and Importers
If your company makes, imports, fills, repackages or rebrands products or packaging in Kenya, you may now have a legal duty to register under the Extended Producer Responsibility (EPR) rules. Many businesses know EPR exists but are unsure what registering actually involves, what it costs, or whether it applies to them. This guide answers those questions in plain language. For the wider picture of why EPR matters, start with our overview of EPR in Kenya.
Quick answer: Under the Sustainable Waste Management (Extended Producer Responsibility) Regulations, 2024, producers register with the National Environment Management Authority (NEMA). They then meet their obligations either through their own compliance scheme or by joining a producer responsibility organisation (PRO). Importers of listed products also need an EPR import certificate, which NEMA has required through the National Electronic Single Window System since 14 March 2026. NEMA has announced a second phase from 30 October 2026, when the certificate moves to the customs clearance stage.
This is general information, not legal advice. EPR rules and enforcement are still evolving, so confirm details with NEMA or a legal adviser before you act.
Who must register for EPR in Kenya?
The Regulations define a producer as an entity that brings goods, products or packaging into Kenya through activities such as manufacturing, importing, converting, filling, refilling, repackaging or rebranding. NEMA’s own summary says manufacturers and importers must manage the full life cycle of their products, including post-consumer waste.
The products covered are listed in the First Schedule. They include:
- Packaging for non-hazardous products: plastics, aluminium, composites, paper, glass, cardboard and cartons
- Packaging for hazardous products such as chemicals, oils, pharmaceuticals, agrochemicals, cosmetics and paints, plus agricultural films
- Electrical and electronic equipment, batteries and accumulators
- End-of-life vehicles, tyres and rubber
- Furniture, textiles, leather, diapers and sanitary towels
The legal summaries we reviewed mention no exemption for small producers and no volume or turnover threshold. That does not prove none exists, so ask NEMA to confirm whether your business size changes your duties.
EPR registration in Kenya: 6 steps
- Check whether your products are covered. Compare what you make or import against the First Schedule categories above. If packaging, electronics, batteries, tyres, textiles or similar items are part of your business, assume you are in scope until NEMA confirms otherwise.
- Map what you place on the market. List each product and packaging type by material and annual volume. You will need this baseline for your compliance plan, for any PRO you join and for later reporting.
- Choose your route: your own scheme or a PRO. Producers can meet their duties individually or through a collective scheme run by a producer responsibility organisation. A PRO carries out EPR duties for its members and charges fees under a structure agreed by members and submitted to NEMA. Organisations named in legal summaries include the Kenya Extended Producer Responsibility Organization, the Packaging Producer Responsibility Organization, the E-Waste Producer Responsibility Organization and the Kenya Hazardous Waste Producer Responsibility Organization. Each scheme must file a four-year EPR plan with NEMA, including a baseline study.
- Apply to NEMA for registration. Producers apply to NEMA, pay the one-off registration fee and receive a registration certificate. Schemes also need an annual operating licence, and scheme registration lasts up to four years and can be renewed once. Check NEMA’s EPR page for the current application channel before you start.
- Importers: get the EPR import certificate. Importers of listed products apply for an EPR certificate, which forms part of the documents needed for customs clearance and inspection. Applications go through the National Electronic Single Window System and need your KRA PIN.
- Keep records and report every year. Schemes must keep records and file annual reports with NEMA and the counties where they operate. Producers also carry design and take-back duties, such as reducing waste in products and packaging and supporting reuse, recycling and recovery.
How much does EPR registration cost in Kenya?
The figures below come from law-firm summaries of the Regulations published in early 2025. Fee schedules can change, so confirm current amounts with NEMA before you budget. In June 2026 NEMA also ordered a review of how EPR fees are collected, so PRO fees in particular may change.
| Item | Amount reported |
|---|---|
| Producer registration with NEMA | KES 5,000, one-off |
| EPR import certificate (importers of listed products) | KES 150 per item at importation |
| PRO membership fees | Set by the PRO and its members under a structure filed with NEMA |
| PRO remittance to NEMA | 5% of membership fees collected, due by 10 February each year |
| Scheme registration and annual operating licence | Payable by applicants; amounts not stated in the sources we reviewed |
For many businesses, PRO membership or running your own scheme is likely to cost more over time than the one-off registration fee. Ask any PRO you are considering how its fees are calculated, for example by tonnage, product type or revenue, and what services are included.
What changed in 2026: importer certificate, fees and a court order
EPR enforcement has moved quickly this year, so check these developments, in date order.
- 14 March 2026: NEMA announced that all importers of specified products must obtain an EPR Import Certificate through the National Electronic Single Window System.
- June 2026: NEMA ordered the Kenya Producer Responsibility Organisation (KEPRO) to reassess how it collects EPR fees and to agree a fee structure that complies with the 2024 Regulations, after finding the current framework non-compliant. As reported, this is a review and consultation, and no new amounts have been announced.
- July 2026: The Environment and Land Court issued conservatory orders in a dispute involving the Retail Trade Association of Kenya. As reported, the orders bar NEMA from making retailers enforce manufacturers’ EPR compliance while a constitutional petition is pending.
- 28 September 2026: NEMA and the Kenya Trade Network Agency (KenTrade) automated the step where importers opt in their KRA PIN on the Single Window platform. NEMA officers used to do this step manually.
- 30 October 2026 (announced 14 October): As reported, the importer EPR certificate moves to Phase 2 of the Single Window system. The certificate is then needed at the customs clearance and declaration stage, not at pre-clearance, and importers must register as producers. The service is reported to be unavailable from 5 pm to 11:59 pm on 29 October, and importers are urged to finish pending pre-clearance applications before then. We found this in one news report, so confirm the details with NEMA or your clearing agent.
The reports we reviewed describe the court order as limiting how NEMA uses retailers to enforce the rules. They do not say that producers’ own registration duties are suspended. Treat the order as a reason to watch for updates, not a reason to delay. A business that waits for the case to end may find itself behind on registration, records and PRO arrangements.
Penalties and enforcement for EPR non-compliance
The Regulations create several offences. According to legal summaries, these include:
- Wilfully failing to meet your statutory EPR obligations (a court must then order you to bear the cost of managing that obligation)
- Giving misleading or false information about quantities managed under a scheme
- Placing a product on the market for a producer that is not registered
- Operating as a free rider, meaning benefiting from a collective scheme without being a member, or failing your individual obligations
NEMA can also revoke, suspend or cancel registration certificates and annual operating licences, and aggrieved parties can appeal to the National Environment Tribunal. One June 2026 news report gives the penalty for non-compliance as up to KES 2 million, four years’ imprisonment, or both. We could not confirm this against the Regulations, so check them or ask a legal adviser for current penalties.
What SMEs should do now
You do not need a large compliance team to get started. These steps are enough for a first month:
- Build a product and packaging inventory. Record materials, weights and annual volumes. Good data makes registration, PRO talks and reporting much easier, and waste traceability systems help here.
- Confirm your status with NEMA. Ask whether you are a producer, an importer or both, and which Schedule categories apply to you.
- Compare PROs or plan your own scheme. Request fee structures, services and reporting support in writing.
- Fix your records. Keep invoices, import documents, take-back and recycling receipts in one place.
- Diarise key dates. Importers should confirm certificate steps before each shipment; PRO members should note the fee and reporting cycle.
Get your EPR registration sorted with Biomaps
Biomaps is a Kenya-based sustainability consultancy that helps SMEs, cooperatives, agribusinesses and institutions meet their environmental obligations. Our EPR consulting service helps you work out whether EPR applies to your products, map your packaging and product volumes, compare PRO options and prepare your records for registration and reporting. Our waste audits give you the data foundation, and our circular economy and recycling support helps you act on it.
Not sure whether EPR applies to you? Email info@biomaps.co.ke with your products, your annual volumes and whether you import, and we will tell you what to do first.
Frequently asked questions
Who must register for EPR in Kenya?
Producers, meaning manufacturers, importers, fillers, repackagers and rebranders who bring covered products or packaging into Kenya, must register with NEMA under the 2024 Regulations.
How much does EPR registration cost in Kenya?
Legal summaries report a one-off producer registration fee of KES 5,000 and an import certificate fee of KES 150 per item for importers. PRO membership fees are separate and set by each PRO. Confirm current amounts with NEMA.
Do I have to join a producer responsibility organisation?
Not necessarily. The Regulations allow producers to meet their obligations individually or through a collective scheme run by a PRO. Individual schemes must still be registered and file a four-year EPR plan.
Does the July 2026 court order mean I can ignore EPR?
No. As reported, the order stops NEMA from requiring retailers to enforce manufacturers’ compliance while a petition is heard. It does not remove producers’ own duties under the Regulations. Take legal advice for your situation.
Do importers need an EPR certificate?
Yes, for specified products. NEMA has required an EPR Import Certificate through the National Electronic Single Window System since 14 March 2026, and the certificate forms part of customs clearance documents. A second phase is reported to start on 30 October 2026, when the certificate moves to the customs clearance stage.
