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2021-06-15T15:45:19Z
Kenya Plastic Action Plan, KAM 2019.pdf
PhotoBylove:

November 2019

Accelerating a Circular Economy in Kenya

Kenya Plastic
Action Plan

Kenya Association of Manufacturers
15 Mwanzi Road opp West Gate Mall, Westlands

P.O. Box 30225 – 00100 Nairobi, Kenya

E: info@kam.co.ke
M: +254 (0) 722201368, 734646004/5

T: +254 (020) 2324817
Twitter: @KAM_Kenya

Facebook: KenyaAssociationOfManufacturers

www.kam.co.ke

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Proposed 6%
growth

annually

January
2020

January
2025

June
2030

1 year
January

December
2022

b) Three Year Plan to operationalize producer
responsibility organizations for all plastics stream

a) Proposed National Recycling Target


Kenya Plastic Action Plan iii

ABBREVIATIONS AND ACRONYMS 1

ACKNOWLEDGMENT 2

FOREWORD 3

EXECUTIVE SUMMARY 4

1 INTRODUCTION 8

2 PLASTIC WASTE MANAGEMENT PRACTICES 11

2.1 Plastics consumption and waste generation on a global scale 11

2.2 Recycling Plastics 14

2.3 The Circular Economy Concept 15

2.3.1 Introduction 15

2.3.2 Plastics in a Circular Economy 17

2.3.3 Global Circular Economy Examples 18

2.3.4 African Circular Economy Examples 21

2.3.5 Alternatives to Plastics 26

2.4 Kenyan Plastic Mass Flow 27

2.4.1 Quantification of plastic volumes 27

2.4.2 Collection Systems 32

2.4.3 Recycling Infrastructure 34

2.4.4 Disposal Practices 36

2.4.5 Challenges for Plastic Recycling in the Waste Management Ecosystem 38

3 LEGAL AND REGULATORY FRAMEWORKS AFFECTING THE PLASTICS SECTOR 41

3.1 Review of Kenyan (regional, national and county) legislation formulation on

plastic and waste management 41

3.2 Discussion of the existing regulatory gaps 44

4 SWOT ANALYSIS OF THE KENYAN PLASTICS VALUE CHAIN 47

5 PROPOSED MEASURES AND INITIATIVES FOR THE ACTION PLAN 50

5.1 Establishing a Financial and Organisational Basis 50

5.1.1 Tax incentives 50

5.1.2 Extended Producer Responsibility 51

5.1.3 Comparing tax incentives and EPR 63

5.2 Action Measures 64

5.2.1 Recycling and/or End of Life Options 64

5.2.2 Segregation at source as best practice and waste collection 66

5.2.3 Product Design for enhanced recycling 69

5.2.4 Consumer awareness – communication and education 71

5.2.5 Biodegradable plastics 73

5.2.6 Integration informal sector 74

Table of contents


Kenya Plastic Action Plan iv

6 IMPLEMENTING THE ACTION PLAN 76

6.1 Implementing the EPR system 76

6.2 Implementing voluntary measures 86

6.3 Implementation Matrix 90

7 REFERENCES 96

8 ANNEXES 105

8.1 Annex 1: Background to Plastics 105

8.2 Annex 2: The polymer types 107

8.3 Annex 3: Recycling the different polymer types 109

8.4 Annex 4: Recyclate usage 110

8.5 Annex 5: The circular economy concept in detail 112

8.6 Annex 6: Global trends 114

8.7 Annex 7: Questionnaire for online survey 120

8.8 Annex 8: Circular Economy and The Big4 Agenda 121

8.9 Annex 9: Alternatives to plastics 121

8.10 Annex 10: Global examples of education and awareness programmes 141

8.11 Annex 11: Flow chart for determining the recyclability 142

Table of contents


Kenya Plastic Action Plan v


Kenya Plastic Action Plan vi

Table 1 Quantities of recycled plastics and plastic packaging acc. to fraction in 2017

[Eunomia, 2018] 30

Table 2: Roles and responsibilities in an EPR system 57

Table 3: EPR fees and green taxes in comparison 63

Table 4: Collection structures for packaging for the individual material fractions in five different

countries with EPR systems 66

Table 5: Plastic packaging fees in EU-28 EPR schemes [Watkins et al., 2017] 81

Table 6: Role of each stakeholder within the proposed Kenyan EPR system 85

Table 7: Integration of the informal sector as employees 88

Table 8: Integration of the informal sector as business partners 89

Table 9: Establishing a legal basis for a mandatory EPR system 92

Table 10: Establishing a pre-organisation on a voluntary basis 93

Table 11: Improving an optimising mechanism when the mandatory EPR system comes into force 94

Table 12: Quantities of produced primary plastics and generated waste acc. to sector, 2015

[Geyer et al., 2017] 106

Table 13: Quantities of produced plastics and generated waste acc. to polymer, 2015

[Geyer et al., 2017] 108

Table 14: Global Warming Potential for different raw materials 122

Table 15: Ranking of different water bottles related to selected environmental criteria

[Schonert et al., 2002] 124

Table 16: Ranking of different beverage packaging for immediate consumption related to selected

environmental criteria [Schonert et al., 2002] 124

Table 17: Phase depending negative effects for different beverage packaging relating to selected

environmental criteria [Kauertz et al., 2011] 125

Table 18: Masses of different packaging types 126

Table 19: GWP of different packaging types relating to different disposal scenarios

[Paqualino et al., ny] 126

Table 20: Comparison of PET-bottles with glass-bottles according to [Stichling, Singh, 2012] 127

Table 21: Comparison of different materials for bottles for water 128

Table 22: Comparison of different materials for carrier bags 134

Table 23: Selected GWP100 for construction pipes 136

Table 24: Phase-Dependent and Total GWP per km of 30.5 cm (12 in.) diameter pipes for different

Materials [Du et al., 2013] 138

Table 25: General advantages and disadvantages of plastic, concrete and steel/iron pipes

[EPA, 2000] 139

Table 26: Comparison of different materials for construction pipes 139

List of tables


Kenya Plastic Action Plan vii

Figure 1: Locations of on-site interviews 09

Figure 2: Global plastics consumption per capita per day [Jambeck et al., 2015] 12

Figure 3: Primary plastics production by industrial sector, 2015, [Geyer et al., 2017] 13

Figure 4: Plastics waste generation by industrial sector, 2015, [Geyer et al., 2017] 13

Figure 5: Waste hierarchy 14

Figure 6: Circular economy conceptualisation [Green Growth, 2014] 16

Figure 7: Expected development of the plastic and plastic recycling market 17

Figure 8: The Danish Plastic Action Plan 19

Figure 9: Waste sorting at Taka Taka 21

Figure 10: The Business of Taka Taka 21

Figure 11: Business of Mr. Green Africa 22

Figure 12: Awareness rising in schools 22

Figure 13: Mass flow of plastics material within Kenya 27

Figure 14: Composition of waste generated in Nairobi [JICA, 2010] 32

Figure 15: The hierarchy of the plastic waste recycling chain 35

Figure 16: Dandora dumpsite 37

Figure 17: Basic idea of an EPR system 52

Figure 18: Basic scheme of an EPR system based on a collective responsibility 53

Figure 19: Comparison of collective and individual EPR system 53

Figure 20: The different set-up conditions of the PRO 55

Figure 21: Operationalised EPR scheme 58

Figure 22: Waste segregation and collection in Germany (upper left) and Spain (upper right),

Japan (bottom left) and Shanghai (bottom right) 67

Figure 23: Waste collection in Palermo (left) and Tunis (right) 68

Figure 24: Container designs 68

Figure 25: PET substitution 70

Figure 26: Attached lids on bottles 70

Figure 27: Interface for determining the obliged companies 80

Figure 28: Distribution of the global plastics production, 2017 [PlasticsEurope, 2018] 105

Figure 29: Recyclate use according to polymer fraction [based on EuCP, 2017] 110

Figure 30: Recyclate use according sectors [based on EuCP, 2017] 110

Figure 31: Three principles and ten corresponding strategies towards circular economy [PWC, 2019] 113

Figure 32: G7 Ocean Plastic Charter 114

Figure 33: The 17 SDGs of the UN 115

Figure 34: GWP for 1 m of installed plain wall sewerage and drainage pipe [Wassenaar, 2016] 137

Figure 35: NRED for 1 m of installed plain wall sewerage and drainage pipe [Wassenaar, 2016] 137

List of figures


Kenya Plastic Action Plan viii

Bio- based plastics Plastics which are manufactured from renewable sources; for instance
sugar cane (as opposed to fossil-based plastics, which are derived from
fossil fuels). The term bio-based doesn’t necessarily imply bio-degradability.

Biodegradable plastics Plastics which can be degraded or composted by microorganisms under
specific, environmental conditions. Biodegradable plastics can be made
both of bio-based as well as fossil-based plastics.

Circular economy The circular economy is defined as an economic model in which resources
like plastics are used more efficiently through the three guiding principles
of “reduce, reuse and recycle” to close the loop. Shifting to such a system
has economical as well as social and environmental benefits through
reduced import dependency, employment creation, reduced littering, less
resource extraction as well as improved human health conditions.

Deposit-refund system (DRS) A surcharge which is placed on certain products and containers by
manufacturers. When consumers return quantities of these containers or
products, the surcharge is refunded.

Disposal Refers to any operation which is not defined as recovery; this also applies if
the operation later results in a secondary consequence for the reclamation
of substances or energy.

Energy recovery A process in which energy (heat, electricity, fuel) is generated from
the primary treatment of waste. The most common implementation is
incineration. It is not material recycling.

Extended producer An environmental policy approach in which a producer’s responsibility for
responsibility (EPR) a product is extended to the post-consumer stage of a product’s life cycle,

i.e. when a product turns into waste. Already during the production and
sale (and export), producers are responsible for disposal of their packaging.
Producers/importers pay a fee for later disposal of the packaging (before)
when their packed goods are placed on the market. The contribution/
fee is used for collecting, recycling and disposing of the packaging waste
and other costs arising from maintaining the system. It is not used as a
contribution to the general public budget of a state.

Feedstock recycling The process of breaking down collected plastics into monomers and other
basic chemical elements. These monomers can be used as virgin material
alternatives in manufacturing new polymers. Particularly interesting for
plastics which are difficult to recycle – due to their low quality, composite
nature or low economic value.

Free riders Producers/manufacturers and importers that enjoy the benefits of the
EPR system without paying the corresponding fees, including those that

under-declare their volumes.

Material recycling Describes a recycling process in which waste materials are mechanically
reprocessed into products, materials or substances with equivalent
properties – also referred to as closed-loop recycling – or a product which
requires lower properties.

Manufacturer / converter Companies which produce plastic packaging or plastic items by converting
raw material.

Landfill A location where most generated municipal solid waste is disposed. In
the Kenyan context, there are no sanitary landfills that include proper
ecological precautionary measures like wastewater treatment or landfill
sealing. In many cases, it cannot be distinguished whether the disposal
site is a landfill or dumpsite.

Definition of terms


Kenya Plastic Action Plan ix

Life cycle analysis Life cycle analysis (also called Life-cycle assessment or LCA) is a technique
to assess environmental impacts associated with all the stages of a product‘s
lifespan (from raw material extraction through materials processing,
manufacture, distribution, use, repair and maintenance, to disposal or
recycling).

Obliged companies Companies which are obliged to pay a fee within a running EPR system.

Oxo-fragmentable plastics Plastics which quickly fragment into micro-particles in the presence of
warmth, light and oxygen but do not degrade in the environment, thereby
becoming a source of environmental pollution in the form of microplastic.

Packaging The materials in which a product is wrapped or covered in to protect it
before being sold or transported.

(Packaging) user Companies that use packaging for their products when placed on the
market. In literature, often referred to as “producer” instead of “user”.

(Packaging) filler Companies that fill empty packaging with their products before placed on
the market.

Polluter pays principle The waste producer or owner is the potential polluter and carries responsibility
(including financially). The “polluter pays” principle creates the necessary
incentives for environmentally-friendly conduct and the required investment.

Producer See “(Packaging) user”.

Waste prevention Measures taken before a substance, material or product has become waste,
which reduces quantities of waste and also includes re-use of products
and the extension of the lifespan of products. Also reduces amounts of
hazardous substances being used and the adverse impacts of the generated
waste on the environment and human health.

Producer responsibility The central element for the organisation of all tasks associated with the
organisation (PRO) EPR system. Allows producers/users to assume responsibility by combining

their efforts and jointly managing the arising waste through collective
responsibility. The PRO is the most important stakeholder (organisation)
and is responsible for setting up, developing and maintaining the system
as well as the take-back obligations of the obliged companies.

Recovery Describes any operation in which waste serves a useful purpose by replacing
other materials or using its material properties (includes preparation for
reuse, recycling as material or feedstock recycling and energyrecovery).

Recyclables Materials that still have useful physical or chemical properties after serving
their original purpose and therefore can be re-manufactured. Some are
of positive economic value as well (e.g. rigid PE, PET bottles).

Recyclates A product which has passed through a life cycle and subsequently a
recycling process, which means it is made from used materials (e.g. plastic
regranules).

Recycler Companies that recycle pre-processed waste streams (e.g. sorted rigid PE
plastics) by washing, flaking, agglomerating and regranulating. With these
actions, an economically marketable output product is reached.

Reducing The practice of using less material and energy to minimize quantities of
generated waste and preserve natural resources. Includes ways to prevent
materials from becoming waste before they reach the recycling state. Also
includes re-using products.


Kenya Plastic Action Plan x

Re-use The repeated use of a product in the same form for the same or a different
purpose. In this case, the product does not become waste.

Rigid plastics items Plastic items that are stable in form, e.g. PET-bottles, PP cups, plastic pipes
(in contrast to flexible plastic items such as film).

Single-use plastics products Are used only once and then thrown away, includes items like plastic
cutlery, straws or coffee stirrers.

Solid waste management (SWM) The storage, collection, transportation and disposal of solid wastes. Also
describes a practice by which several waste management techniques are
used to manage and dispose of specific components of solid waste. Waste
management techniques include avoidance, reduction, reuse, recycling,
recovery and disposal.

Source separation The segregation of specific materials at the source for separate collection.

Waste hierarchy Describes a ranking of waste management options according to what is
best for the environment. It gives top priority to waste prevention; if waste
is generated, the priorities lie within preparing for re-use, then recycling,
then recovery and lastly for final disposal.

Waste management The term waste management discribes characteristic activities include
(a) collection, transport, treatment and disposal of waste, (b) control,
monitoring and regulation of the production, collection, transport, treatment
and disposal of waste and (c) prevention of waste production through in-
process modifications, reuse and recycling.

Definition of terms


Kenya Plastic Action Plan 1

BMO Business Membership Organization

CGK Clean Green Kenya

DRS Deposit Refund System

EMF Ellen MacArthur Foundation

EOL End-of-Life

EPR Extended Producer Responsibility

EPS Expanded Polystyrene

GWP Global Warming Potential

HDPE High Density Polyethylene

JICA Japan International Cooperation Agency

KAM Kenya Association of Manufacturers

KEBS Kenya Bureau of Standards

KEPSA Kenya Private Sector Alliance

KPAP Kenya Plastic Action Plan

LCA Life Cycle Analysis

LDPE Low density Polyethylene

MSW Municipal Solid Waste

NGO Non-Governmental Organisation

NRED Non-Renewable Energy Demand

OECD Organization for Economic Co-operation and Development

PE Polyethylene

PET Polyethylene Terephthalate

PP Polypropylene

PRO Producer Responsibility Organisation

PS Polystyrene

PVC Polyvinyl Chloride

SDGs Sustainable Development Goals

SUP Single Use Plastic

TOC Total Organic Carbon

WEEE Waste Electrical and Electronic Equipment

Abbreviations & Acronyms


Kenya Plastic Action Plan 2

The Kenya Plastic Action Plan was developed by a team of consultants drawn from Cyclos GmbH (based in Germany)
and AHK Services Eastern Africa Limited (based in Kenya) on behalf of Kenya Association of Manufacturers (KAM).
Specifically, KAM appreciates Dr. Stephan Löhle, Ms. Jana Brinkmann, Ms. Agnes Bünemann – from Cyclos, and
Mr Thilo Vogeler, Ms. Caroline Sawe, Mr. George Warutere, Ms. Sophie Kaminski and Ms. Valerie Leisten - from
AHK, for putting the report together.

We would like to acknowledge the KAM Board of Directors, led by the Chairman, Mr. Sachen Gudka for offering
strategic direction in the development of the Kenya Plastic Action and KAM Chief Executive Officer, Ms. Phyllis
Wakiaga, for providing continued guidance in the preparation of the report.

Special thanks to Kenya Plastic Action Plan Steering Committee members led by Mr. Mucai Kunyiha (Coopers
K Brands)- KAM Vice Chairman, Co-Chair Mr. Priyen Tanna(General Printers), Mr. Andrew Musingo (Coca-Cola
Beverages Africa), Ms. Susan Maingi (Coca-Cola Beverages Africa), Mr. Aniruddh Shah(KAPA Oil), Mr. Himanshu
Dodhia (Bidco Africa), Mr. Leonard Kareko(DOW Chemical), Mr. Rajiv Raja(Sanpac Africa Limited), Mr. Davander
S Mongia (Techpak Limited), Mr. Minal Shah (Techpak Limited), Ms. Doris Kendi(Coca-Cola Beverages Africa), Ms.
Faith Ngige(KEPSA), Mr. Sahil Shah(ADPAK LIMITED), Mr. Akshay Shah (Silafrica Ltd) for their overall guidance
to the Consortium.

Oversight on the development of the Action Plan content was provided by Mr. Job Wanjohi, KAM Head of
Policy, Research and Advocacy. Special thanks to Ms. Miriam Bomett (KAM Deputy Head of Policy, Research
and Advocacy), Ms. Sally Kahiu (KAM Head of PR, Communications and Marketing), Mr. Jackson Wambua (KAM
Sectors Manager) and Ms. Sharon Okwany (KAM PET Sub-sector Officer) for leading in continuous review and
revising various versions of the draft document.

Sincere appreciation goes to the Ministry of Environment and Forestry and the National Environment Management
Authority for their contributions on environmental policy and legislation.

Finally, our gratitude goes to the Confederation of Danish Industry (DI) for providing a conceptual framework in
the development of this Action Plan and Business Advocacy Fund (BAF) for financing the research and publication
of this report.

Consortium;

Acknowledgement

Research and publication funded by;

Technical and conceptual support provided by;


Kenya Plastic Action Plan 3

Foreword

Waste is a fact of human life. How we handle it, either depletes us
of our most critical natural resources; or, restores, regenerates and
enhances our humanity.

As the world’s dynamism continues, time is of the essence. Nothing
in the world will stop long enough to allow us to come up with the
greatest, most perfect solution, to any problem, let alone one as
complex as that of waste. It is upon us to act fast, turn this ship
with innovative agile thinking, collaborative efforts and, a zeal to
create a better world.

The Kenya Plastics Action Plan is a giant step by the country to
arrest the problem of plastic waste management, turning it into
an environmental and economic solution. This private-sector led
initiative aims to be a catalyst for the establishment of more long-
term, progressive and revolutionary measures to tackle waste
management holistically.

As we begin this journey, we need to enhance the collaborative frameworks that have brought us to this point, by
bringing onboard actors that will ensure that the spirit of this initiative is centered in the national development
discourse for the short-term and long-term. For instance, how do we make the environment a critical part of
our national consciousness, so that the ethos of every home, school, institution and business in the country is
anchored on leaving the planet, better than we found it? How can we ensure that everyone sees environmental
restoration as a personal, institutional and organizational responsibility? How do we ensure a shared vision by all?

The Kenya Plastics Action Plan, with all its main actors that is, Industry and Government, has started to piece
together the answers to the questions above at a primary level. It paints a roadmap towards realizing a Circular
Economy for plastic use and waste management in the country. It looks at the formation and regulation of
Extended Producer Responsibility schemes and establishment of re-cycling value chains and standards.

As we do this we are conscious that we have just started to lay the foundation for something bigger. In doing this
we must we must equip ourselves with innovation, technology, progressive regulations and policies, to continue
to advance the solutions in step with the needs of our country, and the world.

I speak for the Association in saying that we are committed, and are at the forefront of driving the establishment
of a circular economy, towards sustainably managing waste, and conserving and restoring our environment.

Sachen Gudka
KAM Chairman


Kenya Plastic Action Plan 4

Context
The government, through the Ministry of Environment and
Forestry, has shown a strong commitment to stop the pollution of
the environment which is particularly worsened by poor plastics
waste management. This commitment is marked by the ban on
the use, importation and manufacture of plastic carrier bags for
both commercial and household packaging. Following the ban, the
National Environment Management Authority (NEMA) pronounced
its intentions to extend the ban to plastic bottles. However, the
Ministry of Environment and Forestry has indicated their desire to
encourage manufacturers to develop plans to recycle plastic bottles.

The private sector, through the Kenya Association of Manufacturers
(KAM), embraced the initiative to come up with substantial solutions
to come up with substantial solutions to curb plastic waste and to
tackle management gaps and other challenges faced by the sector.
The Kenya Plastic Action Plan is a private sector-driven initiative, with

the aim to involve policy makers, the general public and the industry itself in safeguarding a clean environment
and together to pave pathway to a green economy in Kenya.

The Kenya Plastic Action Plan written to foster concepts of circular economy, to the benefit of both the environment
and the people. It proposes the creation of a model of Extended Producer Responsibility (EPR), as implemented
successfully in many places all over the world. The EPR model establishes an intermediary organization, the
Producer Responsibility Organization (PRO), that is financed by mandatory membership of all companies that
utilize plastics for packaging within the Kenyan market. It utilizes the collective funds to operationalize waste
management strategies which ensure that plastic waste is managed appropriately – with the goal of maximizing
the recycling rate moving towards a circular economy.

Currently, the waste management structures fail to address the magnitude of the waste problem in Kenya, both
in rural and in urban areas. In the capital region of Nairobi, roughly a fifth of the solid waste of around 3,000
metric tons per day is recovered for recycling. Around four fifths of the waste volumes are littered on the streets
– eventually entering water bodies – burnt onsite or disposed of at dumpsites. Existing dumpsites and landfills
have by far exceeded their capacities to safely dispose of the waste volumes, thereby degrading the environment
and adversely affecting human health. Fuelled by rapid urbanisation and changing consumer patterns towards
more packaged goods, the challenges are only going to increase.

Executive Summary


Kenya Plastic Action Plan 5

The Kenya Plastic Action Plan outlines measures and proposes concrete actions for all stakeholders to overcome
existing waste management problems. Taking the best examples worldwide into consideration and building on
existing value chains and pioneering actors within the country, the measures not only target improvements
towards a clean and healthy environment, but also showcase how the circular economy can contribute to economic
growth and welfare. All plastics that are consumed and processed in Kenya are imported one way or the other.
Therefore, the responsibility to manage them properly must be taken jointly by all entities putting plastics on
the market, including both local and international companies.

Objective of the Study
By building an understanding of the Kenyan context regarding waste management, including existing legal and
regulatory framework, the Kenya Plastic Action Plan provides in-depth research into the Kenyan plastics sector.
It incorporates the entire plastics value chain, spanning from imports of raw material to manufacturing processes
to uses and subsequent recycling of different plastic fractions.

The study followed a qualitative approach and included a literature review, online questionnaire, face to face
interviews throughout the whole country, focus group discussions and a stakeholders’ forum. All findings are
supported by the extensive local and international experience of the consultancy consortium. Thus, the Kenya
Plastic Action Plan aims to document local plastics waste management practices, highlight global best practices
for extended producer responsibility as well as sketch a unified private sector position on an Action Plan specific
to the Kenyan context. Most importantly, this report is meant to inform the development of a suitable and
sustainable policy framework on plastics in Kenya.

Summary of strengths, weaknesses, threats and opportunities for private sector
engagement in tackling waste management challenges

Strengths Weaknesses

• Private sector commitment to manage plastic waste
• Strong support for need an EPR expressed by public and

private sector
• Functioning recycling value chains for certain plastics
• Product design decisions made within the country
• Most consumer products processed domestically

• Plastic waste spread throughout the country
• Practically no tradition of waste segregation
• Slow growth in formalized waste collection
• Insufficient waste management infrastructure
• Gaps in regulations and laws on plastics waste

management

Opportunities Threats

• Government tax incentives to investors into plastic
recycling (15% Corporate Tax for investor operating
a plastic recycling plant for the first 5 years and VAT
Exemption on services offered to plastic recycling plants
and supply of machinery and equipment used in the
construction of the plants

• Rising awareness among the population on plastic waste
management

• Affordable labour cost and high need for employment
particularly on recycling sector

• Improvement on International standards on plastic
manufacturer and waste management

• Unpredictable legislative framework to plastics waste
management in the country

• Disjointed efforts in management of plastics wastes
by various stakeholders in the Industry

• Voluntary measures on plastic waste management
which in most cases may fail to deliver results

• Market highly price competitive


Kenya Plastic Action Plan 6

Key Findings
The research revealed that the regulatory framework concerning plastics in Kenya is currently under intense
development. Tax incentives discussed by the National Government showcase, among other examples, the
commitment of the public sector to improve on private sector engagement in Kenya’s waste management. Yet,
within the given framework, existing recycling companies have shown to be unable to sufficiently meet the
requirements for proper plastic waste management. Three areas have been identified as suitable for legislative
and regulative intervention.

1) Recycling infrastructure – consisting of grassroots businesses as well as formal enterprises – exists within

the whole country. Visionary enterprises and committed individuals offer an opportunity to play a significant
role, also in the further development of a stringent framework. As the sector progresses and redefines itself,
informal players – who played a significant role in the successes that have come about so far – need to be
incorporated as well.

2) Awareness campaigns amongst citizens need to be further developed. This will ensure that all citizens, no
matter their social and economic status, are able to embrace better waste management and adapt behaviour
accordingly. Particular focus needs to be placed on better segregation practices at source, reducing waste
generation and enhancing recyclability. Therefore, the need for environmental protection education needs
to be instilled from an early age onwards.

3) The evident challenges of existing waste management practices in Kenya require immediate action. With a
strong private sector dedicated to taking this action, Kenya is in a position to implement the needed changes
through coordinated action from both the public and private sector. The key element is the setup of an
Extended Producer Responsibility (EPR) framework.

Proposed Measures
In order to tackle the challenges highlighted above, the researchers recommended that:

• An Extended Producer Responsibility (EPR) model led by the private sector should to be set up, with one

independent Producer Responsibility Organization (PRO) as its focal actor.
• The Government should support the private sector to take responsibility for managing plastic waste. The PRO

should therefore be a private sector entity enshrined in an appropriate regulatory and legislative surrounding.
• Membership of the PRO should be compulsory by law – for all companies releasing plastic packaging on to

the Kenyan market, be it from imports or domestic production.
• Within the legislative and regulatory framework, provisions should be set to support the circular economy.

This may include tax incentives as well as set quota for recycling and/ or disposal.
• PRO members should pay a fee based on the volume and type of plastics they use. This fee covers the

associated waste management costs.
• Non-members of the PRO such as informal businesses, should participate in waste management by being

surcharged at the last interface with the formal sector, e.g. when liaising with the raw material supplier.
• The PRO collaborates with waste management operators in building incentives in order to achieve certain

collection and recycling quotas.
• Existing waste management structures, including the informal sector, are involved from the beginning and

need to scale up to increase their role in the growing circular economy.
• The PRO builds a forum connecting all involved stakeholders – government, importers, manufacturers,

distributors, consumers, collectors, aggregators, recyclers, converters, etc.
• Activities of the PRO should include awareness and capacity building among the general citizen on better

waste management practices.

Phyllis Wakiaga
KAM Chief Executive


Kenya Plastic Action Plan 7


Kenya Plastic Action Plan 8

Plastics are one of the most versatile materials of our modern society. Their unique combination of light weight,
inert properties and high durability gives them an essential role in most economic sectors such as building and
construction, automotives, food and beverages, agriculture, health and pharmaceuticals. Plastics have developed
from a material used for niche applications in the first half of the 20th century to an essential and ubiquitous
element of our global economy [Plastikatlas, 2019]. Represented in numbers, the global plastics production
increased from 2 million mt (metric tonnes) in 1950 to 381 million mt in 2015. Cumulatively, the world had produced
7.8 billion mt of plastics by 2015 [Geyer et al., 2017].

However, concerns about negative impacts caused by increased leakages
of plastic waste into our environment are rising globally. Through improper
forms of waste handling, which are happening worldwide, plastic waste has
become a ubiquitous part of our environment, transported by wind and water
to places far off from any human settlement. This accumulation of plastic
waste in the environment is highly problematic; not because of aesthetics,
but because of the multiple harmful, often lethal consequences for animals,
such as entanglement, digestion of plastics and other effects caused by the
hundreds of hazardous chemicals found in littered plastic waste [Kühn et
al., 2015; Rochman, 2015].

As most of these negative externalities eventually result from a poor, improper and socially as well as environmentally
damaging waste management, creating sustainable waste management for plastics is the first logical step to
solve this issue. However, as the sustainable use of plastics requires measures throughout the entire value chain,
a more holistic approach is the most suitable solution.

Objective of the study
As a means to reduce plastic degradation and pollution in Kenya, the Ministry of Environment & Forestry banned
“the use, manufacture and importation of all plastic bags used for commercial and household packaging” in 2017
and proposed to expand this ban to PET bottles. Nevertheless, the Ministry of Environment & Forestry indicated
that they would encourage manufacturers to propose plans to recycle as opposed to the potential ban.

Thus the Kenya Association of Manufacturers (KAM), as the representative organisation for manufacturing value,
commissioned the present report to document local plastic waste management practices, global best practice
on managing plastic waste, as well as to articulate a unified position of the private sector and a “Kenya Plastic
Action Plan” and inform the preparation of a suitable and sustainable policy framework on plastics in Kenya.
In particular, this Action Plan incorporates policy suggestions and sustainable funding mechanisms to enable
circular economy concepts for the environmentally sustainable use and recycling of plastics in Kenya. Therefore,
the plan pursues three main goals:

i) To offer inclusive and broad stakeholder engagement,
ii) To propose policy recommendations to catalyse the transition towards a circular economy on all governmental

levels, and
iii) To deliver achievable and relevant actions leading to tangible results of reduced environmental pollution,

increased investment and more effective circular economy financing mechanisms.

The Kenya Plastic Action
Plan proposes measures

favouring the implementation
of circular economy concepts

for the environmentally
sustainable use and recycling

of plastics in order to
catalyse action tailored to

Kenyan conditions.

1. Introduction


Kenya Plastic Action Plan 9

Methodology
To address this objective systemically, a qualitative case study methodology is used to explore the current
situation and its possibilities from several possible angles. This approach allows us to understand an individual
case and its respective problems.. Thus, literature research, an online questionnaire (see annex 8.7) and face
to face interviews are chosen as suitable methods. Together, they serve to triangulate the information needed.

As a first step, a literature review was undertaken to gain familiarity with the contextually relevant legal and
regulatory frameworks, as well as conditions and practices of plastic waste management in Kenya and other
selected countries. Special emphasis is given to the distribution of responsibilities between the National Government
on the one hand and the devolved functions carried out by the Counties on the other.

Secondly, the theoretical part has been complemented by empirical insights gained from key informant interviews,
the focus group discussions and the stakeholders’ meeting. The interviews and discussions regarding the effects
of the legal and regulatory framework on the plastic sector value chain, the plastic waste management practices
as well as opportunities of a circular economy applied to the plastics sector in Kenya (incl. the economic,
environmental and social dimension) were conducted through personal meetings by the local partner AHK
Services Eastern Africa Ltd. All on-site interviews were attended by two interviewers.

Interviews were conducted in Kisumu, Nakuru, Naivasha, Eldoret, Mombasa and in the Greater Area of Nairobi,
which includes Thika/Kiambu and Athi River/ Machakos. In addition to the interviews, two focus group discussions
and a stakeholders’ meeting covered key informants mainly from the Greater Nairobi area (see Figure 1). The
interviewees and participants in the focus group discussions and stakeholders’ meeting included players from
all levels of the plastics value chain. Additionally, an online survey to gain a more holistic understanding of the
plastic mass flow in Kenya was conducted.

The interviews, the focus group discussions and the stakeholders’ meeting, together with desk research, form
the basis for the Kenya Plastic Action Plan and the proposed policy framework: the local knowledge from the
stakeholder interviews allow the Action Plan to be tailored to the present contextual conditions in Kenya.
The Action Plan thereby entails an inclusive, holistic and broad private sector-led roadmap approved by the
stakeholders across the whole plastics supply chain.

Figure 1 : Locations of on-site interviews


Kenya Plastic Action Plan 10


Kenya Plastic Action Plan 11

The following chapter briefly introduces plastics as material and its recycling practices. More information on
plastic consumption and waste generation on a global scale, with particular reference to different polymer types,
can be found within the annexes. Concepts on how to handle plastic recycling effectively within the framework
of different circular economy implementations are also outlined there.

2.1 Plastics consumption and waste generation on a global scale
The term ‘plastics’ describes a huge group of polymers, which form the
backbone that enable the creation of various fractions of plastics with very
different characteristics for a vast range of applications.

The most commonly used materials for plastic packaging are thermoplastics,
a group of diverse materials that melt when heated and harden when
cooled in a reversible manner. Polymers of this group are, for instance,
polyethylene (PE; widely used in the form of either “low density” = LDPE
or “high density = HDPE”), polypropylene (PP), polystyrene (PS), polyvinyl
chloride (PVC), and polyethylene terephthalate (PET).

For manufacturing any plastic material, so-called monomers have to be
produced through separating the hydrocarbon chemicals from either
fossil sources like natural gas, petroleum or coal (called fossil fuel-based
plastics or fossil-based plastics) or renewable sources like corn or sugar
cane (called bio-based plastics). These monomers form the building blocks
for the polymers.

Due to its suitability for a vast range of products, the plastics value chain
has become a global network.
Looking at the African continent, the daily plastics consumption generally
ranges between 0 to 0.2 kg per person; with South Africa being the only
exemption. Kenya’s daily plastics consumption is estimated to be 0.03 kg
per person (Figure 2), which is at the lower end of the spectrum and roughly
represents a tenth of the total municipal solid waste volume [Jambeck et
al., 2015].

2. Plastic Waste Management Practices

As plastics are used across all kind of sectors, the plastics economy has become a global business.
However, the plastics usage by sector and the plastic waste generation by sector vary significantly, which
is rooted in the different in-use phases of the product. As packaging has the shortest in-use phase, it is
the biggest contributor to plastic waste.

‘Plastics’ is an umbrella term
for a wide range of different
materials with very different
properties. They can originate
from both fossil-based as well
as bio-based sources.

Generally, all plastics consist
of polymer chains, which
vary in their composition and
structure. There are two major
groups: the thermoplastics
that can be reversibly heated,
melted and cooled down, and
the thermosets which cannot
be re-melted once they have
cooled down.

This distinction has important
implications for the recycling
of plastics.


Kenya Plastic Action Plan 12

When it comes to plastics, many terms are used in a vague manner. To clarify the following definitions
are used in this report:

Plastics products is the umbrella term for any items which consist of one of several plastic types,
regardless of purpose, properties and duration of in-use phase. Packaging refers to products made
from any materials for the reception, protection, handling, delivery and presentation of goods which
may range from raw material to processed product and which are passed on by the manufacturer to
the user or consumer.

Single-use plastics (SUP) - often also referred to as disposable plastics - are items which are intended
to be used only once before they are thrown away or recycled. This includes plastic packaging such as
bottles and containers but is not limited to packaging. Other items are grocery bags, straws, cups and
cutlery, among others.

Figure 2: Global plastics consumption per capita per day [Jambeck et al., 2015]

Examining the plastics production on a deeper level by looking at plastics use per sector, the following picture
emerges (Figure 3): in 2015, the highest proportion (36 %) of all plastics was manufactured to produce packaging,
while building and construction were ranked second with 16 %.

However, plastic production does not directly reflect plastic waste generation, as the waste generation is shaped
by the polymer type and the lifetime of the end product (Figure 4). This is why packaging, with its very short ‘in-
use’ phase of, on average, six months, also constitutes the biggest share of waste generation (~47 %). In contrast,
building and construction are responsible for 4 % of the generated waste as the average in-use phase is 35
years. Total annual waste generation equals approx. 75 % of the annual plastics production [Geyer et al., 2017].

2. Plastic Waste Management Practices


Kenya Plastic Action Plan 13

Figure 4: Plastics waste generation by industrial sector, 2015, [Geyer et al., 2017]

Figure 3: Primary plastics production by industrial sector, 2015, [Geyer et al., 2017]


Kenya Plastic Action Plan 14

2.2 Recycling Plastics
To improve the waste management situation, basic concepts and definitions related to waste management, such
as definitions of waste, recycling, recovery are a crucial prerequisite for explaining when waste ceases to be
waste and becomes a secondary raw material (so called end-of-waste criteria), and how to distinguish between
waste and by-products.

The central concept for proper waste management and recycling is the waste hierarchy as anchored in the
European Waste Framework Directive (Figure 5): It is a set of priorities for the efficient use of resources and
waste treatment listing the most preferred to least preferred option starting with prevention (measure before
a product becomes waste), preparation for reuse, recycling, energy recovery, and disposal. The aim of this
hierarchy is to ensure that waste management takes place at the highest level possible.

Figure 5: Waste hierarchy

Recycling requires a specific definition, as there are often different definitions across countries and sectors
about which processes are considered recycling and which are not. Generally, recycling describes the process
of using recovered material to manufacture a new product. This definition can be further differentiated into
material and feedstock recycling.

Material recycling describes recycling processes in which waste is mechanically reprocessed into a product with
equivalent properties – also referred to as closed-loop recycling – or a product which requires lower properties.

Feedstock recycling describes the de-polymerisation of plastics into their chemical constituents [Hopewell et al.,
2019]. Following the definition of the European Waste Framework Directive, energy recovery (sometimes called
energy recycling) is not a recycling process.

Recycling means any recovery operation by which waste materials are reprocessed into products, materials
or substances, whether for their original or other purposes. There are two main types of recycling: material
recycling describes recycling processes in which waste is mechanically reprocessed into a product with
equivalent or lower properties. Feedstock recycling refers to recycling processes in which the material is
transformed into its original building blocks.
Recycling includes the reprocessing of organic material but does not include energy recovery. As recycling
is not possible for all plastics waste, energy recovery is still a suitable and appropriate waste treatment.
form for many plastics waste items.

2. Plastic Waste Management Practices


Kenya Plastic Action Plan 15

Recycling plastic polymers is highly dependent on the purity of the waste polymer fractions. Purity refers to the
presence of contaminants from other waste materials and other polymer types as many plastic polymers are
not suited to creating recyclates.

Recycling plastics is also emphasised in the EU as a crucial part of its circular economy strategy, which is why
the plastic sector and the usage of recyclates fulfil a central role in the transition towards a circular economy.
Increasing recyclate usage is rather a ‘quality instead of quantity’ problem, as the two central problems identified
are the

i) difficulty to meet the required quality and
ii) difficulty to have a consistent, reliable supply of high-quality recyclates [EuPC, 2017].

From a circular economy perspective, plastic recycling is recognised as a key concept. However, due to quality
problems, it is not yet used to its fullest potential. To overcome this challenge, suitable collection and recycling
infrastructure, incentives as well as suitable legal and regulatory frames are needed.

2.3 The Circular Economy Concept

2.3.1 Introduction
The ’circular economy’ is a theoretical concept that stands in contrast to currently dominating practices that are
described as ‘linear economy’. Contrary to the traditional model in which resources are extracted, processed,
distributed, consumed, and eventually disposed, the circular economy concept advocates a circulation of resources
within the economic system. Instead of disposing of waste, it is reintroduced as a resource into the processing
stage, thereby closing the loop. Thus, in a circular economy the material remains circulating within the system
[Ghisellini et al., 2015; Wilts, 2016]. According to the Ellen Macarthur Foundation “a circular economy is based
on the principles of designing out waste and pollution, keeping products and materials in use, and regenerating
natural systems” [EMF, 2017a]. Applying elements of the circular economy offers solutions to the current improper
plastic waste management and the associated negative externalities.

Due to this circulating character, the circular economy offers a more efficient resource use, which has economic,
environmental, and social benefits. The circular economy concept is based on three overarching principles: reduce,
reuse, and recycle [Ghisellini et al., 2015; Wilts, 2016]. As the name implies, the reduction principle pursues the
maximum reduction of raw material and energy demand. It aims to minimize waste during production processes
as well as waste incurring at the point of consumption. The reuse principle describes how products or components
of products that are not waste should be reused again, or – if they have turned into waste – should be prepared
for reuse [Ghisellini et al., 2015].

If a plastics product or good is truly recyclable is eventually determined by two criteria: the compositional
quality of the object and the real recycling options after usage. In practice, recycling is only possible if
there is corresponding, appropriate infrastructure. Otherwise, the product or packaging is only “ready
for recycling”. To turn it into a recyclable product or packaging, a comprehensive expansion and further
development of collection systems and recycling processes are prerequisites – defining general requirements
for a product design. These processes aim at enabling the product to be recycled after use.

The circular economy is defined as an economic model within which resources like plastics are used
in a more efficient manner through the three guiding principles of reduce, reuse and recycle to close
the loop. Shifting to such a system has economic as well as social and environmental benefits through
reduced import dependence, employment creation, reduced litter, less resource extraction and improved
human health. Putting the circular economy principle into practice requires measures, which need to be
taken at all level of the supply chain. Thus, a good collaboration among the different stakeholder to align
measures is crucial.


Kenya Plastic Action Plan 16

This offers especially environmental benefits as it decreases the resource demand and in most cases also the
energy demand since the product is not newly manufactured [Castellani et al., 2015]. The last principle, the recycle
principle, refers to any process in which waste is recovered through reprocessing the material or its chemical
constituents, thereby making it available for new manufacturing processes [Ghisellini et al., 2015, Hopewell et
al., 2009].

Taking circular economy concepts into consideration has important
implications for all steps of the product value chain. The respective
measures cover a broader field than just waste management and are
operationalised at different scales – ideally done in a complementary
fashion (Figure 6). However, this is usually not the case: most
initiatives, despite often being promising, remain fragmented and
measures across scales are often poorly aligned with each other
[WEF, 2016].

Figure 6: Circular economy conceptualisation

Shifting towards circular economy
concepts creates more revenue and
thereby also more jobs in fields of
designing circular products, collecting
and sorting, all crucial for reusing and
recycling. This requires both high-
skilled as well as low-skilled labour.

2. Plastic Waste Management Practices


Kenya Plastic Action Plan 17

2.3.2 Plastics in a Circular Economy
As mentioned, plastics as material have become a ubiquitous part
or our daily life due to their versatility. However, since littered
plastics waste has also become pervasive in our environment, great
concerns and discussions about the multiple negative impacts of
the improperly managed and littered plastics waste have arisen
globally. Shifting towards a circular economy as a response to this
current situation would focus on closing the loop by increasing the
amount of plastics that are recycled.

Putting this into practice requires multiple measures which need to be taken at all steps along the plastics value
chain and adopted by multiple actors, for instance Extended Producer Responsibility (EPR) schemes, product
designs for enhanced recycling, a well-developed recycling infrastructure, appropriate end-of-life options as
well as waste segregation.

Moreover, implementing the circular economy for plastic waste opens the door to increased revenues and
employment creation:
• The global plastics recycling market value equalled US$ 31 billion in 2015 and is expected to reach US$ 57

billion worldwide by 2024 [TMR, 2017]. This is estimated to be approx. 8 % of the total plastic market volume,
which is expected to be worth US$ 654 billion by 2020, and US$ 721 billion by 2025 (Figure 7) [Grand View
Research, 2019a].

• The plastic-to-fuel market is expected to grow significantly in the next years as a response to rising energy
demands. Processing waste plastic would offer a suitable solution to respond to the need for fuel while
processing the increasing quantities of plastic waste; releasing pressure from the depletion of natural
resources [Grand View Research, n.y.].

• In 2018, the global PET recycling market stood at US$ 7 billion and its compound annual growth rate is estimated
to be 7.4 % until 2025, resulting in a value of US$ 11 billion. The increasing consumer awareness regarding
environmental sustainability is a key driver together with the increase of landfill bans worldwide. Demand
for recycled PET is created by several industries
such as the textiles industry, consumer goods,
automobiles and food and beverage packaging
[Grand View Research, 2019b].

Hence, incorporating circular economy concepts will
generate more revenue and thereby more jobs in the
fields of designing circular products, collecting and
sorting; all of which are crucial factors for reusing
and recycling. This requires high-skilled as well as
low-skilled labour.

Reducing the overall amount of
plastics used while increasing the
reuse and recycling of the generated
plastic quantities are the key elements
for transitioning the plastics economy
into a circular one.


Figure 7:

Expected development of the plastic and plastic
recycling market


Kenya Plastic Action Plan 18

2.3.3 Global Circular Economy Examples
Worldwide, several countries have initiated shifts towards a circular economy to address their waste situation.
While their approaches have several similarities, they also exhibit noticeable differences due to the different
conditions present in the respective country.

To push circular economy also on a global scale, there are several global commitments driven by both governments
as well as private sector initiatives to transit to a waste-free circular plastics economy. More detail on these
global practices is presented in annex 8.5.

Belgium
In Belgium, waste management is a devolved responsibility which is organised at the regional level, putting the
three regions Flanders, Wallonia, and Brussels-Capital in charge. In 1996, to ensure a comprehensive packaging
waste collection system and a respective EPR system, the three regions jointly agreed on a nationwide packaging
law to establish a strong, legal basis. Since then, Belgium has developed an extensive collection system across
the country, which is reflected in the high recycling and recovery rates of Belgium, among the highest in the
whole European Union (EU) [Eurostat, 2019].

Additionally, to increase recycling rates, Belgium is addressing the issue of a better waste prevention by developing
comprehensive plastics waste strategies that contain dedicated policy instruments for waste prevention [EEA,
2019].

The Producer Responsibility Organization (PRO) of the Belgian EPR
system is called Fost Plus; it operates as a non-profit organisation.
Fost Plus was founded in Belgium as a voluntary initiative of the
private sector. Although there are no competitive restrictions,
only one PRO has been created so far. Thus, Fost Plus enjoys an
operational monopoly. It comprises approximately 5,000 members,
each paying participation fees. Today, there is a packaging law that
compels every company putting more than 300 kg of household
packaging annually on to the Belgian market (for consumption
in Belgium) effectively to become members of Fost Plus. Each of
these companies is obliged to pay for the collection, sorting, and
recycling of packaging that is brought into the market. Fost Plus is
responsible for all packaging sales according to specific definitions
and publishes a respective criteria catalogue. Fast food packaging
and packaging from online sales also fall under this. Aside from the
funding of waste management, Fost Plus uses 10 % of its annual
budget for education and awareness campaigns focusing on litter.

The results of this system are good in terms of collection, sorting and recycling. However, mixed plastics and foils
are not collected within this system throughout most of Belgium. From 2022 onwards, it is planned to expand
the system to cover all other packaging materials. By 2022, 90 % of beverage packaging waste generated
in the region of Flanders is meant to be collected and recycled. As the next step, by 2023, 65 % of all plastic
packaging waste is set to be recycled. By 2030, the government aims to raise the recycling rate to 70 % of all
plastics packaging waste. These quantitative targets are laid down in the agreement with the sector [EEA, 2019].

From a circular economy perspective,
the Belgian system is overall running
well. The Belgian system started with
only separately collected valuables
like plastic containers and bottles
beside metals. Other packaging like
flexibles, films and mixed plastics
were collected together with mixed
municipal solid waste for later
incineration.
Due to the increase of recycling
quotas set by the EU, Belgium is now
expanding its separate collection to
all packaging for subsequent sorting.
and recycling.

2. Plastic Waste Management Practices


Kenya Plastic Action Plan 19

Denmark
In January 2018, the EU introduced its European strategy for plastics
including goals to make all plastics packaging recyclable by 2030, to
reduce single-use plastics where applicable and to restrict intentional
use of micro-plastics. Moreover, binding regulations are planned
which oblige manufacturers to use a certain amount of recyclates
in their products and obliges Member States to recycle 50 % of
their plastic packaging by 2025 and 55 % by 2030.

The current waste management system in Denmark has a
comprehensive waste collection infrastructure. However, according
to a study by the Danish Ministry of Environment and Food [2018],
the majority of this waste, 63 %, is incinerated while only 36 % of
all plastics and only 18 % of all plastics packaging are recycled. Thus, the Danish government introduced their
new strategy to transition to a more circular economy and meet the goals set by the EU plastics strategy. In their
Action Plan (Figure 8), the Danish government portrays a holistic approach with measures all across the value
chain. In particular, they highlight six focus areas and 27 reinforcing action measures in order to transition into
a more sustainable, more circular economy. The six focus areas are:

• To strengthen enterprises as a driving force for circular transition
• To support the circular economy through data and digitalisation
• To promote circular economy through design
• To change consumption patterns through circular economy
• To create a proper functioning market for waste and recycled materials
• To increase recycling of material used in buildings and biomass

All stakeholders in the value chain of plastic packaging are included
in these actions. To increase recycling of plastics from households,
a standardised waste collection is planned, as well as a mandatory
EPR system. Also, better plastics waste handling is part of the goal
to transition into a more circular economy. Danish companies are
encouraged to develop sustainable plastics solutions for design,
reuse, recycling, circular business models and recycling technology.

VEmbracing a more circular approach also offers great economic
benefits as it is estimated that for every 1,000 mt of recycled plastic
waste (which are not incinerated), three to four jobs are created
along with additional revenue of 6 million Danish kroner (equalling
approx. US$ 900,000). The Danish government has set aside EUR
16 million to implement these initiatives [MFVM, 2018].

Despite extensive waste management
frameworks in place, the majority
of Danish municipal waste is still
incinerated. In Denmark, it is assumed
that per 1,000 metres of recycled
– not incinerated – plastic waste,
three to four permanent jobs and
an economic value of roughly US$
900,000 can be created.

Figure 8: The Danish Plastic Action Plan


Kenya Plastic Action Plan 20

Chile
Pushed by an OECD report of 2016 that listed Chile alongside Turkey at the lowest end of OECD member states
with regard to recycling quotas, the country has initiated a change towards a circular economy through several
measures. One of the key factors driving this change is the establishment of a sound legal basis: in 2016, a long-
awaited waste management law entered the congress and has been officially passed as the ‘Waste Management,
Extended Producer Responsibility and Recycling Incentives Bill’ [Ley N°20.920, 2016].

This bill defined clear goals and requirements for several circular economy-based measures. As a central part of
the law, Extended Producer Responsibility (EPR) systems for six product categories are defined: tires, packaging,
lubricant oils, waste electrical and electronic equipment (WEEE), automotive batteries, and portable batteries.

Through this law, an instrument for producer responsibility was created, obliging the producers of these product
categories to create Producer Responsibility Organisations (PROs) or deliver proof of take-back. A corresponding
producer register has already been established. This law will gradually start to come into effect, as the specific
regulations and targets (collection and recovery rates) are defined and published in the present and coming years
[dated June 2019] to tailor them to local conditions. Moreover, most of the Chilean population lives in urban
areas, while vast parts of the rural areas are only scarcely populated. As a response to this, waste segregation
and collection of the recyclables will first be introduced in urban centres and then gradually expanded to other
areas. The advantage of this approach is that the first quantities will already be collected while the necessary
infrastructure, like accessible roads, will be built later.

As another key factor, the law considers the inclusion of the informal recycling sector, mainly waste pickers,
through a formalisation as accredited waste operators once they obtain the corresponding certification [Ley
N°20.920, 2016]. Collection and recycling have to be tendered separately and informal recyclers and municipalities
are treated with preference by the PRO. Through including and formalising the informal sector, Chile chose an
inclusive approach rather than taking away the livelihood of the workers, which reflects the social dimension of
the circular economy approach [Ministerio del Medio Ambiente, 2019].

Comparing these three countries, it appears that the following are requirements for success:

• Sound legal basis
• Holistic approach with measures all across the value chain
• Inclusive approach which integrates all actors (including the informal sector)
• Focus on comprehensive and extensive waste collection and sorting to increase recycling
• Establishment of an EPR system as a sustainable financing basis

2. Plastic Waste Management Practices


Kenya Plastic Action Plan 21

Figure 9: Waste sorting at Taka Taka

Figure 10: The Business of Taka Taka


2.3.4 African Circular Economy Examples
Complementing to the global examples, there are also examples of circular economy concepts which have been
implemented in African countries.

Kenya
TakaTaka Solutions is one of the prominent examples of companies actively present in the country’s garbage
collection and recycling space in Kenya. As a leader in waste
collection in Nairobi and on a smaller scale in neighbouring cities,
it is successfully collecting and sorting waste from major waste
sources like notable hotels and malls as well as national and
international institutions (Figure 9).

To reduce the amount of waste ending up in dumpsites, TakaTaka
recycles 95 % of the waste it collects; this is partly undertaken by
themselves or, predominantly, by one of the numerous recyclers
and converters that feed sorted and pre-treated fractions from
TakaTaka into their production processes. Waste is sorted into
more than 45 fractions within their two sorting sites in Nairobi.

As part of its recycling strategy (Figure 10), the company makes
composts out of their separated organic waste, which is sold to
farmers.


Kenya Plastic Action Plan 22

Mr. Green Africa is another example of an innovative business model aiming to introduce circular economy
concepts in Kenya. The company works with informal waste collectors (pickers) by integrating them into their
value chain. The company collaborates with these informal waste pickers and accepts the collected waste at one
of 25 trading points, predominantly set up in Nairobi’s low income areas. With the use of digital applications, Mr.
Green measures and keeps a record of each of its suppliers. Through the app, the company also informs about
the rates plastic wastes are sold at, thereby assuring transparent prices paid to the suppliers. The company has
managed to build a relationship with their suppliers by giving fair and stable prices but also by offering supplier
loyalty programmes and services (see Figure 11).

Mr. Green focuses on the collection
of plastics, specifically PET bottles,
HDPE, PP as well as aluminium and
papers like cartons. The recycled
plastics are sold as flakes, both
locally and internationally. Raising
awareness plays an important
role in Mr. Green’s operational
model. Continuing their social
and environmental approach,
Mr. Green Africa partnered with
the international consumer
goods company Unilever on a
plastics recycling programme for
primary schools. The aim is to
entice children at an early age to
become environmentally conscious
and to help lead society towards
behavioural change (see Figure 12). Figure 11: The Business of Mr Green Africa

Figure 12: Awareness rising in schools

2. Plastic Waste Management Practices


Kenya Plastic Action Plan 23

Rwanda
Rwanda is a pioneer in Africa in terms of maintaining a clean environment. It is well known for its zero tolerance
policy for litter, which is still a problem in other parts of Eastern Africa.

For over ten years now, the country’s economy has been running with an active plastic bag ban in place. To
understand and learn from this example, Rwanda has:

i) Banned the use of single use plastic bags in 2008
ii) Put in place a heavy fine on the banned items
iii) Made it easy to package stuff with paper, which are available in shops and stalls
iv) Invested in education and awareness
v) Drafted a bill on the ban of all single-use plastics in the country.

Rwanda has successfully managed to promote awareness amongst
its population in environment related topics. In 2011, the Rwanda
Environment Management Authority initiated a Greening Schools
Programme [REMA, 2019]. In addition to tree planting, greening
school grounds, using improved handwashing facilities and making
children aware of the importance of the harmful effects of improper
waste management the country has managed to educate its citizens
on the importance of a clean living environment.

Within the framework of the UN Education for Sustainable Development (ESD) programme, a consortium of
two local organisations with the support of the British development agency, DFID, enhanced awareness building
around the topic of the environment through the development of Eco-School Rwanda. The aim of the Eco-Schools
project is to promote environmental education in the country starting at an early age. This is achieved by
using education to help reduce poverty levels, as well as develop environmental protection and climate change
mitigation knowledge amongst the children [Foundation Saint Dominique Savio, 2014].

Rwanda has been successfully able to keep its streets clean with help of the legal framework and heavy fines
put in place once the plastic bag ban was implemented. Rwanda has one of the stringiest and strictest fines
on this in place, which all people living in Rwanda adhere to. It ensures clean streets within and outside of the
capital Kigali and beyond.

Compliance with authority is a culture in Rwanda. Therefore, regulations put in place by government are quickly
adopted by the population. The way the citizens have adopted the policy shows that a ban can be quickly
assimilated by a country.

Early 2019, the country also drafted a law to ban all single-use plastic which, undoubtedly, will affect the industry.
If this passed as legislation, companies affected will have to adapt to this.

The country’s infrastructure still remains inadequate as the population is fast growing. There are projects to
develop further the city’s infrastructure and residential buildings. The country has an extensive programme to
construct high density buildings by 2040, by multiplying the medium rise row houses as well as the multi-storey
apartments by more than three times the number (State of the Environment and Outlook Report 2015, REMA,
2015).

Rwanda has successfully managed
to promote awareness amongst
its population in environment
related topics. As one measure, the
Rwanda Environment Management
Authority initiated a Greening Schools
Programme in 2011.


Kenya Plastic Action Plan 24

Even though streets and roads in Rwanda are clean, recycling remains a practice with an insufficient infrastructure.
Some categories of waste cannot be recycled in the country due to lack of financial and technical capacities. The
number of companies in the sector is insufficient and therefore the infrastructure is not functioning sufficiently.
Thus the recycling industry is not entirely developed.

With increase of the population in City of Kigali, there has been a rise in the amount of waste being generated
on daily basis. Solid and liquid waste (SLW) are collected from households and transported to Nduba landfill to
the tune of 300 tonnes par day and only 2 % of solid waste is recycled. The main landfill, Nduba, does not have
a waste segregation system.

Just as it is the case in many developing countries, a dumpsite constructed in Kigali is quickly filled. The city
therefore closed down its Nyanza dumpsite and is now operating the landfill [Office of The Auditor General of
State Finances, 2016].

As much as the country has an efficient way of ensuring the streets and the public environment are clean and
from free of waste, the final handling of the waste is still a challenge. Mandatory monthly street cleans are done
which in addition to the regulatory framework helps to keep the streets clean. But the sector of waste management
still needs to be improved in order to apply more circular practices in waste management.

2. Plastic Waste Management Practices


Kenya Plastic Action Plan 25

Tunisia
In 2004, Tunisia set up several systems for the collection, treatment and valorisation of certain categories of
waste, such as ECO-Lef. To foster the development of the sector, the Tunisian government encouraged the
creation of microenterprises by awarding contracts together with the municipalities.

The system was financed by an eco-tax, although it was labelled as an EPR system (for difference see chapter
5.1.1). A fee of 5 % on the net added value has to be paid for imported plastic, including empty packaging and
raw materials. For the import of already packaged goods, no tax needed to be paid.

The funds collected via the eco-taxes were (partially) used to;

• Finance the ECO-Lef system,
• Cover part of the operational fees of the municipal and hazardous waste infrastructures, and
• Cover part of the functional costs of the National Agency for Waste Management.

ECO-Lef is a public system for the recovery and recycling of packaging waste, implemented in partnership with
local authorities. It includes the collection of packaging waste and recycling of plastic waste according to the
conditions set by the National Agency for Waste Management. The Eco-Lef system covers only specific packaging
types, namely PET bottles, milk bottles made of HDPE, plastic films and bags made of PP as well as metal cans
– cardboard packaging is excluded.

The collection of recyclable materials is done by approved and authorised companies. These usually small
companies can also buy material from informal collectors, which play a major role in the recovery of recyclables
in Tunisia. In turn, the collections companies (can) sell their collected quantities to ECO-Lef; however, this is not
mandatory. Eventually, the material is sold to recyclers. Despite their great importance in the recycling system,
the informal sector is not visible in the ECO-Lef system.

After an initial success, which peaked in 2008 with collection of 15,700 mt of packaging, collection and recycling
gradually but significantly decreased to 5,400 mt of collected packaging waste in 2017. The reason of this
significant decline was rooted in the mismatch between funds generated from the eco-taxes and the actual
packaging waste quantities and the lack of adequate steering function of taxes on the actual collection and
recycling infrastructure. This was exacerbated by further structural weaknesses, as the decrease of the profitability
of certain parts of the system was diminished due to the decrease in collection activity. Further causes for the
poor outcomes include a lack proper control, complaints over the quality of the recyclers and proliferation of
non-approved recycling companies, long transport distances connected to relatively high costs, and, last but
not least, limited domestic recycling value chains.

To improve their system, the National Agency for Waste Management is currently making revisions to transform
it into an actual EPR system.


Kenya Plastic Action Plan 26

2.3.5 Alternatives to Plastics
In light of the growing wealth and consumption and therefore also increased resource demand required to meet
this growth, efficient and effective waste management has become more important than ever before and plays
a central role for nature and resource conservation.

As part of the reduction pillar of the circular economy, it is important to consider the alternatives to plastics, i.e.
the substitution of plastic material with other materials in packaging and other products. As will be described
in the following chapters, there is currently no comprehensive waste collection and treatment infrastructure
for waste in general and plastics in particular in Kenya. In light of the prevailing waste management conditions
(predominantly landfill, low recycling structure for glass and plastic, no relevant reusable systems), the use of
resources, for instance in the form of packaging, should be reduced as much as possible in order to minimize
resource losses and unorderly deposits with the associated ecological consequences.

Against this background, it is important to compare plastics vis a vis alternatives and analyse their feasibility
and impacts in regards to a multitude of impact categories. Such a comparison and analysis has been done as
part of the research and is presented in annex 8.9. In particular:

• carbon emissions (expressed through the global warming potential (GWP)) and water footprint as ecological
indicators

• health, safety, collection and recycling situation as economic indicators

These comparisons are based on Life Cycle Analyses, which compared different material solutions for the same
purpose at item level. Life Cycle Analysis (LCA) is a technique to assess the environmental impact associated with
all the stages of a product’s lifespan (from raw material extraction through materials processing, manufacture,
distribution, use, repair and maintenance, to disposal or recycling). In doing so, the prevailing framework
conditions in each case are considered. LCAs indicate the product’s impact regarding climate change or global
warming potential, acidification, photo-oxidant formation, ozone depletion potential, terrestrial eutrophication,
aquatic eutrophication1, particulate matter, total primary energy, non-renewable primary energy, use of nature,
water use (related to water input).

Generally, it is not possible to derive a general rule stating that a specific alternative is better than plastics; as such
a statement is always item-specific and dependent on a multitude of contextual factors such as the availability
of a proper waste management system. Thus, from a resource conservation point of view, the development
of an orderly and comprehensive recycling structure is the preferred alternative to simple substitution. In the
foreseeable future, substitution will largely not be able to replace the specific and for many purposes favourable
attributes of plastics.

1Aquatic eutrophication describes the process when an aquatic body becomes over-enriched in nutrients, which causes
excessive algal blooms, potentially leading to oxygen depletion and a shift in species composition often associated to
detrimental effects on the aquatic ecosystem [Chislock et al., 2013]. Terrestrial eutrophication is based on a similar
process and outcomes, although the enrichment of nutrients caused by air pollution [EEA, 2018].

2. Plastic Waste Management Practices


Kenya Plastic Action Plan 27

2.4 Kenyan Plastic Mass Flow

2.4.1 Quantification of plastic volumes
To quantify the flow of the various polymer types in Kenya, the
finished goods import, use and export, as well as the per capita
consumption in Kenya, the plastics material flow at every step of the
value chain have to be verified. The approach (Figure 13) considers
that plastic material is introduced in Kenya either through;

i) imported raw material for plastic packaging (raw material for resins and plastic resins),
ii) imported packaging material as well as plastic goods, or already as
iii) waste material

Within Kenya, the raw material for plastics is converted into plastic packaging and plastic products, which –
together with the imported packaging and products – are sold to companies and/or consumers and eventually
become waste. This waste is subsequently prepared for reuse, recycled, disposed of or dumped through formal
and informal channels, or potentially even exported to other countries. Other possibilities for material outflow
of the country are through the export of plastic packaging and plastic products to other countries as well as the
export of raw materials.

The researchers conducted a mass
flow analysis by combining:
modelling of national data sets
on plastics and plastic packaging
consumption from 2016 inflated to
2017 with a survey of Kenyan recyclers
regarding the quantities of recycled
plastics and plastic packaging waste.

Figure 13: Mass flow of plastics material within Kenya


Kenya Plastic Action Plan 28

To identify the flow of plastic material at every step of the plastics value chain, an online survey (see annex 8.7)
was conducted via KAM with relevant actors from all steps along the value chain. In this survey, the interviewees
were asked to indicate their activities in relation to plastic use and fractions according to the seven, internationally
coded fractions (see annex 8.2), the respective volumes purchased and potential challenges they face.

This is complemented by insights derived from the key informant interviews conducted for the Kenya Plastic
Action Plan’s research.

The results of the online questionnaires have been compared and complemented with results of previous studies
conducted in this field to increase the accuracy of conclusions. In particular, two studies were used. The first
was a study undertaken by Eunomia [2018] which identified the quantity of plastic packaging waste annually
generated in Kenya. Eunomia’s research is based on the assumption that the quantity of plastic packaging put
on the market equals the quantity of waste generated, due to the very short in-use phase of packaging. However,
it has to be considered that this assumption is not fully accurate in the Kenyan context. An important share of
packaging is reused either for the same purpose or for a different one. Thus, the in-use phase is prolonged. The
main research method is interviews of different stakeholders in the value chain. The numbers presented as results
can therefore rather be considered estimates. The second important study considered here was undertaken by
Ipsos [2019] with focus on PET bottles: within the course of the market assessment, a mass flow analysis of PET
material in Kenya was also conducted, based on data from 2017.

Import of plastics
Although Kenya possesses crude oil, there are no plans to set up a refinery in Kenya in the foreseeable future.
Domestic crude oil is therefore not (yet) used for the generation of plastic material, i.e. every plastic material
and/ or product must have been imported to Kenya at some point (including imported as resins and raw material
for resins). This assumption matches with the approach of the other studies [Eunomia, 2018; Ipsos, 2019]. Thus,
quantifying this interface is the most relevant one.

According to Eunomia [2018], an estimated 567,000 mt of primary
and non-primary plastics was imported into Kenya in 2017. The Ipsos-
study reports 453,781 mt of imported primary plastics in the same
year (and 469,400 mt in 2016). Due to the lack of primary plastic
production, it is assumed that this number consists of both primary
plastics in the form of granulates, resins, etc. and processed plastics
in the form of film, empty containers and other plastics products. In
2017, the plastic industry processed around 240,000 mt of primary
plastics with the balance, roughly half the total imported volumes, and assumed to be pre-processed plastics.
The import of plastics in the form of already packed goods is, however, not accounted for [Ipsos, 2019]. Although
the numbers of the two studies are not fully congruent, they are generally close to each other indicating a scale
of 450,000 to 570,000 mt of primary and non-primary plastic imports for 2017. The differences are based on
the different nature of the data, as one is an estimated value, based on the previous year’s data and previous
developments. Moreover, it also shows the uncertainty of the market with reliable data difficult to obtain. Putting
into perspective that Eunomia also includes packed/made products in its estimates, representing around 20 %
of all goods consumed in Kenya, the gap shrinks – making both assumptions quite congruent.

The main countries from which the material is imported are China, India and the United Arab Emirates. For
instance, 86 % of imported PET originates from China and India alone [Ipsos, 2019].

2. Plastic Waste Management Practices

The numbers on imported plastics
of the two reviewed studies are not
fully congruent, but they are generally
close to each other indicating a scale
of 450,000 to 570,000 mt of primary
and non-primary plastics for 2017.


Kenya Plastic Action Plan 29

The interviews revealed that sorted plastics fractions are also occasionally imported, for instance from Uganda or
Tanzania, to be recycled in Kenya as the prices for waste material are significantly cheaper in these neighbouring
countries [Kenya Plastic Action Plan Interviews, 2019]. These amounts seem to be relatively negligible in comparison
to the domestic volume flows, altough no exact quantities could be assessed. Another aspect, which could not be
assessed, was the illegal import of plastics in any form. Thus, the magnitude of this remains widely unquantified.

Domestic processing of plastics and production of packaging
As the domestic production of plastics material and products is dependent on the import of the required raw
materials, the material flows from the previous step to this one are inevitably interlinked and hence serve as an
important verification of the mass flow.

As briefly mentioned in the previous section, the domestic production
of plastics material is non-existent; the import therefore covers the
whole demand. Around half (equalling 240,000 mt) of total plastics
imports are processed domestically. These locally processed plastics
have to compete with oftentimes cheaper prices from China, India
and the UAE, for example [Ipsos, 2019]. The results of the online
survey display, particularly raw material for LDPE, HDPE and PP
is imported, while the quantities for PVC and PS are only of minor
importance – which is also reflected in their low recycling numbers
(see below ‘Waste management and recycling’).

In Kenya, the domestic packaging, supposedly linked to domestic production, is significantly higher than the
import of packed/ made goods. According to Eunomia [2018], around four fifths of packaging materials’ volume
is used locally from imported packaging, imported virgin material (processed into packaging domestically) and,
to a lesser extent, domestically recycled materials. Only around a fifth of packaging is imported in the form
of packed/made products. The Kenyan private sector comprises a diversified structure of both locally grown
and multinational consumer goods companies that serve Kenya and surrounding markets with a wide range
of products. With production and packaging operations on site, they together represent the clear majority of
packaging material consumed in Kenya [Kenya Plastic Action Plan Interviews, 2019].

Export
Just as the with the import group, this group is an umbrella for three different forms of export: the export of raw
materials (both made virgin materials as well as recyclates as secondary material), export of plastic products
including packaging, and the export of waste. Regarding the export
of raw materials, Eunomia [2018] reported that 4,691 mt of recycled
plastics have been exported. Exported plastic products are estimated
at 51,000 mt for 2017 [Eunomia, 2018; Ipsos, 2019], although the
primary source of export data does not clearly indicate if the volume
of all packaged products and plastic goods is included in this number.
Information about exports of plastic waste could not be identified.

Around 80 % of packaging materials
volume is used locally from imported
packaging, imported virgin material
processed into packaging domestically
and domestically recycled materials.

The numbers on imported plastics
of the two reviewed studies are not
fully congruent, but they are generally
close to each other indicating a scale
of 450,000 to 570,000 mt of primary
and non-primary plastics for 2017.


Kenya Plastic Action Plan 30

Waste management: recycling quota
To analyse the quantities of the plastic fractions which have been consumed in Kenya, the export quantities of
exported raw materials (only primary, not secondary) and exported products are deducted from the quantities
of plastics introduced on the market (either imported or produced locally).

As presented by the Eunomia study, a total of 36,193 mt of plastic waste were recycled in 2017(see Table
1), meaning processing plastic waste through washing, flaking, shredding, grinding, pelletizing and/ or using
recycled plastics in the production of new products. The volume forwarded to recyclers was higher at 42,950
mt, indicating that only parts of the recovered materials met the criteria for recycling [Eunomia, 2018]. The
amount of plastic packaging recycled was 23,006 mt. The remainder, 13,907 mt, was therefore sourced from
plastics applied for different purposes. Whereas practically all PET recycled in Kenya is derived from packaging,
significant percentages of other recycled fractions HDPE, PP and LDPE were originally not used for product
packaging. Differentiated according to the seven plastic fractions, the numbers are as follows:

Table 1 : Quantities of recycled plastics and plastic packaging acc. to fraction in 2017 [Eunomia, 2018]

Plastic waste forwarded to
recyclers (mt / year)

Amount of plastics
recycled (mt / year)

Amount of plastic packaging
recycled (mt / year)

PET

Specific data not available

5,778 5,778

HDPE 10,943 4,407

PVC 177 0

LDPE 8,091 4,998

PP 6,806 4,873

PS 0 0

Others 4,398 2,950

Total 42,950 36,193 23,006

Reflecting on all steps of the mass flow and the plastics consumption in Kenya, it becomes visible that the
recycling capacities regarding the different plastic fractions vary significantly: On the one hand, this is related
to the difference of the in-use phases based on the sectoral uses, as explained in the previous chapter; some
fractions, for instance, are utilized for longer periods, e.g. in construction. They are therefore not counted as
waste yet. On the other hand, it is also based on the differently developed recycling capacities currently existing
in Kenya; for instance, no PS recycling infrastructure has been identified, indicating just one gap in closing the
recycling loop.

Overall, the quota for recycled plastics equals 7 % according to the data of the Eunomia study [2018]
coupled with export data from the Ipsos Study [2019]. Putting these two sources together, the assumption for
the recycling quota is based on the following calculation:

The underlying data shows certain amounts of uncertainty. Therefore, utilizing alternative input numbers, the
resulting recycling quota varies. Nevertheless, even taking into account different data sources, it is safe to say
that the recycling quota for plastics in Kenya stands at less than 10 %.

36,193mt plastics recycled

(567,000 mt plastics imported - 51,000mt plastic products exported

2. Plastic Waste Management Practices


Kenya Plastic Action Plan 31

However, different to the above, the quota can also be estimated by
analysing the generated waste. According to the World Bank [2018],
every Kenyan generates 0.39 kg of waste per day. The portion of
plastic has not been evaluated for the whole country. For Nairobi,
the percentage ranges from 9 % for low income over 12 % for middle
income to 15% for high income households; 11.8 % for the whole of
Nairobi [UN Habitat 2019]. Data obtained by JICA [2010] assumes
the portion of plastic at the lower end of this, with 9.5 % of the total municipal solid waste volume.

Taking a total population of approx. 50.2 million inhabitants in 2017 [World Bank, 2019] into account of which
each person generates 0.39 kg municipal solid waste per day [World Bank, 2018], the equation comes to a total
of almost 20,000 mt of waste generated daily; and around 7 million mt annually. Utilizing data from Nairobi
that 11.8 % of the municipal waste streams are composed of plastics [UN Habitat, 2019], around 820,000 mt of
plastic waste are generated annually in Kenya. This estimate is significantly higher than the one from Eunomia
[2018]; amounts of imported plastics are supposed to be higher using this method. The overall plastics recycling
rate would thus be significantly lower.

Closing the gap related to recycling and a circular economy depends on several contextual factors such as
current waste management practices, recycling possibilities and demand for recyclates as well as the political
and legal framework.

Waste Management in Kenya
Kenya counts a population of around 50 million people. The metropolitan area around the capital Nairobi mainly
includes neighbouring counties Kiambu and Machakos and comprises a population of up to six million people; the
city Nairobi itself houses around 4.6 million inhabitants [UN Habitat, 2019]. The second biggest city, Mombasa,
counts more than one million inhabitants and forms another major economic and logistical hub, particularly
apparent in its role as the main harbour for several countries in East Africa. Other economic centres like Kisumu,
Eldoret and Nakuru exist in the more densely inhabited highlands towards the Western and Central parts of the
country. Especially in the agriculturally productive highlands and a narrow stretch of the coastline, population
density is quite high even in rural areas, while particularly northern and eastern parts of the country, towards
the borders of South Sudan, Ethiopia and Somalia, are scarcely populated.
Kenya’s characteristics as a rapidly developing country are also present in the waste generation data. On average,
0.39 kg of waste per capita occur daily, compared to 2.7 kg per capita in Germany [World Bank, 2018; OECD, 2017].

In the Greater Nairobi areas, Kenya’s political and economic hub, 3,000 mt or 0.64 kg per capita of municipal
waste occur daily from residential areas, industry and other private companies as well as public institutions [UN
Habitat 2019], a slight increase since the estimates by JICA [2010]. All in all, the waste is mainly organic compost
plus minor amounts of glass, paper, metal and others. According to JICA [2010], plastic fractions account for
9.5 %. Recent data collection carried out by UN Habitat [2019] assumes plastic content in a range of 9 % to 15
%, specified as per different income levels in Nairobi; countrywide data is not available. Lower income areas

count relatively lower volumes of plastics on the one hand. On the
other, high income areas account for the highest volumes of plastics.
Middle income areas are, by far, the most relevant areas in terms
of absolute volume of plastics in municipal solid waste. Due to its
function as the economic and political hub, a significant number of
Kenya’s high-income areas are concentrated in Nairobi.

Putting all these findings together, plastics account for the largest share of municipal solid waste after organic
waste and paper. These volumes predominantly originate from plastic packaging including traded and locally
manufactured goods [Eunomia, 2018].

Estimates for plastics used in
Kenya range from around 500,000
to 800,000 mt per year. Less than
10 % of these plastics are currently
recycled.

Roughly a tenth of municipal waste
volume in Kenya comes from plastics,
mainly packaging material.


Kenya Plastic Action Plan 32

organic waste;
66,0%

paper; 12,0%

plastics; 9,5%

rubber, leather, textile;
2,5%

glass; 1,5% metals; 1,5% Other; 7,0%

2.4.2 Collection Systems
The public sector as a stakeholder steers the general direction of Kenya’s waste management in strategies and
actions plans. Institutions like the National Environmental Management Authority (NEMA) issue licences for
operation in the field. Additionally, some rules and regulations are set by the County Governments, which are
responsible for executing national law by implementing waste management infrastructure accordingly [GoK,
County Government Act, 2012]. A detailed overview of relevant legislation and the institutional framework is
provided in chapter 3.

Within its legal boundaries, Nairobi City County Government is in
charge of collecting waste effectively. However, inefficient public
services led to the rise of a dominant informal stakeholder group
ranging from waste pickers (also called scavengers), collectors and
sorters to recyclers [UNEP, 2015]. Private collection, segregation and
recycling happen without restrictions, based on an open competition
of buyers and sellers, and is a largely cash-based economy [UNEP, 2015]. Waste collection undertaken by the
informal sector also plays a major to dominant role in all other Counties of Kenya, though the respective levels
may vary [Kenya Plastic Action Plan Interviews, 2019]. Collection systems, run officially in some Counties by the
public or private sector, are nevertheless shown to have many irregularities or are simply non-existent, hence
country-wide data is only limited or not available at all [Kenya Plastic Action Plan interviews, 2019].

Figure 14: Composition of waste generated in Nairobi [JICA, 2010]

In Nairobi, economic activities
and services relating to waste
management are mainly undertaken
by the informal sector.

2. Plastic Waste Management Practices


Kenya Plastic Action Plan 33

Thus, systematic waste management infrastructure is lacking. A recently undertaken study by UN Habitat [2019]
estimates that around 75 % of Nairobi’s waste volume is collected in a matter that could be described as ‘limited’
at best. The remaining roughly 25 % of waste volume ends up being dumped in the rivers or the respective
neighbourhoods or self-treated, i.e. incinerated on site [JICA, 2010].

To the contrary, some professionals in the waste management value chain assume total collection rates of only
around 25 % to be more realistic [Kenya Plastic Action Plan Interviews, 2019]. About 75 % of residential waste
is collected in high-income areas, whereas it is respectively lower with declining income. A general observation,
confirmed in both studies, is that collection rates are significantly higher in high-income areas; with the reverse
being true in low income areas. UN Habitat [2019] assumes a collection rate of 100 % in high-income areas,
referring to 13 % of Nairobi’s population. The collection rate is estimated at 66 % in both medium- and low-
income areas, representing around 35 and 52 % of the total population, respectively.

At generation of ‘domestic’ source, mainly households but also
public and private offices, waste is usually not segregated. The same
is true for waste from streets and public areas where it is literally
picked; hence the informal part of street collection does not clean
the environment but results in the collection of valuable waste only. In general, if collected, waste is transported
in a mixed collection lorry. During transport, casual waste workers segregate materials and pick out items that
seem of value for the subsequent recycling chain. When reaching a dumpsite, some resalable items like metal,
rigid plastics, PET bottles and glass have been put aside. According to UN Habitat [2019], the respective recovery
rate before reaching a dumpsite stands at slightly more than 20 % of the total waste volume or slightly less
than 30 % of the collected volume. After this first segregation on the collection lorry, waste pickers further sort
out materials at the dumpsite. Particularly on the dumpsite, the health of workers, the surrounding population
as well as the environment in proximity and downstream of the water bodies is adversely affected. Both on the
collection lorry and on the dumpsite, sorting capacities are limited. This is mainly due to lacking segregation
at source and declining value of dirty and moist materials [JICA, 2010; Kenya Plastic Action Plan interviews,
2019]. These secondary recovery activities at the dumpsite barely cover 1 % of Nairobi’s total waste, or around
2.5 % of the waste volume that has reached a dumpsite, i.e. roughly 97. 5% of the waste volume offloaded at a
dumpsite will never be recovered [UN Habitat 2019].

Putting these numbers into proportion: In Nairobi, around 3,000 mt of municipal waste occurs daily. 2,250 mt
of these are collected, 750 mt are directly disposed into rivers or burnt on site. 640 mt of the total waste are
recovered either before or on the collection truck and another 40 mt from the dumpsite, out of a total volume
of almost 3,000 mt. The recycling rate of municipal solid waste in Nairobi can therefore be assumed at around
22 % of the total waste or 30 % of the collected waste volumes.

Aside from the above mentioned “domestic” waste (including private and public offices), waste is also generated
on a more industrial scale, usually by private enterprises. Some manufacturing industries organize their own
waste management by either contracting private companies to collect – whereby the further treatment is
usually unknown – or by managing it internally. Small scale baling, shredding and recycling is common to move
production waste back into the loop as raw materials or to sell it to (usually small scale) companies that resell
it for secondary use. To a limited extent, incineration is practised as well; particularly in the case of hazardous
waste. Some industrial steam boilers have the capacity to burn plastics as a by-product and one pyrolysis plant
exists, however both business models are not realized at scale and are operating only as pilots yet.


Waste segregation at generation of
source is generally absent in Kenya.


Kenya Plastic Action Plan 34

Some companies prove to be especially innovative as they expand to different markets and products, based
on their by-product; hence closing materials loop within own operations. The general observation is that the
manufacturing sector has applied proper solid waste management practices in its production processes by
feeding back most fractions into the production processes and selling remaining fractions to secondary users/
recyclers. [Kenya Plastic Action Plan interviews, 2019].

2.4.3 Recycling Infrastructure
Recycling infrastructure in Kenya is composed of private companies
that access waste through market mechanisms and subsequently
convert it into secondary materials that can then be fed into new
production processes/be used for a new purpose. Materials that are
recovered by waste collectors, including waste pickers, are usually
sold to a waste recycler. After undertaking some material processing
steps, depending on the material and including processes like e.g.
sorting, washing, shredding, etc., the segregation at the recycling
yard is usually undertaken by hand, enabled by relatively cheap
cost of labour.

The secondary resources are then resold to material converters that produce new products. Converters are part
of the recycling value chain but are usually not regarded as recyclers themselves. The whole picture, nevertheless,
also consists of many companies whose business areas overlap into several parts of this recycling value chain.

Organic Material
With around two thirds of the volume, organic matter accounts for the vast majority of municipal solid waste
in Kenya. Composting for organic waste is undertaken usually on a small scale and rather for agricultural and
horticultural waste, whereas only one industrial composting facility exists in the country, in Nairobi. Particularly
in urban areas, most of the collected organic waste is disposed on dumpsites. Some of the organic waste is fit for
animal consumption and especially pigs are fed and bred both in rural areas and in the proximity of dumpsites.
Especially pork that is produced in the surrounding of dumpsites is deemed as potentially contaminated and
only limitedly suitable for human consumption.

Rigid plastic recycling (like recycling
of PE bottles, PP cups or PET bottles)
is common with a large number of
small-scale recyclers throughout
Kenya. In bigger economic hubs,
recycling infrastructure for HDPE and
PP is in place; other areas are yet to
attract recycling businesses.

2. Plastic Waste Management Practices


Kenya Plastic Action Plan 35

Paper, Glass and Metal Recycling
For paper recycling, several processing facilities that convert waste paper into material like sanitary papers and
carton boxes form value chains that recycle high percentages of waste paper, both from domestic sources and
from neighbouring countries. A fair number of paper segregators are located throughout the country, with the
converting facilities mainly concentrated in the Greater Nairobi area; one exception being a newly set-up paper
plant in Kisumu/ Western part of Kenya.

Only two companies have the capacity to properly recycle glass bottles. According to market insights, their
existing recycling capacity is barely sufficient to supply the two main existing take-back-schemes with recycled
glass; one is located in the capital Nairobi, being run by the market leading brewery. The market for secondary
glass is dominated by the second one. Based on the coast, this company buys glass waste from all over the
country. The glass recycling plant is therefore both a focal point and a bottleneck for local value chains in sorting
and aggregating glass waste. Seen from a closed-loop perspective, the limited recycling capacities for glass
connected with the supposedly high inflow of import glass result in poor recycling rates. The shredding of glass
for subsequent use as e.g. filling material in construction is a commonly exercised practice.

Due to the relatively high value and good recyclability, the scrap metal recycling value chain seems to generally
fulfil its requirements. Metal is used in relatively low quantity for packaging in Kenya, accounting for around 1.5
% of household waste in Nairobi [UN Habitat 2019]. The two main applications include beer and, already to a
lower extent, soft drink cans as well as tinned foods with both commanding relatively low market shares. There
seems no recycling facility for canned beverages operational in Kenya; recycling value chains are supposedly
directed abroad which due to its value-weight ratio seems to be a feasible practice. Packaging for tinned cans
is recycled domestically.

Plastic Recycling
Rigid plastic recycling is common with a large number of small-scale recyclers throughout various areas of Kenya.
Rigid plastic items are stable in form, e.g. PET-bottles, PP cups, plastic pipes (in contrast to flexible plastic items
such as film) and more easy to collect. For the main fractions, HDPE and PP, a recycling infrastructure converting
waste materials into flakes is in place within the bigger economic hubs and particularly in the surroundings of
bigger dumpsites. Newly urbanised areas outside the traditional towns are lagging behind. As much as local
value chains for the mentioned plastics do exist in e.g. Eldoret, Kisumu and Nakuru, other areas such as Nyeri,
Meru and Kisii, among others, have yet to attract recycling businesses and build local value chains consisting
of several recycling companies.

Figure 15: The hierarchy of the plastic waste recycling chain


Kenya Plastic Action Plan 36

Especially outside of areas with functioning recycling value chains, so-called aggregators or collectors, usually
small businesses by nature, serve as focal points for informal waste pickers. They undertake manual segregation
and subsequently send the fractions for recycling into other parts of the country. Due to logistical costs associated,
recycling happens more selectively and recovery rates are lower.

Similar to the above described practices for rigid plastics, recycling is undertaken for flexible plastics as well,
namely LDPE. Recycling rates seem to be lower and the recycling value chain counts fewer active companies,
mainly due to more logistical challenges in collecting the relatively light and unstable material.

Mechanical processes mainly include baling, shredding, washing, flaking and palletizing. The injection or blowing
into new products usually happens after the primary recycling at plastic converters; here, secondary materials
can be mixed with virgin materials to produce rigid plastics, mainly for household items, e.g. buckets, basins
and related products.

PET plastic recycling is done by a small number of companies on few locations throughout the whole country;
recycling sites have been identified in Kisumu, Nairobi and at the Coast. Recycling ratios are therefore low, also
because of economics of logistics, e.g. lack of decentralized baling facilities at points of collection in combination
with the low volume-value ratio; similar metrics are found for any LDPE (flexible) plastics. If recycled, output is
often exported for fibre production in Asia. Currently, a single project to deepen the value creation from PET
recycling is being undertaken. With newly set up infrastructure, PET is envisioned to be used for garments.
Despite scattered existing and upcoming recycling infrastructure, most PET currently ends up being dumped
[Kenya Plastic Action Plan interviews, 2019].

Recycling value chains for PVC and PS have not been identified within this assignment. Currently, these fractions
seem not to be recyclable domestically. They are, however, of less importance for packaging value chains than
the aforementioned materials. Mixed packaging materials, e.g. ‘Tetra Pak” but also other flexible material with
specific attributes, e.g. coffee or tea multilayers, lack recycling facilities. Currently, the setup of a recycling facility
converting ‘Tetra Pak’ packaging into building material is underway [Kenya Plastic Action Plan interviews, 2019].

2.4.4 Disposal Practices
The current disposal practices in Kenya are described best by initially shedding light on the characteristics of
Kenya’s biggest waste disposal site by volume, the Dandora municipal dumpsite (see Figure 16). The Dandora
dumpsite is located eight kilometres away from Nairobi city centre and spreads across an area of at least 30 acres.
It was originally designed as a temporary disposal site, but was declared an official dumpsite in the mid-1970s.
Dandora’s capacity stands at around 500,000 cubic metres. Since the year 2001, this limit has been exceeded
with 1.8 million cubic metres estimated in 2016 [JICA, 2016]. Dandora has a limited official status, dumping there
is unrestricted and all kind of industrial, agricultural, domestic and medical waste gets offloaded [UNEP, 2015]. A
2010 estimate stated that between 1,200 and 1,500 waste pickers work at Dandora, some of them independently,
others organized in still informal, often unethical structures [JICA, 2010]. According to the estimates of the local
operators, 2,000 mt of waste are disposed of at Dandora on a daily basis, while 30 to 40 mt of valuables are
picked, collected and transported out of Dandora to recyclers and converters. This corresponds mostly with the
figures from UN Habitat [2019].

Around 70 other smaller dumpsites are spread across Nairobi. None of these have an official status as a landfill
to dispose waste. In addition to dumpsites, dumping of waste on the roadside or in vacant spaces is common,
more so in low-income residential areas. Already polluted upstream by inappropriate waste disposal, Nairobi
River later flows through Dandora, causing downstream water used for domestic and agricultural purposes to
be highly contaminated [UNEP, 2015].

2. Plastic Waste Management Practices


Kenya Plastic Action Plan 37

The waste disposal practices in the second biggest city of Mombasa, with more than 1 million inhabitants, are
similarly dysfunctional. Here, the collected volume of around 800 mt of solid waste daily represents a collection
rate of around 68 % [UNEP, 2015]. Semi-formal and informal dumpsites exist throughout the whole county,
particularly in the proximity of urban areas. The problems described for Nairobi usually apply in a similar way
in all other urbanized areas, with their respective sizes always being smaller. With the potential exception of an
ongoing setup of a new dumpsite in Murang’a County (due to its distance and its size not feasible for Nairobi’s
waste), no dumpsite in Kenya is operated according to international standards for landfills.

All in all, the absence of formal waste management services, insufficient treatment facilities and unsafe dumpsites
operated in an unregulated environment bring severe societal and environmental consequences. Several
issues exist which are yet to be overcome in order to enable an effective waste management infrastructure in
organisational, logistical as well as legal terms. The current organisational structure demonstrates an improper
management, insufficient monitoring, lacking legal enforcement as well as very limited data availability. A lack
of land zoning fuels conflicts when new residential areas appear close to industry and illegal dumping spots. In
terms of the collection and transportation system, the formal and informal private sector operates in a rather
unorganised and inefficient way. Collection and transportation are usually beyond the control of the County
governments, hence so far not organisable, resulting in illegal dumping scattered throughout all areas in all
parts of the country [JICA, 2010].

Figure 16: Dandora dumpsite


Kenya Plastic Action Plan 38

2.4.5 Challenges for Plastic Recycling in the Waste Management Ecosystem

Segregation
Systematic segregation at source, i.e. mainly at the household (and office) level, would provide better recovery
rates for recyclable materials. Several factors contribute
to this finding, among them are limited awareness, lacking
infrastructure, informal waste collection services, a loose
regulatory framework and, compared to worldwide figures,
low plastic waste generation due to low consumption of
packaged goods due to low income. The high portion of
organic waste makes the recovery of valuable fractions
difficult. Additionally, due to moisture and dirt, the value of
the fractions is lowered further, affecting the economics of
segregation.

Logistics
The value of the potentially recycled material in its unprocessed form is often insufficient to cover the aggregated
costs of collection, segregation and transport, due to the low volume-value ratio. Recovered materials often have
to be transported over far distances to certain hubs to be fed into the recycling value chain; facilities for upfront
baling or shredding are missing. Only the areas around Nairobi and, to a more limited extent, Mombasa offer
possibilities to recycle all main fractions (not to speak of completely missing value chains for certain fractions)
whereas logistics have to be organised in order to ship certain fractions over large distances.

Licensing/ Regulatory Framework
The regulations and policies related to solid waste management are outlined in chapter three. As they are generally
loose, the currently biggest hurdle for the recycling value chain are licences that are required for moving waste,
i.e. secondary materials. The attributed costs and frequent time-delays in obtaining these licences damage the
economics of transporting waste. Furthermore, there is limited clarity on whether these licences apply also to
secondary resources. It is thus unclear if single fraction shipments are considered waste.

Product Design
With certain criteria taken into consideration when designing product packaging, recycling processes can be
significantly eased. Currently, some products contain an unfavourable mixture of material which lowers the
recycling value. Additives like filling chemicals, partially applied in rigid plastics, are difficult to identify for the
collector and likewise the recycler and may only be noticed by the customer of the secondary product (usually the
converter). By then, all costs within the recycling value chain have already occurred whereas no value has been
created. The change of material for a certain packaging, e.g. from HDPE to PET, can also distort the recycling
value chain as casual collectors and workers are not aware of the respective differences. For many fractions,
different colours imply different value; e.g. the recycling value for coloured PET is currently significantly lower
than the already marginal one for clear PET.

A bottler of carbonated drinks in Kenya is currently harmonizing its product design by shifting to clear PET and
utilizing PET labels. This is exemplary for a producer’s action to create more value for recyclers.

Challenges in the Recycling Value Chain:

• Segregation
• Logistics
• Licencing/ Regulatory Framework
• Product Design
• Secondary Market
• Awareness/ Education

2. Plastic Waste Management Practices


Kenya Plastic Action Plan 39

Secondary Market
The current plastic recyclers are by and large small companies processing relatively small volumes of plastics
waste, thereby usually building the transition point between the informal and formal sector. Both recyclers and,
subsequently in the value chain, the converters face a number of hindrances to scale up operations and increase
recycling. Two main factors are unpredictable and unreliable: mass flows and the quality of the input material.
The efficient utilization of fixed assets can only be assured if the input material is available. Due to the largely
informal collection and aggregation structures that are sensitive to price changes, larger-scale investments bear
a certain risk of not recovering their costs. The oftentimes low quality of input materials is rooted in rudimentary
sorting practices, unfavourable composition of fractions (e.g. through filling material or different colours) as well
as the lack of waste segregation at source (dirt, moisture). The use of recycled plastics is therefore limited to a
narrow range of applications that only require low qualities, which is why the recycling sector almost exclusively
practises “downcycling” towards end-of-life solutions. Recycled material therefore faces stiff competition with
virgin material – in regards to price, quality and availability. Thus, the vast majority of business models for the
Kenyan recycling sector are disabled at this moment. This is also proven by the low actual recycling rate.

Awareness/ Education
Awareness and Education are identified as one of the key hurdles for better waste management in Kenya.
Littering in public at a small scale or the irregular disposal of waste on a larger scale is still practiced widely and
spans multiple generations. Some programmes and activities in schools and the general public are undertaken;
drivers of those are non-profit organizations, private companies including those in the recycling value chain as
well as the public sector. Despite these numerous efforts, education on waste management lacks a clear base
in the school curricula.

Nevertheless, the current lack of a proper recycling infrastructure also creates limits for better education on
managing waste; despite some behavioural changes when it comes to littering, polluting water bodies and similar
related activities, by and large there are just no best practices in place that can possibly be undertaken currently.


Kenya Plastic Action Plan 40


Kenya Plastic Action Plan 41

Following the previous description of Kenya’s waste
management situation, the following chapter elaborates
on the underlying legal and institutional framework. The
legal analysis includes the identification of regulatory
gaps which have to be addressed to achieve a proper
waste management system. Currently, differing strategic
directions and goals are stated by a variety of policies
and plans. Looking at the overall picture, some areas
are under-, others rather overregulated.

3.1 Review of Kenyan (regional, national and county) legislation formulation on plastic
and waste management

Plans and Strategies
In 2007, Kenya’s government published a strategy that described the pathway towards developing the country
into a middle-income industrial nation by the year 2030 [GoK, Vision 2030, 2007]. This Vision 2030 recognizes
the need for a sustainable waste management system in order to handle industrialization in line with its social
pillar. The latter one claims in paragraph 5.4 to realize ‘a just and cohesive society enjoying equitable social
development in a clean and secure environment.’ In particular, the strategy calls for reducing pollution and
establishing waste management systems through economic incentives. Regulations regarding plastics bags
and hazardous products are one of its figurehead projects [AWEMAC et al., 2019]. The Big Four Agenda is the
medium-term strategy of the Vision 2030, set by the current government after its election in 2017. While the
Big Four Agenda does not state waste management and circular economy in particular, it implies the need for it
to enable its goals in regards to food, health, manufacturing and housing in coherence with the long-term vision
[GoK, Big Four Agenda, 2017].

The Third Medium Term Plan 2018-2022 (MTP III) and Green Economy Strategy and Implementation Plan 2016-2030
(GESIP) comprise specific reforms, programmes and projects for the realization of the overarching government
strategy. With regards to solid waste management, they call for separation at source as well as the establishment
of new collection infrastructure, treatment facilities and disposal sites. It is planned for new urban programs
to build these in respective areas. The goal for 2030 is a nationwide quota of 50 % for waste recovery, in the
form of recycling and composting. The implementation of extended producer responsibility (EPR) and landfill
legislation is stated within GESIP. Financial incentives to support functional markets for waste management
shall be established. This relates to the promotion of recovering and utilizing more secondary materials and
recycled products. Furthermore, the national and County Governments are obliged to enforce and monitor the
total ban of plastic bags [GoK, GESIP, 2016; GoK, MTP III, 2018]. Despite pointing out certain goals for improving

waste management practices in Kenya, the mentioned
documents remain vague in setting out implementation
measures.

The National Environment Policy requires the
development of an integrated National Waste
Management Strategy with economic incentives to entail
cleaner production, waste recovery, recycling and reuse
[GoK, 2013]. The Solid Waste Management Strategy
of the National Environment Management Authority

In Kenya, waste is defined as ‘any matter prescribed
to be waste and any matter whether liquid, solid,
gaseous or radioactive, which is discharged,
emitted or deposited in the environment in such
volume, composition or manner likely to cause
an alteration of the environment’ – according to
the National Environment Management Authority
(NEMA).

Kenya’s plans and strategies on waste
management are guided by Vision 2030. Vision
2030 calls for reducing pollution and establishing
waste management systems through economic
incentives. In light of the pillars of the Big Four
Agenda, it will be important that waste is managed
in a manner that creates jobs and allows the
manufacturing sector to flourish.

3. Legal and Regulatory Frameworks affecting the Plastic Sector


Kenya Plastic Action Plan 42

(NEMA) translates this into the 7R Zero Waste Principle, applicable at the County level to achieve 80 % waste
recovery and 20 % landfilling by 2030. The latter strategy links EPR to e-waste, making electronics producers
accountable for their products and end of life. However, it mainly triggers public awareness campaigns. Plastic
recycling is not specifically mentioned.
For medical waste, the National Health Care Waste Management Plan guides the planning, implementation and
monitoring of waste management across the health sector. Emphasis is placed on segregation, recycling and
safe disposal [Ministry of Health, 2016].

To ensure a holistic, clean and healthy environment, the Kenya Environmental Sanitation and Hygiene Policy
2016-2030 (KESHP) claims to reduce solid waste and, in particular, to minimize the use of plastics. Solid waste
management systems and mechanisms shall be established and enforced by national and county governments
in every city, municipality and town. Especially the use of plastic bags shall be regulated with market-oriented
incentives. The private sector is invited to provide services for realization [GoK, KESHP, 2016].

Another relevant legislative document is the National Climate Change Action Plan 2018-2022 (NCCAP). Under
Priority No. 5: Health, Sanitation and Human Settlement, the Plan calls for circular waste management ‘to
substantially reduce waste generation through prevention, reduction, recycling and reuse’ [AWEMAC et al.,
2019]. By 2023, five waste management plans and regulations shall be developed on county levels, in line with
NEMA’s National Waste Management Strategy 2015 [GoK, NCCAP, 2015]. The latter one claims for a countrywide
integrated solid waste management system that follows the principle of the waste management hierarchy:
reduction, reuse, recycling, resource recovery, incineration, and landfilling [NEMA, 2015].

Laws and Regulations
Kenya’s Constitution states that every individual has the right to a clean environment. In that respect, all waste
generators, transporters, recyclers and institutions that own disposal facilities are obliged that their activities do
not threaten citizens’ rights. Refuse removal, refuse dumping and solid waste disposal is assigned to the County
governments in order to ensure environmental conservation [GoK,
Constitution: Article 42, 2010].

Urban areas and any physical planning needs to manage and dispose
of waste effectively, offer designated sites and bear responsibilities
for adherence according to the constitution [GoK, Physical Planning
Act, 1996; GoK, Urban Areas and Cities Act, 2011].

The Environmental Management and Coordination Act 1999 (EMCA), with its specific publication on Waste
Management Regulation from 2006, sets the applicable rule of law. The act directs anyone whose activities
generate waste to implement mechanisms for reducing and appropriately treating remaining waste; it prohibits
dangerous handling of waste, denies the disposal of any waste in a way that causes pollution and delegates the
responsibility for pollution to its producer. The principle that the polluter pays needs to be considered when
exercising jurisdiction [AWEMAC et al., 2019].

Moreover, the transportation of waste and any disposal operation
need licences from NEMA, which come with standards for operations.
Effective from 2017 onwards, a ban was enacted that prohibits the
use, manufacture and import of all plastics bags used for commercial
and household packaging. This ban covers the categories of carrier
bags and flat bags made from polyethylene (PE). Bags for industrial
packaging and garbage bin flat bags are exempt from the ban, if
clearance is issued by NEMA.

According the Constitution of Kenya,
every Kenyan has the right to a clean
environment.

A majority of those interviewed
welcome laws and regulations,
however they would prefer that
implementation is phased and
predictable. This would allow the
industry to be better prepared for
changes and plan their strategic
investments accordingly.

3. Legal and Regulatory Frameworks affecting the Plastic Sector


Kenya Plastic Action Plan 43

Clearance approval is subject to exerting producer responsibility, e.g. in the form of a take-back scheme or similar
measures; labelling needs to enable traceability of the plastics and sufficient documentation of the inventory
and dissemination needs to be provided [Gazette Notice No. 2334 &2356, 2017; AWEMAC et al., 2019].
The plastics bag ban was expanded by Gazette Notice No. 4858 in June 2019 to the use of plastics bottles,
straws and other single use plastics in protected areas, i.e. National Parks, Forests, Reserves, etc. It will take
effect in June 2020.

County governments are responsible for the implementation of waste management policies set at the national
level. However, counties are free in their decision on how effectively to implement them. Counties have to
publish a pricing policy that sets tariffs for public waste management services that shall include the collection
and recycling of waste [GoK, County Government Act, 2012].

Draft Policies and bills
Several legislative documents that affect plastics are in the pipeline or are being ratified. The Bill for the Sustainable
Waste Act, 2019, opts for a more sustainable, circular economy in which waste is recognized as a secondary
resource. Therefore, Zero Waste Principles are applied. Within the Bill, EPR is defined as ‘measures that extend
a […] firm’s financial or physical responsibility for a product to the post-consumer stage of the product’. EPR is
stated as being a key pillar for policy development and implementation by the National and County governments
in order to prevent causing waste and to enable re-use initiatives.

The Ministry of Environment is tasked with developing
regulations to expand the recycling market, possibly via
tax incentives and government procurement preferences
[AWEMAC et al., 2019]; the National Government has
to come up with a milestone timeline to improve waste
management and design necessary regulations; private
entities are obliged to apply clean production principles
and are fined if not compliant; citizens are obliged to minimize waste generation and apply recycle, reuse and
recover measures for the remaining consumed materials. Waste has to be disposed in accordance with the Act;
prosecutors will be held liable including the possibility of imposing fines [GoK, Sustainable Waste Management
Bill, 2019].

Within the budget statement for fiscal year 2019/2020 it was proposed to lower the corporation tax rate for
plastics recycling companies from the usual 30 % to 15 % for the first five years of operation. Services offered
to plastics recycling plants as well as the supply of machinery and equipment used in the construction of these
plants are supposed to be exempt from Value Added Tax. These proposals are provided for in the Finance Bill
2019 that is yet to be passed.

The draft policies emphasize recycling and
recognition of waste as a resource that should
be harnessed and exploited for the purposes of
jobs creation and cleaning of the environment.


Kenya Plastic Action Plan 44

Another draft Environmental Management and Co-ordination (Plastics Bags Control and Management) Regulation,
2018 refers to plastics bag control and management. Every manufacturer and importer of legal plastic bag
packaging has to propose and uphold a recycling plan to support the collection and recycling of plastic brought
into the market. The plan can be developed individually or in collaboration with other producers. It needs to be
submitted to the authority in charge (NEMA) for publishing and documenting previous activities and achievements.
Each manufacturer and importer has to submit a Recycling Program Report to NEMA with details on plastics
mass flow and treatment activities. Due diligence is required throughout the plastics value chain. The government
requires a recycling rate of 30 % for the manufacture of any plastic bag, with respective labelling. A list of all
plastic collection sites shall be published by NEMA. NEMA is also accountable for regular inspections of the
mentioned and all other facilities that handle any plastic packaging material throughout their lifecycle [GoK,
Draft Environmental Management and Co-ordination Regulations, Plastic Bags Control and Management, 2018].

3.2 Discussion of the existing regulatory gaps
Whereas some forms of EPR such as take-back schemes are already in place, public awareness and necessary
infrastructure for waste recovery are non-existent. Moreover, several regulatory gaps were identified across all
three framework dimensions, i.e. policy, legal and institutional, that hamper an actual creation of a functioning
waste management system in Kenya. The following descriptions are based on interviews conducted with several
stakeholders along the plastics value chain. Research undertaken by AWEMAC et al. in 2019 on behalf of KAM
is additionally taken into account. The following collection assesses existing local and global practices for post-
consumer plastic packaging EPR schemes in Kenya.

Policy Framework
Currently, certain provisions in the policy framework contradict one
another. For example, on one hand, bans on the import, manufacture
and use of certain materials have been declared or announced [Gazette
Notice No. 2334 & 2356, 2017] whilst on the other, the business
operation of recycling is promoted [e.g. GoK, National Environmental
Policy, 2013]. Investments into recycling infrastructure are at risk of
sinking if respective input materials are banned. Moreover, policies
are not aligned. For instance, different bills state differing recycling
rate targets. Some policies, like the Sustainable Waste Act, proclaim
EPR schemes. However, roles are not clearly allocated among the plastics value chain and hence the financial
and/or physical responsibility in the system lacks definition. Uncertainties, unspecific statements and vagueness
of the timeline for enacting draft policies, particularly the awaited National Sustainable Waste Management
Policy, 2019, discourage the private sector from engaging and building value chains that entail the capacity of
a functional waste management ecosystem.

Legal Framework
The definition of the term ‘waste’ in Kenya is currently done by NEMA. It does not consider the reclassification
of waste. The concept of transforming waste into secondary resources once value is added, e.g. by segregation
or further steps in the recycling process, does not exist. This situation creates challenges especially when it
comes to transport during the process, as the trucks are subject to the same standards, costs, and requirements
as waste collection transporters (dump trucks).

Currently, a number of political
documents are tack l ing
waste management practices.
Nevertheless, different policies
have little interconnection to
each other, resulting in an overall
blurry, partly self-contradicting
framework.

3. Legal and Regulatory Frameworks affecting the Plastic Sector


Kenya Plastic Action Plan 45

Waste segregation is mandatory by law, but in reality applies only to the separation of hazardous from non-
hazardous waste. There are no consumer obligations and regulations to segregate waste at source. In most areas,
the local authorities fail to provide infrastructure for adequate littering prevention. Willingness of consumers to
segregate waste in any terms is difficult to enforce. A comprehensive strategy on building awareness through
e.g. campaigns or insertion into curricula is lacking. Last but not least – regarding the legal framework of overall
waste management at County levels – laws and infrastructure are not harmonized. For example, transport levies
at every county border impose costs that discourage value adding processes and hinder the closure of waste
value chains. Putting the mentioned circumstances together makes waste recovery a hard goal to achieve, as
the economics of collection, transporting and processing of waste hardly build viable business cases.

In respect to plastics, first responsibility for the plastic life cycle is allocated to manufacturers and importers
of end market goods only; the role of other stakeholders in the plastics value chain, like certain raw materials
importers, retailers, collectors and consumers, among others, remains undefined. Secondly, it is obligatory by
law to set up appropriate recycling plants either individually or jointly. However, regulations to provide certain
directions on how to set up and implement any of those do not exist. Also, the lack or the inconsistency of
collection and recycling targets for obliged companies hinder monitoring processes.

Regarding the establishment of an EPR system, existing laws and regulations do not specifically outline requirements
and the potential setup of an overarching EPR system. So far, NEMA guidelines as well as the draft Environmental
Management and Co-Ordination Act on Plastics Bags lay out control and management schemes – exclusively
focused on polythene bags, with other plastics fractions/ product categories being fully left out. The National
Sustainable Waste Management Bill also claims to set up measures and necessary rules and regulations for EPR,
take-back schemes and deposit systems. In reality, it neither gives sufficient details on concrete measures to
be taken, nor does it provide a timeline by when those rules and schemes have to be enacted or implemented.

Moreover, no measurement in respect of to ‘how to identify the plastic volume put into the market’ is defined.
The enforcement of a potential EPR is therefore made difficult. Despite provisions in the law, monetary and non-
monetary incentives are not sufficiently aligned to spur changes. This applies to minimizing waste generation at
production and packaging, as well as putting minimum collection rates in place for different fractions. Current
laws allow ‘cherry picking’, and do not properly outline how to increase recycling rates; space for ‘free-riders’
avoiding contributions to a potential EPR throughout the value chain is still provided. Voluntary EPR schemes
therefore imply rising costs and worsening competitiveness for participants/ contributors.

Institutional Framework
Any enforcement and monitoring by the government and the authority
in charge (NEMA) is lacking due to unclear co-ordination mechanisms.
Standards of KEBS for recycling products are currently missing.
The same applies for NEMA guidelines that could promote circular
production patterns, i.e. through labels etc. These could encourage or
oblige the manufacturing sector to participate and actively engage in
waste recovery and recycling processes. Counties are limited in their
capacity to implement waste management practices adequately. For
instance, the segregation and responsible waste disposal/ treatment is
demanded by law on the one hand. On the other, adequate infrastructure
to comply with these regulations is not provided, neither for littering
consumers nor for the disposal industry. Additionally, implementation
of supervision measures and compliance enforcement are difficult
considering the double burden from both national and county level laws,
requirements and regulations. This is especially the case with regards
to licensing requirements and non-harmonized rules, fees and charges.

Within the plastics sector, more
so recycling, there are different
government agencies in charge
for regulations. Harmonization of
the enforcement efforts between
the different government agencies
would greatly benefit the plastics
industry. For instance, with no clear
standard from KEBS on plastics
waste, the transition from waste
to resource cannot be specifically
defined.


Kenya Plastic Action Plan 46


Kenya Plastic Action Plan 47

The following Strengths-Weaknesses-Opportunities-Threats analysis evaluates the status quo of the Kenyan
plastics value chain.

Strengths

• Strong and well organised private sector which is ambitious to take action on better, ‘smart’ plastic waste
management practices

• Strong need for an EPR expressed by both public and private sector
• Relatively well working individual recycling value chains for certain fractions, e.g. HDPE, PP, paper, etc.
• Plastic packaging value chain does exist in Kenya and can take joint action/product design decisions which

can be effected within the country

Weaknesses

• Spread of plastic packaging throughout the country/ limited local recycling infrastructure at point of
consumption paired with high cost of transport/ logistics

• Lack of awareness and culture on proper waste management practices among citizens and especially in the
part of the lower income class living above the poverty line

• Practically no tradition of waste segregation especially in households
• Little experience in formalized waste collection systems
• Insufficient general waste management infrastructure: lack of waste bins, formal dumpsites and organised

collection; poor roads etc.
• Little legislation concerning waste management/ many relevant areas not sufficiently covered by current

legislation
• Enforcement of existing waste management regulations partly deficient
• Lack of clear definitions, responsibilities, roles, etc., leading to different interpretations and waste management

practices across the country

Weaknesses

• Growing industry of local consumer goods manufacturers with continuing need for packaging
• Strong multinationals with strict internal targets on better managing waste who can serve as forerunners
• Lack of alternatives to plastic packaging for a range of applications/ banning certain plastics would cause

more problems than solutions
• Rising awareness of some parts of the population with regards to better waste management
• Low cost of labour/ high demand for employment enables business models for collecting, sorting and recycling
• Raising the value of disposed plastics even marginally is a viable mechanism to increase collection/ recycling

rates due to high need for even marginally paid employment/ income generation
• Adaptation of circular economy concepts can create “green jobs” while increasing Kenya’s recycling rate

from currently low rates.
• Waste management is a devolved responsibility, hence allowing pilot projects in certain parts of the country

through local decision making

4. SWOT analysis of the Kenyan Plastics Value Chain


Kenya Plastic Action Plan 48

Threats

• Unpredictable regulatory frameworks
• Risky environment for investment due to uncertainty of coming legislation
• Fragmented opinions within industry on the way forward
• Industry may not find a common voice/ voluntary EPR schemes not viable
• Voluntary take-back schemes would cause competitive disadvantages due to high price sensitivity of the

market
• EPR organization may not be recognized by all relevant stakeholders/might become a victim of conflicts of

interest with competitive disadvantages and free riders

The insights from the analysis of the Kenyan waste management situation, the identified legal and regulatory
gaps as well as the SWOT analysis are considered for creating tailored measures reflecting the Kenyan situation
in the subsequent Action Plan.

4. SWOT analysis of the Kenyan Plastics Value Chain


Kenya Plastic Action Plan 49


Kenya Plastic Action Plan 50

Based on the analyses and evaluations in the previous chapters, this chapter will introduce specific action steps,
initiatives and measures to accelerate Kenya’s transition towards a circular economy for the environmentally
sustainable use and recycling of plastics. In particular, it focuses on policy suggestions and sustainable funding
mechanisms to create a sound basis for further actions. Thus, the first part will focus on establishing the necessary
organisational and financial basis while the second part will introduce specific measures to be taken for action.

5.1 Establishing a Financial and Organisational Basis
Economic instruments are crucial to establish a sound financial and organisational basis for sustainable waste
management and recycling. Generally, there are three different types of economic instruments;

• Revenue-raising instruments which create a direct income from the industry and/or households through
taxation or charges as, for instance, a landfill tax

• Revenue providing instruments which create an indirect income for industry and/or households through
reduction of charges or subsidies, like tax rebates or variable VAT rates

• Non-revenue instruments which do not create revenues but motivate the industry and/or households to
improve their individual waste performance, as it is done for example through EPR systems as detailed in
chapter 5.1.2 below

• Ideally, instruments from all three categories are implemented in a complementary fashion to achieve ideal
results.

5.1.1 Tax incentives
Generally, taxes can be raised on several products at several steps along the value chain. It is most important
to avoid unfair double taxation and use taxes which are complementary to the EPR levies that will be explained
in the next chapter. Thus, the most important taxes to consider are the landfill charges and the refunded virgin
payments.

Landfill Charges
Generally, landfill charges are composed of the gate fees imposed by the operator of the landfill and the landfill
tax imposed by the authority: The gate fee is charged in order to generate revenues for keeping the landfill in a
working order and finance the provided services. The landfill tax is a levy charged by public authorities (usually
on a national, but also on a regional or municipal level) for waste disposal on a landfill site; the cheaper the landfill
tax, the lower the incentive to recycle waste. Thus, there is clear and linear correlation between the total landfill
charge and the percentage of recycled waste, i.e. landfill charges are a key driver for diverting waste from landfills.

To allow the system and the relevant authority to adapt to raising landfill taxes, the landfill charges should be
increased gradually. However, it is crucial to have clear commitments to increase these costs, while giving the
municipalities and the (informal) industry time to adapt. From a long-term perspective, legislative regulations
such as landfill restrictions or bans may be effective in redirecting waste into a recycling process. This requires
waste segregation at source and a corresponding collection system.

5. Proposed Measures and Initiatives for the Action Plan


Kenya Plastic Action Plan 51

Refunded virgin payments
Refunded Virgin Payments is a two-part measure: producers of products which solely consist of virgin materials
pay a fee that is used to refund producers whose products consist of a specified amount of recyclates. Thereby,
producers using more recyclates than their peers become net receivers of the refund, while producers who
predominately use virgin materials become net payers in this system. This tax has an upstream steering function
on recyclate usage.

To avoid double payment, this tax should only be applied to plastic products that cannot be covered by an EPR
system. So far, Refunded Virgin Payments are piloted in Sweden to incentivise textiles recycling.

5.1.2 Extended Producer Responsibility
Extended Producer Responsibility (EPR) is an environmental policy approach in which a producer’s responsibility
for a product is extended to the post-consumer stage of a product’s life cycle, i.e. when a product turns into
waste. In the approach, already during the production and sale (and export), producers are responsible for the
disposal of their packaging. Producers/ importers pay a fee for later disposal of packaging already when their
packed goods are placed on the market. The contribution/ fee is used for collecting, recycling and disposing
the packaging waste and other costs arising from maintaining the system. It is not used as a contribution to the
general public budget of a state.

The concept of Extended Producer Responsibility and its basic principles
The concept of an extended producer responsibility (EPR) was developed in Germany in the late 1980s. It is
based on the idea that the producer responsibility, which e.g. determines that the producer is responsible for
their products regarding aspects of safety, health and environmental impacts, is extended until the end-of-life
stage. ‘Producer’ in this context describes companies that put plastic goods (product and/ or packaging) on the
market for consumption, which are usually referred to as ‘users’ in the Kenyan context.

This means that in the EPR scheme, the producer (or user) is responsible for all waste management related to
tasks like collecting, sorting and recycling. Thus, the EPR involves producers in the management and financing of
packaging waste and gives them the obligation to assume responsibility for their waste. Although EPR systems
vary across countries with regard to certain aspects of their set-up, EPR schemes should be designed to manage
the obligation of producers while balancing the mandates of environmental policy in the light of the ‘polluter
pays’ principle. Accordingly, the basics of EPR are almost the same in every country:

• Every obliged company pays a fee when introducing a packaged good on the market.
• The fee serves for the collection and further processing of the packaging waste.
• Collection, sorting, recycling, or energy recovery of packaging waste remains the responsibility of the obliged

companies.

This basic concept is illustrated in the Figure 17 on the next page.


Kenya Plastic Action Plan 52

In its simplest form, EPR is rooted in an individual responsibility through a direct interaction between the users,
importers, fillers and the source of waste generation; meaning that they will directly collect or pay someone
to collect their waste and take it back. This very simple form of EPR is already applied in Kenya as the current
legislation obliges producers to organise a take-back scheme for the waste of their products. However, this model
is only practicably applicable to a limited extent as it requires the producers/users to have knowledge about
the exact spreading of their packaging and how to access it. Furthermore, logistical challenge arise especially if
products are distributed in small quantities, still requiring similar logistical infrastructure and attributed costs
as applicable with bigger volumes.

Collective responsibility through Producer Responsibility Organisation

As it is, from a practical perspective, not possible for each producer/user to assume an individual responsibility, a
transition to a collective responsibility is needed. As a key element to achieve this transition, an EPR organisation
is needed as a central element. It takes over the take-back responsibilities of the obliged companies. This
organisation is referred to as the Producer Responsibility Organisation (PRO; sometimes also referred to as
system operator) as it allows the producers/ users to assume responsibility by combining their efforts and
jointly managing the arising waste. Thus, the PRO becomes the central element for the organisation of all tasks
associated to the EPR system. In particular, this means that

• The PRO is the most important stakeholder (organisation).
• This organisation is responsible for setting up, developing and maintaining the system.
• This organisation is responsible for the take-back obligations of the obliged companies.

As the compliance of the PRO with all its tasks and responsibilities is necessary, a third party like a public agency
is responsible for supervising the PRO in this regard. The following graphic (Figure 18) shows the basic principle
of an EPR system with the PRO as central organisation for a collective responsibility.

Figure 17: Basic idea of an EPR system

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Kenya Plastic Action Plan 53

Figure 18: Basic scheme of an EPR system based on a collective responsibility

Figure 19: Comparison of collective and individual EPR system

Figure 19 emphasises the organisational differences between the collective and individual EPR system:


Kenya Plastic Action Plan 54

Another specific form of EPR system is a deposit-refund system (DRS): In a deposit-refund system, the waste
collection is based on consumer participation. In a DRS, packaging or other items receive an economic value
by obliging consumers to pay money as deposit when purchasing the item. Upon return of the purchased item,
they get back the same amount they paid as deposit. Thus, consumers are incentivised to bring these items to
take-back stations instead of just disposing them as waste. DRS are systems based on consumer participation
which reduces littering of these items. Moreover, as the DRS focuses on specific goods (like PET bottles), they
allow well sorted material fractions to be collected in large quantities. Such collection systems thereby allow
for high quality recycling of these items. Furthermore, DRS also increase the competitiveness of reusable items
such as bottles in supermarkets or cutlery in food stores, thereby contributing to another key principle of the
circular economy.

A return of the items takes place at designated take-back stations, such as retailers or specific automats, where
the consumer receives the reward. In most cases, this reward is monetary and is received per each single item:
The specific product is sold to the consumers with a deposit amount meaning that the price of an item (for
instance $ 1.25) is the sum of the price of the single item ($ 1) and the deposit amount ($ 0.25). Once this item
has been returned, the consumer is repaid the deposit amount or a voucher with the amount ($ 0.25). However,
other rewards are also possible, such as vouchers for services.

Creating DRS as form of EPR is limited to specific, easily identifiable items like beverage bottles. Thus, it
is not suitable to cover a broad range of plastic items.

Successfully implementing an EPR system requires a system which can be put into practice being economically,
environmentally and socially sustainable as well as guaranteeing a level playing field. This demands clear and
unambiguous legislation coupled with a multi-stakeholder cooperation between all involved actors from the
value chain. Crucial actors include governments, local authorities, producers organised in business member
organisations (BMOs) and waste management organisations. The legal framework has to determine objectives,
responsibilities, enforcement mechanisms and a timeline for implementation complemented by a framework
for the PRO.

The Producer Responsibility Organisation
Since the PRO is responsible for operating the entire system, it is the most important actor. Its tasks comprise
the following:

• Registration of all obliged companies (in cooperation with the supervisory authorities): These are the companies
introducing packaged goods onto the market, which are consumed in the country meaning that their packaging
needs to be disposed in that respective country (financed by the importers, fillers, and producers)

• Collection and administration of all funds from all obliged companies while ensuring fair costs and therefore
not harming the competitiveness of a participating company

• Tendering and contracting for collection and recycling of packaging waste
• Documentation of collection, sorting and recycling of packaging waste
• Informing all waste producers/ consumers about the importance of separate collection
• Controlling all services that have been awarded to service providers, specifically services relating to the

fulfilment of collection and recycling by waste management companies
• Financing all tasks with funds provided by the obligated companies
• Documentation and verification to the supervisory authorities: the PRO has to prove that it has completely

fulfilled all its tasks and aims and used the money of the obliged companies accordingly. This can be done
for instance in form of a report, which is verified by a third party or the authorised public agency.

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Fulfilling these tasks can be achieved through different PRO setups. The main differences with regards to the
setup are based on

i) whether the PRO is a private organisation or a public authority,
ii) whether the PRO is a non-profit organisation or a for-profit company, and
iii) whether one PRO or several PROs exist in competition (see Figure 20).

Experiences in European countries have shown that there is no singular most successful setup, but that the
success is determined through an effective and efficient organisation, financing, administration and controlling
of the system.

The most distinguishing characteristic is whether the PRO is set up as a for-profit or non-profit organisation.

• PRO (system operator) as non-profit organisation: Such PROs are in the hands of the obliged producers and
industry, as for instance in Belgium, the Czech Republic, Ireland, Italy, France, the Netherlands, Norway,
Portugal and Spain. The obliged industry creates one common non-profit entity that collects the necessary
funding.

• PRO (system operator) as for-profit corporation: The legal framework can require direct competition between
several PROs instead of having a single monopolistic PRO. Such models exist e.g. in Germany and Austria
where the EPR systems have evolved from having a single PRO to competition between several PROs.

• Other distinctions can create the following PRO set-ups:
• Dual model: Industry has full operational and financial responsibility over collection, sorting and recycling.

There is a separate collection system delegated to local authorities but their influence is minimal (Austria,
Germany, Sweden).

• Shared model: The responsibility is shared between industry and the local authorities based on common
agreements regarding collection. Municipalities are responsible for collection, and often for sorting of
packaging waste arising at the municipal level, while industry’s financial responsibility differs from country
to country (Belgium, Czech Republic, Italy, France, Netherlands, Slovenia, Spain).

• Tradable Credits Model: There is neither a link between industry and municipalities nor differentiation between
commercial packaging and packaging arising at the municipal level (UK).

• Competing on the infrastructure: Every PRO offers its own container to inhabitants (Estonia).
• Each PRO in a separate district: Each PRO signs up with as many municipalities as needed to fulfil targets

according to market shares (Poland, Romania, Bulgaria, Slovakia, Malta, Latvia, and Lithuania).

Figure 20: The different set-up conditions of the PRO


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Who is obliged to pay?

The fees paid for the EPR participation are to be paid exclusively for the waste management related costs and
only for the products that are consumed and will become waste within the country, i.e. for an EPR system in
Kenya the fees only have to be paid for the products that will be consumed and turn into waste in Kenya. This
therefore includes both domestically produced products as well as imported products equally in order to ensure
a level playing field. However, products manufactured for export are not included as they will be consumed and
subsequently turned into waste in another country.

To determine who is obliged to pay for the operation of the EPR system, a clearly identifiable interface needs
to be determined. In most countries, this is the interface where a product is put on the market for consumption
in the country as it will turn into waste in this respective country.

The fees that need to be paid are dependent on several factors, which all influence the total costs and thus need
to be covered. These factors include:

• Type of collection system
• The waste composition
• Organisational structures
• Contractual constellations
• Financial contributions of the municipalities
• Recycling quotas
• Recovery and disposal infrastructure
• Existence of deposit-refund systems
• Distribution of costs across different material fractions
• Where applicable: modulation of costs reflecting the degree of recyclability (as for instance in France, see

‘global examples and success stories’)

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Roles and responsibilities of the involved actors
Although the set-up of the EPR systems and PROs are different in each country, the involved stakeholders and
responsibilities assigned to them are, in principle, the same.

Table 2: Roles and responsibilities in an EPR system

Stakeholder Responsibility

Raw materials suppliers,
manufacturers and converters of
plastics

Should enable reuse & ensure recyclability of materials and should
use secondary raw materials where possible

Consumer goods companies
(fillers and importers)

Obliged to pay fees for the EPR system proportional to the products,
which are covered by the EPR system

Distributors/retailers of pack-
aged goods

Can be obliged to take waste back and to ensure its proper handling.
Should also ensure that their suppliers are participating in the EPR
system

Consumers
Have to be informed about strategies for waste reduction and proper
return or disposal of packaging; should buy as many unpackaged goods
and products as possible and reuse packaging as often as possible

Waste management operators

Receive funds from the EPR system for their services in handling pack-
aging waste. Should try to recycle packaging according to the highest
standards possible to ensure high quality recycling; includes the infor-
mal sector

Government and other public
authorities

Legislation & supervision of the EPR system

Municipalities or Counties
Linkages between consumers and waste management operators, main
responsibilities for implementation of EPR on the local level through
organizing the collection

Thus, an operationalised EPR system can be outlined as outlined in Figure 21:


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Figure 21: Operationalised EPR scheme

Legal basis
EPR systems can be operated on a voluntary basis only to a limited extent. Thus, mandatory EPR systems are
the preferred choice in light of effectiveness and efficiency to transition to a sustainable waste management and
circular economy. A mandatory EPR system in turn requires a respective legal basis to ensure compliance of all
stakeholders, which is why a sound legal basis is a crucial element. As a first introduction step for a mandatory
EPR system, voluntary systems are, however, a suitable measure to push the introduction through such self-
commitment.

The legal framework is usually established on the national level through a framework for waste management and,
hence, the Ministry of Environment therefore takes a leading role. In particular, the legal foundation can be laid
down through environmental protection law, a specific packaging law or a packaging ordinance – depending on
the legal context. To ensure a successful implementation, the process of drafting the legislation should involve
all key stakeholders from the public and private sector as well as from civil society.

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The legal framework should outline clear objectives, responsibilities, enforcement mechanisms and a timeline
for implementation. In particular, the legal frame should determine:

• How to set up a PRO (as aforementioned)
• Which companies are legally obliged to take on responsibility
• Who is responsible for financing and organising the system
• Who registers all legally obliged companies
• Which items should be included in the system
• What are the requirements and quotas for collection and recycling
• What the role of the municipalities is
• How can the informal sector be integrated
• What kind of public supervision is required and how can this be organised

There are also some additional requirements which do not need to be mentioned in the law but can be defined
by the PRO. This includes:

• Upstream: modulated fees based on recyclability (see chapter 5.2.1), recyclate usage, usage of mono-
materials, preferred materials

• Downstream: Recycling and recovery processes, quota and how they are calculated; waste stream specifications,
collection infrastructure

What can be financed by an EPR system?
First of all, an EPR should cover all costs which will arise in the course of achieving the pursued goals for the
waste management. This also includes efforts for e.g. data management and administration. Furthermore,
complementary measures could also be financed, such as:

• Linking plastic producers to recyclers in terms of design, recyclability, awareness (e.g. through a forum or
guidelines)

• Coordinating, giving incentives to improve collection and recycling while keeping a level playing field
• Educating recycling and collection businesses and actors
• Raising awareness, especially in the middle class (above the poverty line)
• Adapting school curricula; technical education at universities
• Running pilot projects (e.g. in certain geographic areas, special sectors like tourism) and researches
• Using labelling on products

The PRO can also contract third parties to carry out certain tasks, like awareness-raising campaigns.


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Measurements based on legal frame
The goal is to build an EPR strategy which is proactively discussed with the government. The basis for a mandatory
EPR system is a corresponding law. Through such a law, the following targets can be achieved:

• Fair financial burden for all participants as the EPR fees are proportional to the amount of products which
are part of the EPR system. Thereby, the competition on the market between the EPR system participants
is not impacted

• Enabling the implementation of nationwide solutions
• Requirements for a gradual system implementation and recovery targets can be legally defined
• Establishment of control mechanisms and penalties in case of non-compliance

Thus, the setup of a legal frame is the preferred solution for the implementation of a successful EPR system.

Voluntary measures
In smaller regions, it is possible to establish voluntary initiatives or voluntary commitments as pilot projects to
collect and utilise plastic waste. Aside from geographical boundaries, these pilot projects may focus on individual
types of packaging, particular points of origins, specific brands and also on defined timely frames. Manufacturers,
importers and other stakeholders may work together to implement these voluntary projects. However, the
effectiveness of pilot projects is limited due to the following issues:

• Only a few companies (and not all) will participate in voluntary measures
• The financial contribution of each company is low compared to the contribution companies have to pay in

an EPR scheme
• Extent of the single activities is small and usually comprises only smaller projects
• Impossible to establish a nationwide collection system based on voluntary measures
• No official controlling systems
• Voluntary initiatives may prolong important decisions regarding the setup of a nationwide EPR

Voluntary initiatives should rather be used as a preliminary basis for the system operator of an EPR system
to help develop the respective legal basis of the system. Voluntary initiatives can help to gather individual
experiences through pilot projects.

Global examples and success stories
As aforementioned, EPR systems can be implemented in many different ways. In Europe, there are currently
30 countries that have implemented EPR in their legislation, with the industry having respectively set up PROs.
Outside of Europe, such organisations have been established as well, for instance in Israel, Turkey and Japan.
Below the systems of Germany, France and the Netherlands are presented, which all have different set-ups.

In Germany, the legal framework allows a direct competition between several PROs instead of having a single
monopolistic PRO. Since the PROs are private companies, they are not in the hands of the obliged industry, but
each obliged company has to contract a PRO of their choice for the management of their waste. Therefore, the
exact fees are not disclosed. Furthermore, the EPR system exists in parallel to municipal waste management
and municipalities are not part of the EPR system.

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This setup has achieved very good results with regards to collection, sorting and recycling. However, this system
requires intense monitoring and supervising due to the complex and partially unclear structure, which is why
some companies exploit this system to participate inadequately or avoid participation in the system. The ‘Central
Agency Packaging Regulation’ was established after the passing of a new packaging law, which entered into
force in January 2019 as a new controlling authority.

In 2003, Germany established a compulsory deposit-refund system by law for one-way beverage packaging
made from glass, plastics, metals or composite materials. From 2003 to 2006, the deposit-refund system was
built on a direct relationship between consumers and retailers. Empty one-way beverage bottles could only be
returned at the original point of sale. After 2006, the deposit-refund system was transformed. Since then, the
law obliges every retailer to take-back deposited one-way beverage packaging made of materials they supply
through their own product range. Thereby, Germany implemented a uniform, nationwide system for deposit-
refund with clearing. As a clearing organisation, the Deutsche Pfandgesellschaft (DPG) was established, owned by
the German Retail Association and the German Food Association. Through employing clearing service providers,
the producers and importers of deposited beverages receive the record data of returned deposited beverage
packaging and reimburse the respective amount to the retailers. The return rate of deposited beverage packaging
was 98.4 % in 2015.

In France, Citeo (until 06/2017 named Eco-Emballages) was developed as the dominant EPR system that is
exclusively responsible for end consumer packaging. Eco-Emballages was founded by a coalition of several
industrial parties (manufacturers). A second EPR system, Adelphe, was established by the wine and spirits
industry to meet the take-back obligations for glass bottles. Today, Adelphe is fully owned by Citeo, yet continues
to operate as an independent company.

Citeo is a non-profit joint-stock company with approximately 240 shareholders from manufacturers, distributers as
well as the print, services and related supply chain sectors. In total, Citeo is the PRO for approx. 50,000 members.
The fees of Citeo are based on the weight of the packaging, a fixed price per packaging unit, a malus system for
non-recyclable packaging (e.g. fees for non-recyclable plastics as packaging material are twice as expensive).

The producers finance approx. 80 % of the system and the local municipalities finance the remaining 20 %.
Moreover, the municipalities are also responsible for performing disposal services.

The system achieves good results with regards to collection, sorting and recycling. However, mixed plastics and
plastic foils are not included in the system throughout most areas in France. It is planned to expand the system
to comprise all types of packaging waste by 2022.

In the Netherlands, the Afvalfonds Verpakkingen (packaging waste fund) was established jointly by manufacturers
and importers to fulfil the extended manufacturer responsibilities. It is a non-profit organization which is
managed by a management board, which is itself appointed by producers and importers. The tasks include
the maintenance of the waste management system, collaboration with communities and other stakeholders to
organise collection, and recycling of packaging. Other tasks are the mitigation of packaging waste, monitoring
and reporting on collection and recycling of packaging materials as well as defining and receiving compulsory
financial contributions from manufacturers and importers.

A noticeable feature is that the tasks of collection, sorting and transportation of waste to recyclers are exclusively
done by the municipalities. In turn, Afvalfonds pays compensation for the collection and sorting of packaging waste.


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Since December 2007, Nedvang, a non-profit organization, acts as mediator between manufacturers, importers and
retailers as well as recovery companies, municipalities, and national authorities. Moreover, Nedvang monitors the
packaging market and the recovery of packaging waste. Nedvang works for the waste fund and makes contracts
with municipalities regarding the reporting of packaging waste, which is collected, sorted, and recycled. Nedvang
reviews this information and, following their review, dispatches approval through payment from the waste fund.

Overall, this system achieves good results with regards to collection, sorting and recycling. However, the costs
are high compared to other EPR models.

Local examples and success stories
In Kenya, there is no mandatory EPR system. Thus, organisations that operate as a take-back organisation follow
the principles of an EPR system for selected materials only. These organisations are based on the voluntary
participation of their members. In particular, there are PETCO and Clean Green Kenya.

The PET Recycling Company Ltd. (PETCO Kenya) registered in December 2017 and started operating in June
2018 with its organisational scope being limited to PET beverage bottles. Through self-regulation mechanisms
for the industry, PETCO aims to create value for post-consumer PET and encourage a change in consumer
and industry behaviour towards recycling PET beverage bottles which is supposed to help in creating more
employment possibilities in the recycling industry.

Currently, the organisation has 14 active members. The main financial sources are the membership fees, grants
from retailers, plant owners and bottlers. The grants are obtained through negotiations with members.

For the PET bottle collection, PETCO has contracted two companies as of now, WEECO Limited and Karsam
Limited. The plan is that WEECO Limited collects and recycles 4,800 mt, while Karsam Limited collects and
recycles 1,000 mt annually. Overall, PETCO aims, together with other partners, to collect and recycle 6,000
mt or 300 million PET bottles by 2019. Through its collaboration with retailers such as Naivas Kenya and other
members, PETCO Kenya aims to set up drop-off points to enhance the collection of recyclables.

To raise awareness and promote consumer education, PETCO targets stakeholders which can bring maximum
returns to the consumer awareness programs. Some initiatives aim to couple media coverage with school
recycling initiatives.

Clean Green Kenya (CGK) is also a voluntary system with the set goal of developing a circular economy, bringing
awareness of proper waste management to all sectors and becoming a hub of information in the recycling sector.
The companies Alternative Energy Systems Limited, RAMCO and King Plastics subsequently founded CGK as an
NGO in 2017. The idea of CGK is to establish a platform through which collectors, recyclers and manufacturers
across different industries can interact and create synergies.

Key activities include the collection of funds through a monthly ‘EPR fee’, which is invested in enhancing the
waste management capacities. CGK also aims to secure collectors’ supply chains based on a pricing model that
incentivises the collection of post-consumer waste. The organisation currently has 22 companies registered
on a voluntary basis. These include manufacturers, recyclers and end consumers. They have committed to a
monthly levy which is calculated based on their monthly plastics production. The collected levy is mainly used
for collection and sorting of waste plastics (done at dumping sites), pre-processing activities (transportation,
cleaning and compacting of waste plastics) and educational campaigns and capacity building in schools.

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5.1.3 Comparing tax incentives and EPR
In many cases, measures are referred to and published under the label of EPR. However, in light of the defini-
tion of an EPR scheme, these are mostly green taxes and environmental charges or eco-taxes. These envi-
ronmental taxes or import duties are charged on raw materials and goods. In these cases, most of the funds
usually flow into the general public budget, so there is no producer responsibility fulfilled as defined in an EPR
system.

The following table compares the fees paid within an EPR system by the obligated companies with green taxes
and environmental charges.

Table 3: EPR fees and green taxes in comparison

EPR fees for packaging Green taxes / environmental charges

The fees are determined by the PRO or - in case of
for-profit corporations - negotiated with the obliged
companies.

The tax is defined by law or through other public
regulations and acts.

The PRO receives the fee. The responsible public agencies receive the tax.

EPR describes extending the producer responsibili-
ty: Those who introduce certain goods on to a mar-
ket are also responsible for the subsequent waste
management and disposal of the arising packaging
waste.

Eco-taxes can be charged without being directly
related to a specific responsibility of a producer. The
duty is fulfilled through payments.

The fees are precisely related to the products cov-
ered by the EPR scheme, which are introduced on
the market of the respective country in which they
will also turn into waste.

Eco-taxes do not have to be related to the consump-
tion in the respective country. For instance, they
can also be related to raw materials or imports.

There is a direct relation between the EPR fee and
the quantities of arising waste in the respective
country.

There is no relation to the arising packaging waste
quantities in the respective country.

The EPR fees are meant to be exclusively used for
collection, sorting and recycling of the waste. This
also includes a corresponding communication and
public awareness work.

Eco-taxes usually contribute into the general public
budget, so there is no ‘polluter pays’-principle in the
sense of an EPR system.

Generally, both EPR fees and green taxes can have a steering function. Green taxes can steer raw materials,
materials and goods which are newly introduced onto the market; for instance through taxes which are staggered
based on ecological criteria such as the recyclability, usage of recyclates, or origin of the material (upstream
impact).


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The steering function of EPR fees also covers the part when raw materials, materials and good are newly
introduced onto the market, but expands beyond this as EPR fees also impact the establishment of an operative
system, meaning EPR can finance, amongst other things, infrastructure, communication, and campaigns against
littering (up- and downstream impact).

Thus, EPR fees – if they can be applied to a specific product – are the preferred choice with regards to their
steering function.

5.2 Action Measures

5.2.1 Recycling and/or End of Life Options
The End of Life (EoL) options for waste plastics are geared to the waste hierarchy (see chapter 2.2), which is a set
of priorities for the efficient use of resources and waste treatment, listing the most preferred to least preferred
option. Based on the waste hierarchy, the following EoL options exist for waste plastics:

Prevention refers to measures taken before a substance, material or product has become waste. These measures
reduce the quantity of waste (including through the re-use of products or the extension of the lifespan of products),
reduce the adverse impacts of the generated waste on the environment and human health, or reduce the content
of hazardous substances in materials and products. Prevention measures are taken before a product becomes
waste! Examples for prevention measures include resource-efficient processing leading to less material being
manufactured (thinner wall thickness of bottles, cans) or multiple use applications. (cans or baskets used for
the same or another task and therefore remain within the utilisation phase).

Preparation for re-use describes materials and items which have become waste, are cleaned, refurbished and
remanufactured for reapplication.

Recycling means any recovery option by which waste materials are reprocessed into products, materials or
substances, whether for the original or for other purposes. It includes the reprocessing of organic material but
does not include energy recovery (which is part of recovery!). Recycling also includes re-granulation as well as
production of flakes and agglomerates out of plastics.

Other recovery processes, e.g. energy recovery: For this purpose, the energetic content of the plastics are
used to generate heat, cold and/ or electric energy; mostly through incineration.

Disposal describes any operation which is not recovery, even where the operation has a secondary consequence
for the reclamation of substances or energy. Thus, disposal does not count as recovery measure. Disposal does
not mean littering or the landfilling in unsuitable locations.

Generally, no comprehensive collection and, further, proper waste treatment (household and commercial waste)
is implemented in Kenya, especially with regards to plastics. Considering the waste management practices
(improper landfilling in terms of organizational and environmental aspects, low recycling structures for glass,
paper, plastics, no relevant multiple use systems), the usage of resources for e.g. packaging should be widely
reduced (prevention) to tackle the challenges (loss of resources, littering, improper treatment to reduce negative
environmental impacts).

As a recommended, complementary first step, the development of a systematic recycling structure is crucial.
This also includes the treatment of plastics which are not recycled at the moment or which are by nature not
suitable for recycling (see section recyclability).

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Similar to Europe, the long-term goal should be to transfer the current, unsystematic disposal of plastic waste
into a suitable form of treatment through planning and reconstructing landfills with adequate safety measures
(e.g. waterproofing, gas retention, waste water collection and purification).

This should go along with the requirement only to transport pre-treated waste to landfill sites. Since the beginning
of 2006, there is a so-called landfill ban in Europe. It states that waste which is supposed to be landfilled must
only have a very small amount of total organic carbon (TOC). This is accomplished when;

• Waste is already separated and collected at source
• Contained recyclable fractions are sorted
• Remains unsuitable for recycling are used energetically

The latter two points are key elements for a circular economy and should therefore be put into focus through
the implementation of an EPR system (see chapter 5.1.2) and measures (see chapter 6). However, it should be
considered that even with a higher usage of plastic recyclates in production processes, there is still a need for
virgin materials, which e.g. are obligatory to fulfil certain quality criteria during manufacturing processes.

Moreover, the recycling processes should not be limited to Kenya location-wise as long as the inland market is
not established sufficiently; i.e. export of waste or secondary resources for processing abroad can, at least in
an initial phase, be a viable part of the solution.

For a long-term success, structures outside of recycling need to be established as well as structures for waste
treatment for non-recyclable plastics. This generally happens through incineration (energy with heat generation
as the best option), as the resulting ashes are landfilled. Alternatively, the option of ‘catalytic pressurised oiling’
and the generation of fuel are conceivable for plastics but still in development to scale them to an industrial
level; also in Europe where packaging waste is managed on a comparably high level.

The EPR system shall create financial incentives for more plastics recycling, especially in light of the fact that
current disposal options such as unsanitary landfills like Dandora or improper disposal sites in residential,
agricultural and protected areas are still the cheaper options compared to recycling.

The creation of recycling targets (such as a certain amount of used plastics which must be recycled within a
year) shall result in reduced attractiveness of unsystematic landfills and less waste remaining within the city.
The simultaneous implementation of a landfill tax promotes the shift to more recycling at the same time (see
chapter 5.1.1).


Kenya Plastic Action Plan 66

5.2.2 Segregation at source as best practice and waste collection
Segregation at source and the respective waste collection is a central part of sustainable waste management
and recycling. Since segregation and collection systems need to be tailored to the local conditions, they vary
globally. Even in European countries with established EPR systems, the collection form of the different lightweight
packaging materials varies as shown in Table 4 below.

Table 4: Collection structures for packaging for the individual material fractions in five different countries
with EPR systems

Germany France Spain Italy Netherlands

Plastic foil (plastic bags) 1) X6) 3) X5) 4) X6)

PE and PP X6) X2)5)6) X5) X2)5)6) X6)

PS X6) 3) X5) 4) X6)

PET bottles X6)7) X5)6) X5) X5)6) X6)

PET non-beverage bottles X6) 3) X5) 4) X6)

Mixed plastics (rigid) X6) X2)5)6) X5) X2)5) X6)

Mixed plastics (flexible) X6) 3) X5) 4) X6)

Beverage cartons X6) X5)6)8) X5) X5)6)8) X6)

Tin plate/ferrous metals X6)7) X5)6) X5) X5)6) X6)

Aluminium/non-ferrous metals X6)7) X X5) X5)6) X6)

Paper and cardboard X5)6) X5) X5) X5)6) X5)6

1) The target fraction is narrowed down (size > DIN A4) in order to ensure a significant enrichment of LDPE.
2) At the moment: only bottles and/or containers
3) Expected from 2022 onwards
4) It is expected that the collection systems of CONAI (Italy) will be expanded to these fractions as well to fulfil

the quotas for 2025 set in the EU packaging directive.
5) Drop off system/‘bring it yourself’-system
6) Kerbside collection/pick-up system
7) Deposit system for beverage packaging
8) In France and Italy, beverage cartons are often (estimated 50 % to 80 %) collected together with paper and

cardboard and not in the collection system of lightweight packaging like in other countries.

Generally, there are two distinct possibilities to collect waste: either at the household level through kerbside
collection systems or on the streets through bring banks (also referred to as drop-off systems or ‘bring it yourself’-
systems). Some examples from four different countries are presented on the next page (see also Figure 22)

5. Proposed Measures and Initiatives for the Action Plan


Kenya Plastic Action Plan 67

Figure 22: Waste segregation and collection in Germany (upper left) and Spain (upper right),
Japan (bottom left) and Shanghai (bottom right)

In Germany, waste is usually separated into
four fractions and collected at the household
level through a kerbside collection system. Glass
packaging is usually collected through bring banks.
The costs arising from collection, sorting and
recycling are covered by the PROs. The costs
arising from the waste of the “paper, cardboard
and carton” fraction are divided between the
municipalities and PROs as this fraction includes
both paper packaging waste and other printed
products for which there is no EPR scheme.

The prevalent collection system in Japan is a bring
system where the waste is sorted in different fractions.
Nevertheless, there are also some kerbside collection
systems. In several places, the waste collection is
complemented by additional collection forms, such as
group collections organised by residents. The overall
numbers of waste fractions, which are segregated at
source, vary across Japan.

In Shanghai, China, a waste segregation
and colle sction system has been introduced
which is based on segregation at source into
four fractions: kitchen waste for composting,
valuables for recycling, specific waste (like
hazardous waste), and residual waste.
Inhabitants will be penalised if they fail to
segregate properly.

In Spain, collection is mainly organised via drop-off
containers/banks. Rigid plastic, cans and cartons
belong in the yellow containers, and paper and
cardboard belongs in the blue ones. In total, there
are over 573,000 yellow and blue containers
available throughout Spain to collect packaging
waste (very high density). From there, packaging
is collected and transported to suitable sorting
plants that further segregate into more specific
fractions.


Kenya Plastic Action Plan 68

In Tunis, several containers for separate waste collection of plastic packaging have been set up in different
districts across the city. These containers are built in such a way that the collected plastic packaging is highly
visible for everyone and can also be removed by everyone, which is particularly interesting for the informal
sector. As a consequence, all valuable plastic packaging (like PET bottles) is removed from the containers and
only the valueless, non-marketable plastic packaging remains inside the containers. Another problem is the
high amount of litter which is generated as a side effect upon removal at the places where the containers are
set up. Thus, the container design is an important element to consider when setting up a waste collection
system (see Figure 24).

Figure 24: Container designs

Problems arise when waste management operators do not fulfil the service for which they have been contracted
and the collection points are not appropriately taken care of as shown in the examples of Palermo, Italy and
Tunis, Tunisia in Figure 23.

Figure 23: Waste collection in Palermo (left) and Tunis (right)

Collected packaging is
clearly visible. Through
the door, they can be
removed by everyone.

Opening is small
enough that nothing
can be removed and no
children can enter.

The opening is large
enough for removing
items. It also dangerous
as e.g. small children can
be put into the containers
through these openings
(to facilitate the removal).

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Kenya Plastic Action Plan 69

As the collection costs are covered by the PRO, the following disposal services have to be discussed and negotiated
for waste collection:

• Establishment of an infrastructure for the collection of packaging waste
• Documentation of the collection
• Regular emptying of the containers
• Cleaning of the collection points
• Maintenance and care of the containers
• Establishment of infrastructure for the sorting and recycling of plastics waste
• Documentation of recovery and recycling

5.2.3 Product Design for enhanced recycling
Recyclability is the key figure for the qualitative and quantitative behaviour of a product in the post-use phase as
it determines it respective recycling process chain for primary raw material substitution. This means, it must be
possible that the products after use are collectable via existing collection possibilities and sortable in a qualified
manner. Its reprocessability must enable recirculation.

As aforementioned, the recyclability is determined by two factors:
i) the composition of the object, and
ii) the actual existing recycling options after usage, which is why a plastics object is only truly recyclable if an

actual recycling pathways exist. Otherwise, it remains ‘ready for recycling’.

However, these two factors have a reciprocal connection since the composition of the object often determines
whether an object can be recycled through the existing recycling pathways in the respective country. In turn, the
existing recycling option can influence the composition and design of a plastic object. There are several steps
which need to be considered when designing the product. They are illustrated in a flow chart (see annex 8.11).

The decision about the recyclability is material-dependent – meaning that the decision flow chart has to be
applied to each material and the respective item design (bottle or tray).

Based on the prevailing collection and recycling structures in Kenya (see chapter 2.4), it can be assumed that
recyclables are aggregated on an item basis both through formal collectors as well as through informal waste
pickers and the subsequent, largely manual sorting.

Thus, technical requirements for plastics packaging as well as non-packaging plastics items with regards to
their suitability for automatic sorting do not need to be considered. Nevertheless, negatively impacting design
trends on the recyclability have been already recognised in the Kenyan context: in particular, this refers to the
substitution of PE or PP as valuable and well recyclable polyolefinpolymers with PET (sometimes opaque; see
Figure 25), which cannot be recycled by polyolefin existing recycling companies specialized in PE or PP.

Another development leading to reduced recyclability is the usage of filler material (like chalk). This increases
the weight, which in turn causes the material to be sorted out as residual waste during the mandatory swim-sink
separation (a mandatory step in the recycling process of polyolefin; for more details see annex 8.3).


Kenya Plastic Action Plan 70

Also, material composites, which are hard to separate, should be avoided as much as possible. For instance,
the attached lid on bottles has to be cut off of the bottle and is disposed as residual waste at landfills instead
of being recycled (see Figure 26).

Moreover, the combination of incompatible materials (PET bottles with full sleeves made of non-PET) or the
usage of fully coloured (opaque) PET material significantly lowers existing PET recycling.

Thus, it is recommendable to create recyclable design standards for selected packaging and non-packaging items.

Figure 26: Attached lids on Bottles

Figure 25: PET substitution

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Kenya Plastic Action Plan 71

Modulated fees
Incentives for an improved product design for increased recycling can be incorporated into economic instruments
like taxes or EPR fees. In France and Italy, for instance, the EPR participation fee for plastics is dependent on the
recyclability of the plastics packaging, meaning that the fees for non-recyclable plastics packaging are significantly
higher. Thus, using non-recyclable packaging is significantly more expensive for companies putting this packaging
onto the market. The criteria for recyclability and non-recyclability are clearly defined and transparent. In the
case of France, the EPR participation fee for non-recyclable packaging is twice as high as the fees for recyclable
plastic packaging.

The approach of modulated fees is being gradually implemented in other European countries to provide monetary
incentives opposing the trend of non-recyclable packaging design and increase actual recycling. Moreover, this
instrument is powerful for raising awareness among packaging and product designers for the topics of EoL
and recycling, informing them and transferring knowledge about the issue of recyclability upstream the supply
chain. A bonus on the EPR levies for recyclable product design is only granted for products which deliver proof
of their recyclability. Usually, the recyclability is determined and certified by external institutes and based on
regulations and requirements set by the legal frame or PRO.

Moreover, modulated fees can also be applied for the usage of recyclates in the product: If the product contains
recyclates, a bonus lowering the EPR levies is granted. This can roughly be verified through the annual production
quantities, annual usage of virgin materials and the annual usage of recyclates.

5.2.4 Consumer awareness – communication and education
Complementary to the actions which need to be taken upstream and downstream of the value chain, inclusion of
the consumers in the transition to a circular economy has to be targeted. Achieving increased plastics recycling
rates is dependent on changing the consumer attitude towards waste. Awareness of the benefits of a proper waste
management as well as the adverse effects of an improper waste management is a key element to start this change.
In addition, a lack of awareness of waste, its effects on health and on the environment contribute significantly
to mismanagement of waste. From communities to schools and universities, to businesses, organisations and
governments: All of them play a role in building a culture in which effective waste management systems thrive.
There are various means to raise awareness among consumers, such as:

• Guidelines and signs
• Printed media
• Digital media
• Environmental education programs in schools
• Events and campaigns
• Eco-labelling schemes
• Marketing
• Product fees

Consumer awareness starts on an individual level and can be raised through multiple tools. Educating people
on the best ways to deal with waste and keeping them updated with the latest strategies and decisions related
to waste and waste management can significantly change the way waste is handled. An overview of selected
global examples is presented in annex 8.10.


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School education for long-term impact
One of the most powerful tools to achieve better waste
management are environmental education programmes
at schools, as it is easier to impact children’s behaviour
than that of adults. Children can also be an active part
in the learning process by transferring their knowledge
to their parents, close family, and community. Teaching
children from an early age also guarantees a long-
term impact, because those children will grow with
the knowledge, then pass it on to later generations.

Schools can become a main driver of change needed to
achieve a better waste management: The first step is
to introduce informative curricula about waste, waste
management, and the results of improper handling
of waste, as well as the best practices to deal with
waste. Integration of waste management curricula in
different classes such as science, social studies, etc.,
helps students to link mismanagement of waste with
the effects it has on health and the environment. It
also instils in students’ minds that waste is inseparable
from their lives, and that it can become – if properly
treated – a valuable resource for new products and
applications offering economic and social benefits,
such as introducing different careers in the environment and waste management sectors in the future.

In addition to curricula, workshops, events, and campaigns are considered essential tools to practically educate
children on waste management. Engaging children in activities that combine theoretical and practical knowledge
will enhance their critical thinking and analytic and problem-solving skills which enables students to make
informed decisions about waste issues.

Successful examples in other African countries can be found, for instance, in Ghana (see green box).

Product fees as customer incentive for reuse of single use plastics (SUP)
Single use plastics (SUP) are globally recognised as growing problem: due to their convenience, their global
demand has been increasing; however, since they are usually only used once and then disposed of, they have
a very short in-life phase and generate significant quantities of waste. Solutions to better deal with the arising
quantities of SUPs are in demand, such as charging a product fee when selling certain SUPs to incentivise the
reuse (one of the three key principles of circular economy) over a new purchase. Although the charges are
usually minimal, it is enough to incentivise the reuse as means to save money, which is thus highly effective in
countries with price-sensitive consumers.

Generally, it is possible either to increase the price when handing out an SUP (often used for carrier bags) or to
give a discount for bringing one’s own (reused) SUP (e.g. on coffee-to-go cups). Which of the two possibilities
is Kenya introduced a full ban on the use, manufacture and import of all plastics bags used for commercial and
household packaging made of PE (see chapter 3.1). For other carrier bags which are sold at supermarkets, the
supermarkets collect a fund from the sale of these bags. Other types of SUP products are still available, such
as single-use coffee cups.

In Ghana, the NGO Environment360 works with
schools through programs that focus on teaching
children about the proper segregation of waste at
source; and introducing them to the green economy
and green technology careers. They also collaborate
with the Ghana Recycling Incentive Program for
Schools (GRIPS) to help schools save money by
reducing their waste, and to earn rewards for proper
waste segregation.

Moreover, Environment360 runs volunteering
programs in which volunteers participate in
the initiatives and activities organised by the
organisation at schools and communities. An
example is the annual Float Your Boat competition,
where children design and build boats using plastic
bottles and then participate in a race in order to
raise funds for environmental education programs
in coastal and urban regions in Ghana. ‘Float Your
Boat’ also teaches students how to segregate waste
and helps them discover exciting ways to reuse
their plastic waste, thereby reducing the amount
of waste generated.

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Kenya Plastic Action Plan 73

5.2.5 Biodegradable plastics
The term ‘biodegradable plastics’ is oftentimes (incorrectly) used in reference to both bio-based plastics as well
as biodegradable plastics. However, as described in chapter 2.1, bio-based plastics are derived from renewable
sources such as sugar cane and processed into plastic polymers like PE. Bio-based plastics can be recycled just
like conventional plastics. In contrast, biodegradable plastics are characterised by their ability to be degraded
by microorganisms into water, carbon dioxide (or methane) and biomass under specified conditions. However,
biodegradable plastics can be manufactured from both fossil as well as renewable sources [PlasticsEurope, 2018].

Biodegradable plastics are used for a wide range of applications, such as organic waste collection (e.g. as kitchen
waste bags), and agricultural purposes (e.g. as films). They can be foamed into packing materials, extruded, and
injection-moulded in modified conventional machines.
Different types of fillers can be used with the system,
such as wood flour, lime, clay or waste paper. Most of
the applications for which they are used have a short or
very short in-use phase. For instance, there are drinking
straws and coffee capsules made of biodegradable
plastics available [PlasticsEurope, 2017].

To ensure that biological treatment, such as composting,
is a sustainable waste management option, both the
biodegradability and compostability as well as the
resulting compost and digestate have also to comply
with the appropriate standards.

However, the critical side to biodegradable plastics is that these plastics can only be degraded under certain
temperatures, oxygen availability and humidity, and in the presence of certain microorganisms. These conditions
cannot be guaranteed either during conventional composting or at landfills. Biodegradable plastics can contribute
just as much to litter and the existing waste problem as conventional plastics as long as there is no proper
collection, sorting, and recycling or composting infrastructure.

Even in case of a proper waste management chain, there are several critical issues regarding treating biodegradable
plastics in composters:

• Most industrial composters are not able to create the specified environmental conditions, i.e. biodegrad-
able plastics will not be degraded in them and will instead become a contaminant in the compost [DUH,
2018]

• The quality of degraded biodegradable plastics does not fulfil the requirements for compost quality (e.g.
European standard EN 13432) leading to contamination [DUH, 2018]

• Biodegradable plastics do not hold many soil substances and merely degrade into water and CO2; there-
fore, from an environmental point of view, incineration with heat or electricity generation would be a
preferred option [DUH, 2018]

• Inaccurate claims over the compostability of biodegradable plastics might confuse consumers or even trick
them into thinking that littering these plastics is not harmful to the environment as they are degraded,
which is not the case, as was recently shown in research by the University of Plymouth, where biodegrada-
ble plastics bags were able to hold shopping items even after three years of being buried in the soil or the
sea [Williams, 2019])

The usage of biodegradable plastics does not
pose an advantage over conventional plastics,
particularly in comparison to sturdy and long-
lasting materials such as cotton or thick plastics
suitable for reuse which have more advantages.
Repeated usage of the material through recycling
is more environmentally friendly than the loss
of the material through degradation. For their
decomposition, biodegradable plastics require
certain temperatures, oxygen content and humidity
which would be difficult to achieve outside a
laboratory.


Kenya Plastic Action Plan 74

Another term, which is often brought up in relation to biodegradable plastics are oxo-fragmentable plastics.
Oxo-fragmentable plastics are plastics which can be characterized by the fast fragmentation after usage –
however, they are not decomposable. Therefore, the fragmented plastic particles remain in the environment as
microplastics litter, contributing to environmental degradation.

5.2.6 Integration informal sector
Informal collectors and recyclers are increasingly recognised for creating value for their cities and countries. They
contribute in form of lowering waste quantities, conserving resources, lowering CO2 emissions and especially
supplying the local value chain with recyclable material.

The same applies for Kenya, where informal waste pickers collect relevant amounts for subsequent, rather
formalised recycling. However, the situation is insufficient both for the people working in these informal relation
as well as for the effectiveness of the waste management.

The situation for the informal collectors is highly exploitative as;

• their income is irregular,
• their social situation is insecure,
• they are exposed to high health risks,
• they are vulnerable to unfair business practices and
• they lack access to social security systems.
• from a waste management perspective, a mainly informal system is inefficient as
• only valuables will be collected, while invaluable materials remain uncollected (waste picking, no cleaning

service),
• collection occurs only in areas with demand for recyclables (in proximity to the facility and/ or trading point),
• formal collection of remaining waste will become more expensive (because valuables are already removed),
• informal collection and separation often contribute to littering.

This is why informal workers should be integrated or formalised in waste management practices, especially
EPR systems. In this context in Kenya, a few initiatives have already been established (see examples of Mr.
Green Africa and Clean Green Kenya). Their implementation should be evaluated in relation to positive impact
mechanisms for expansion all across Kenya. From a social sustainability perspective, it is necessary that the
involved persons keep their source of income.

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Kenya Plastic Action Plan 75


Kenya Plastic Action Plan 76

6.1 Implementing the EPR system
As analysed before, the general waste management structure as well as the plastics waste management
structure in particular lack organisational and financial resources in Kenya, which can both be improved through
the implementation of an Extended Producer Responsibility (EPR) system. The basic mechanisms of an EPR
system were introduced in chapter 5.1.2, complemented by a few global examples. Also, the first steps towards
implementing an EPR system in Kenya have already been initiated.

As previously explained, EPR systems allow for a proper and practical strategy to address the plastics situation
through their steering function on material usage (upstream) and the operative waste management system
(downstream), especially collection and recycling. The first and foremost priority with regards to developing an
EPR system for plastic packaging and other specified plastics items is defining the organizational responsibilities to
create a sound Producer Responsibility Organization (PRO). The subsequent paragraphs outline the implementation
of an EPR system in Kenya under the given contextual conditions in order to define policy recommendations
for a policy framework for a transparent and fair system, which ensures that funds are only spent on waste
management purposes and competition between the stakeholders along the supply chain is kept alive.
For the waste management practice, this implies:

• Transition from picking and collecting valuables to cleanliness as a service.
• Transition from individual responsibility (take-back schemes) to collective action.

These transitions require that the following aspects are defined in detail, tailored to Kenyan conditions:

What are the first important steps for implementing an EPR system in Kenya?
Against the Kenyan background system, it is crucial to establish a system that is;

i) based on an aligned understanding and planning throughout the private sector, and
ii) robust enough to work, yet quick and easy to implement. Thus, it is essential to establish a system which

includes all stakeholders in the supply chain, designates unambiguous rules to the obliged companies and
guarantees a level playing field.

As indicated in the name EPR, extending the producer responsibility is initially a purely economic topic. In almost
all well-functioning systems, this obligation of the economy is accompanied by the fact that such a system is also
initiated and implemented by the private sector. Also in Kenya, the first steps facilitating and influencing the
setup of an EPR system should be initiated by the private sector, ideally organised through business membership
organizations (BMOs) such as Kenya Association of Manufacturers (KAM) or Kenya Private Sector Alliance
(KEPSA), for instance. Moreover, they can ensure that all stakeholders along the supply chain are involved in the
process. This applies under the condition that there are external control and validation bodies. The advantage
in that is the opportunity for the obliged industry not only to react but also to shape and tailor the system to
local and economically viable conditions.

At the same time, political decision-makers need to be involved in the process as well in order to prepare the
respective legal framework. As several branches are potentially affected – for instance environment, transport,
economics – it is important to include decision-makers from all of these fields. Furthermore, existing political

6. Implementing the Action Plan


Kenya Plastic Action Plan 77

actions need to be put in congruence and existing legislation clarified in regards to certain aspects as, for example,
providing sufficient details on concrete measures to be taken.

Adapting and passing a legal basis is a process which takes time. Thus, it is recommended to found a voluntary
PRO, potentially supported by the resources of an existing BMO such as Kenya Association of Manufacturers
or Kenya Private Sector Alliance in which companies and organisations can organise themselves, collectively
negotiate with the decision makers about the setup of the mandatory system. Voluntary projects related to EPR
can be operated in order to gain first experiences. The participation in the PRO will then become mandatory after
the law has entered into force. Simultaneously, additional measures based on the legal basis need to be created.

Recommendation on financing the first steps
The first steps are financed through the voluntarily participating companies, which are stakeholders in the plastic
value chain. As the process of establishing an EPR system is complex and requires time, it is recommended to
support the process (implementation of PRO, first measures and pilot projects, discussions about legal frame)
through external third parties. Therefore, a project should be initiated which builds on the Kenya Plastic Action
Plan and advances it. Moreover, it is likely to receive funding particularly from European states since the plastics
waste issue is currently a topic of high importance. The Kenya Plastic Action Plan is a suitable basis to apply
for respective funding.

How should the EPR system be set up?
It is required to ensure the highest level of transparency possible for the EPR system in order to establish a
foundation of trust and acceptance. Against this background, it is recommended to start with;

• only one EPR system and one PRO or
• one PRO umbrella organisation uniting the existing schemes like PETCO and Clean Green Kenya

which, in the beginning, exclusively regulates the financing and organisation of defined plastics. Moreover, other
complementing economic instruments, such as landfill taxes, should be implemented in parallel for the proper
treatment of plastics, covering areas that cannot be covered by the EPR system (see chapter 5.1.1).

One industry owned PRO can be initiated within the organizational resources of an existing business member
organization such as Kenya Association of Manufacturers or Kenya Private Sector Alliance. It should pursue –
as part of its statutory purpose – a public service mission regarding the collection, recovery, and recycling of
the plastics waste covered by EPR. In light of transparency issues, this PRO should be a non-profit organization
which acts as a superior institution independently from the individual companies and interests.

The private industry is widely aligned to establish an EPR system which is in the hands of the private industry
and a PRO which is run as non-profit organisation; this reflects the ideal setup of a PRO that covers all plastic
fractions equally.

It is also possible to establish different PROs for different plastics fractions. However, this comes at the expense
of registration, controlling, monitoring and transparency. Moreover, it needs to be agreed upon how to finance
joint responsibilities (e.g. awareness-raising and education) and how to balance out the unequal values of the
different plastic fractions. In addition, it needs to be defined how the different PROs assume responsibility for
the disposal of the residue originating from the mixed collection and subsequent sorting and how the costs for
disposal are divided between them.


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How are the different stakeholders affiliated with the PRO?
The PRO is the most important stakeholder (organisation) within an EPR system. This organisation is responsible
for setting up and developing the system. In order to transform their individual responsibility, which has been
fulfilled in Kenya through the various take-back schemes, to a collective one, the producers/users, importers
and fillers should give a mandate to the industry-owned PRO. Thereby, the PRO becomes responsible for the
fulfilment of all take-back obligations of the obliged companies as the representative entity.

All stakeholders in the supply chain should participate in the PRO. Thus, they should become members in this
new organisation. There should be four different forms of participation:

i) Obliged companies (more details below): producers/ users, fillers, brand owners who bring their plastic

packed goods and plastic products onto the Kenyan market. These companies pay a product-based fee that
is proportional to the amount in weight of plastic items they introduce to the market, which is then used to
finance all waste management services.

ii) Members: Companies which are part of the plastics supply chain. This includes raw material suppliers, plastic
packaging and product converters, designers, manufacturers, retailers and traders, and waste management
operators for collection and recovery, especially recycling. These companies should pay a membership fee
to the PRO for the operation of the PRO.

iii) Affiliated members (advisory board): This includes offices of the National government, Counties, universities,
NGOs, and other authorities. None of the affiliated members have to pay a membership fee. These institutions
and organisations impact the work of the PRO as an advisory board and therefore need to be informed about
recent developments, innovations and novelties, as well as similar updates.

iv) Management (executive board): The PRO needs an executive board to manage the operative work, financial
spending and controlling. This management can consist of one or several persons which can be either chosen
by the members or externally appointed. Generally, it is recommended to appoint one chair and a vice chair.

Which plastic items (packaging/ non-packaging) are covered by the EPR system?
In most cases, EPR systems for plastics are set up for plastic packaging, while non-packaging plastic items are
usually not covered by the EPR system. However, as EPR has the best steering function both upstream and
downstream, it is recommended to include both plastic packaging as well as other non-packaging plastic items
in the EPR system to achieve better results in recycling and waste management. Moreover, the EPR system will
include all sources of waste generation as it best reflects the Kenyan situation.

Thus, it is recommended that all plastic based packaging (food, non-food, industrial, and transport packaging) as
well as composite packaging, which consist of plastics and at least one other material, are included. Quotas for
how high the plastic content has to be to be obliged to take part in the EPR system need to be defined. Possible
suggestions include at least 50 % of the packaging having to be composed of plastics; however, other percentages
are also possible. Since packaging items are consumed quickly and thus have a short in-life phase leading to
near-time waste generation, the preferred approach is to cover as many plastic items as possible in the scope of
the EPR system. In addition, the collection and recycling structure for the different types of plastics concerned
(PET, HDPE, PVC, LDPE, PP, PS, others) will be improved. Generally, it is also possible to create separate EPR
systems for household waste and non-household waste (i.e. industrial and transport; secondary packaging) as
it is done for instance in other countries such as Germany.

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Kenya Plastic Action Plan 79

In addition to the plastic packaging, other plastic items which can be covered by an EPR system should be
included. This has to be decided on a case-by-case basis by designated decision-making bodies. This concerns
particularly plastic items, which are similar to packaging, for instance plastic buckets, plastic hangers, plastic
bags and single use plastics (SUPs) (see, for instance, the EU SUP Directive). These additional items also need
to be clearly outlined in the legal frame.

It is recommended to clearly label plastic packaging and selected plastic items which are covered by the EPR
system and take part in it by paying the fees. Once an obliged company pays, they are allowed to add the label
to their packaging and/ or products (comparable to “Green Dot”).

Thus, companies introducing plastic packaging (sold to private households, agriculture, industrial and transport
packaging) and/or other plastic items covered by the EPR system on to the Kenyan market as laid out in the
legal frame, are obliged to participate (they are ‘the obliged companies’). Moreover, it means that the following
applications are excluded from the EPR scope: packaging for hazardous content, and other non-plastic packaging
materials and plastic items that cannot be covered by the EPR system like plastic items for permanent built-in
components such as pipes.

As mentioned, other non-plastic packaging is currently not included, while in most countries with EPR systems
generally all packaging materials are covered. This is meant to keep a balance between the various packaging
materials and thereby avoid undesired, ecologically questionable substitution effects of different packaging
materials.

Who are the obliged companies that have to pay for the EPR system?
In an EPR system, it has to be legally determined who has to pay for the system and through which interface
these obliged parties can be identified. As aforementioned, the obliged companies are based on the definition
of which plastic items (packaging and non-packaging) are covered by the EPR system. Moreover, it is a de-
termining requirement that these plastic items are put on the market in Kenya for consumption in Kenya i.e.
will become waste in Kenya. Thus, these companies have to finance the operation of the waste management
services. In particular, this includes two groups (see also Figure 27):

• Users (producers)/ fillers for the sale of their packed goods in Kenya for consumption in Kenya
• Importers for the sale of their goods in Kenya for consumption in Kenya

Through which interface can it be ascertained which packaged goods and other
non-packaging products are being put on the market in Kenya?
The obliged companies (see definition above) comprise of:

• Plastic packaging which is filled in other countries and is imported to Kenya
• Plastic packaging which is filled in Kenya and consumed in Kenya
• Other non-packaging plastic products which are imported to Kenya
• Other non-packaging plastic products which are produced, sold and consumed in Kenya

To measure the exact amounts of these items, the following criteria can be used: sales revenues (in the respective
segment), mass (weight), number of items, filling volume, and area. In most countries, mass has beenproven as
the most practical measurement unit; some countries, such as Spain, also have an additional number of item
-based fees.


Kenya Plastic Action Plan 80

Figure 27 illustrates the most suitable interface for the steps in the supply chain when the items are introduced
onto the market.

Figure 27: Interface for determining the obliged companies

How to oblige the informal packaging users?
Since the informal sector is not only limited to waste operators but also includes packaging users, it is important
to integrate these informal packaging users into the EPR system; it is of major importance as the majority of
the domestic packaging users belong to this group. Thus, it is crucial to find an approach which also financially
covers these plastics quantities in the EPR system. One possible approach is to oblige the manufacturers that
are selling packaging material to these non-licensed packaging users to pay the fees for them, instead of levying
informal businesses directly. This should be complemented by a definition of a maximum quantity of packaging
per year (e.g. 300 kg per year) per user. In turn, the manufacturers forward the costs for paying the EPR fees to
the non-licensed packaging users in form of a surcharge. This economic incentive is aimed at the non-licensed
users to integrate themselves into the system in the long run: if a packaging user shows their licence which
verifies their participation in the EPR system, no surcharge from the manufacturer is raised as the packaging
users pay their levies directly to the EPR system for the packaging used in the Kenyan market.

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Kenya Plastic Action Plan 81

How much should be paid by the obliged companies?
The exact amount that needs to be paid is proportional to the specific goals which are pursued. To keep the risk
of under- or overestimating the costs needed for the waste management task financed by the EPR system as low
as possible, it is recommended to pursue specific measures as goals as their costs are the easiest to calculate.
Since the PRO should be set up as a non-profit organisation, the total amounts paid by the obliged companies
should equal the expenses for all waste management costs. To calculate the costs, it is required to estimate;

i) the amounts of waste which will arise from the plastics items covered by the EPR system, and
ii) the costs needed for the treatment of these amounts of waste.

It is recommended to calculate a defined amount (per material and mass) which will be evaluated after three to
five years and adapted to developments and trends. It is also possible to introduce modulated fees to provide a
steering function in regards to recyclable product design (see chapter 5.2.1).

To provide an idea on the expected costs, an overview of current EPR fee models is provided. It should be noted
that the underlying EPR systems are well established and in some cases comprise only household packaging (H).
Others also include commercial and industrial (C/I) packaging, as it is also recommended for Kenya. The fees are
ultimately adapted to the prevailing conditions (including underlying infrastructure, measures to be financed,
costs, organisation and control).

Table 5: Plastic packaging fees in EU-28 EPR schemes [Watkins et al., 2017]

Plastic (general
unspecified)c

PET/ HDPE Beverage cartons
Other/Composite

Material
H C/I H H C/I H C/I

Austria (ARA) 0.6100 - - 0.5800 - 0.6100 0.1000

Belgium (FOST-PLUS) 0.2823 - 0.2107 0.2455 - 0.2823 -

Bulgaria (EcoPack) 0.0800 0.0800 - - - 0.1000 0.1000

Croatia (Eko-Ozra) - - 0.0550 0.0550 0.0550 0.1000 0.1000

Cyprus (Green Dot) - 0.0380 0.1060 0.1230 - - -

Czech Rep (EKO-KOM)
0.2060

> 5l: 0.1540
0.0220 - 0.1580 - 0.2230 0.2230

Estonia (ETO) 0.4090 0.1090 - 0.1050 - - -

France (Eco-Emballages / CITEO) 0.3120 - - 0.2470 - - -

Greece (HE.R.R.Co) 0.6600 0.6600 - 0.5700 0.5700 - -

Hungary (Ökopannon) 0.1850 - - 0.0620 - 0.1850 -

Ireland (Repak) 0.0892 0.0892 0.0892 0.0758 - - -

Latvia (Latvijas Zalais Punkts) 0.1490 0.1490 - - - - -

Lithuania (Zallasis taskas) 0.0810 0.0810 0.0810 0.1220 0.1220 0.1250 0.1250

Luxembourg (Valoriux) - - 0.3703 0.2835 0.2835 - -

Norway (Gront Punkt) 0.3876 0.3876 - 0.1200 0.1200 - -

Poland (Rekopol) 0.0046 0.0046 - - - - -

Potugal (Sociedade Ponto Verde) 0.2319 0.2319 - - - - -

Romania (ECO-ROM Ambalaje) 0.1330 0.1330 0.1330 - - - -

Slovenia (Slopak) 0.1340 0.1340 0.0770 0.0100 0.0100 0.1340 0.1340

Spain (Ecoembedes) 0.4720 - 0.3770 - - - -

Sweden (FTI) 0.2440 0.2200 - - - - -

H = households; C = commercial; I = industrial; all prices are per kg


Kenya Plastic Action Plan 82

It is recommended to price all plastics that consist mainly of mono materials with the same amount. An exemption
to this could be made for special cases, e.g. PVC from household packaging, since there are no proper recycling
options in place in Kenya. The same applies for opaque PET packaging and PET trays in general. In order to
balance packaging fees for beverages, it is also recommended to define a levy for beverage cartons. Otherwise,
this could lead to unexpected substitution effects.

The price of composite packaging, meaning packaging made of different materials (e.g. material composites
that cannot be manually separated and of which none of the used materials exceeds more than 95 % of the
total composite packaging weight) should be comparably high. This is due to the fact they are not or only poorly
recyclable, both in quality as well as in quantity.

In an initiating phase of implementing fees, the same prices should be used for both household packaging and
additional products as well as plastics packaging and additional products from commercial and industry resources.

Recommendation for modulated fees
Modulated fees are not the first step to be taken when implementing an EPR system. Even in Europe, this
approach has been in place for only three years. In the Kenyan context, the initial focus should be on increasing
the recycling of plastics. Against this background, a regular forum should be established that acts as a platform
for recyclers and collectors to discuss recent challenges and problems and to discuss potential solutions to
increase recycling. This step is followed by developing standards for specified products and packaging categories,
followed eventually by modulated fees.

As a recommendation for practice, formalised and informal collectors and recyclers should come together to
identify the problems which they are facing in the daily business in regards to product design (see chapter
5.2.3) and summarise them in a guide as a basis for discussion with the plastic producers. Based on this guide,
a standard should be developed at a later stage. Please note that modulated fees do not equal varying fees
for different materials (as the example shows, see Table 5) – modulated fees are a measure to implement an
incentive to further advance recycling in an already well running and balanced EPR system.

What are targets of the EPR which should be fulfilled by the PRO?
The overall system of the EPR is the establishment of collecting, sorting, and recycling infrastructure for plastics
which are covered by the EPR system. To achieving this, several types of targets are possible:

a) Quotas (collection quotas, recovery quotas): These are the most common targets used in established EPR
systems. In the current Kenyan situation, the challenge arises that quota attainment is poorly controllable,
as e.g. the absolute size of the marketed quantity is unknown and a number of participants are difficult to
identify. Prospectively, the inclusion of a quota is possible with further development of the EPR system.

b) Rate of linkages to system: This means that within a certain period of time, a certain proportion of the
population should be linked to a waste collection structure (for example, after five years, 20 % of the
population must be connected to an infrastructure). Again, it is difficult to control the achievement of goals,
since a formal collection structure has not been achieved yet in large parts of the country.

c) Specific waste management measures: Alternatively, specific, measurable waste management measures
can be specified for the abovementioned goals. They can be increased in the course of further development.
This has the advantage that the costs can be calculated more precisely (i.e. the financing requirements of
the PRO), be better controlled and react more flexibly towards unexpected developments. In Spain, the EPR
system was initially implemented with such targets.

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Kenya Plastic Action Plan 83

For Kenya, it is recommended to use c) specific waste management measures. Regarding implementation, it
needs to be noted that some measures need to be reconciled with third parties like the Counties. Deciding on a
recycling quota or the increase based on the status quo is not recommended as there is a lack of reliable data.
Therefore, determining a specific minimum (e.g. 50,000 mt) of annually recycled plastics, which needs to be
achieved within a defined period of time, is more suitable (e.g. 3 a).

The establishment of a reliable reporting and controlling system as basis for monitoring and progressing of the
system is essential. The controlling focuses on three dimensions:

i) Fulfilling the operational services of the PRO: The PRO structure needs to be transparent. This enables
visibility on potential misconduct of single deciders within the organization and allows for the structures to
be adapted accordingly (particularly important in the initial phase).

ii) Prevention of free riders among the obliged companies: An effective measure is to register all obliged
companies to report their amounts of plastic packaging and additional plastic items covered by the ERP
system. In other states, it has been proven successful to publish the registered obliged companies (e.g. via
website). This way, free riders can be identified by the authorized controlling body and also by competitors.
Furthermore, with the published data it is possible to validate plastic amounts at least roughly by gaining
knowledge about the sector and revenues of the single companies.

iii) Fulfilment of operational performance by waste management operators: It is important that all stakeholders
(collectors, sorters, recyclers) which provide services to the PRO are paid correspondingly and are also
registered and licensed. This also includes a general suitability assessment. As an additional key element,
the mass flows which are handled by them as part of their operative business need to be documented.

Who is controlling and which instruments are suitable?
It has to be anchored in law who is responsible for the success of the EPR system. Three different control
mechanisms can be distinguished. It is recommended to regard all three elements with the following tasks, which
correspond with the interests of controlling parties:

i) Self-assessment: This control is based on the principle that every deviation from the rules leads to market
distortion (if one party does not fulfil their responsibilities and duties, all other involved parties have to
bear the resulting disadvantages, e.g. free riders). Thus, registration, data gathering, reporting as well as
accounting of the funds should be in the hands of the PRO. The PRO installs a controlling mechanism based
on self-interest, which specifically focuses on the prevention of free riders.

ii) Control by a public agency (defined by the state): The responsible controlling agency has to be explicitly
named in the law and needs to be staffed with knowledge and finances. The controlling tasks cover the
fulfilment of the operative task of the PRO with regards to achieving the targeted goals (collection and
recycling). This can be done through both random on-site controls as well as through controlling the reports
of the PRO in terms of the fulfilment of the targets.

iii) Public control: This describes well informed consumers, who can recognise misconduct and point out
mistakes of the operative management.

For developing a legal framework, only the control by a public agency has to be defined. Therefore, the competent
authority has to be specifically named. In most cases, a new section in the Ministry is created which is only
responsible for the EPR act. They control and validate e.g. reporting by the PRO that declares the fulfilment of
the EPR aim.


Kenya Plastic Action Plan 84

Which taxes/ levies should be implemented additional to the EPR system?
In case of a well-running EPR system, no further taxes or levies in the sense of penalties for users, importers
and fillers of packaging as well as for additional plastic products are needed, as it would otherwise be a double
payment. The monetary steering function of an EPR system is particularly effective if poorly recyclable plastic
products and packaging items are significantly more expensive.

For economic impacts that currently burden the Kenyan recycling, it is necessary to implement additional taxes
or levies in the long run. This means limiting the possibilities of cheap landfilling and disposal. For this, improper
disposal needs to be penalised and the gate fees of existing landfills need to be increased. The raised gate fee has
to be used aimfully for redeveloping measures of landfills and dumpsites as well as developing waste management
in general. This strategy can only lead to successes if illegal dumping is strictly controlled and prohibited.

How can the Counties/ local authorities be included?
A close partnership between the Counties/ local authorities and the industry-owned EPR organisation is
a relevant condition for the success as well as the economic and environmental sustainability of the EPR
compliance scheme.

Municipalities/ local authorities have several key roles to play, as they

i) Help to set up the collection points
ii) Agree with the EPR organisation on the most appropriate collection system, taking into account local

particularities and the conformity with national requirements.
iii) Cooperate with the EPR organisation in regards to:

• local public communication and awareness programmes
• data gathering and monitoring
• controlling the waste management operators and
• tendering for collection services and pilot projects

How can the licences and fees for waste collectors and recyclers be harmonised?
A fair and transparent EPR system requires the equal treatment of all participating stakeholders nation-
wide. This also includes licences and fees for collection, transportation and recycling. Thus, discussions are
needed with the competent authority granting these licenses upon EPR implementation. In Kenya’s case, the
respective entity is most likely the National Environment Management Authority (NEMA). Unequal licences
and requirements will inevitably lead to imbalances in the waste management and recycling sector.

At the same time, the already existing registration system for collectors and recyclers can be integrated into the
EPR system. For instance, it is possible that only registered companies are allowed to participate. This requires
equal treatment and harmonization as well as countrywide integration and formalisation.

In case different fees apply, they have to depend on legal framework conditions. The size of the company (No.
of employees), processed amount and/or turnover are possibilities to be defined in this case.

6. Implementing the Action Plan


Kenya Plastic Action Plan 85

Which responsibility does each stakeholder have in the proposed EPR system?
The following Table 6 summarises the role of all involved stakeholders in the plastic supply chain in Kenya.

Table 6: Role of each stakeholder within the proposed Kenyan EPR system

Stakeholder Role

Manufacturers of packaging material
or of packaging and additional plastics
products

• should enable reuse and ensure recyclability of packaging materials
and should use secondary raw materials where possible

• exchange (forum) with collectors and recyclers in order to improve
recyclability and standardisation

Consumer goods companies
(users, fillers and importers)

• obliged to pay fees to the EPR system for the plastic packaging ma-
terial of their packed goods and additional plastic products

• need to be registered with PRO

Distributors/retailers • can optionally be obliged to take packaging and selected plastic items
back and to ensure their proper handling

Consumers • have to be informed about strategies for waste reduction and prop-
er collection (incl. participation in pilot projects for e.g. separate
collection)

• public control

Waste management operators
• receive funds from the EPR system for their services for handling

packaging waste

• need to be registered with PRO/ authority

Public institutions
• legislation and supervision of the EPR system

• registration of waste management operators

• support pilot projects

Counties and municipalities • support collection and recycling or collect themselves

• inform consumers

• take part in pilot projects


Kenya Plastic Action Plan 86

6.2 Implementing voluntary measures
As the setup of an EPR system is the central element for creating the financial and organisational basis, the
proposed measures based on chapter 5.2 are connected to the proposed EPR approach.

For stakeholders along the plastic supply chain, especially companies proposed to be obliged it is beneficial to
participate right from the start as this offers them the possibilities to

i) Actively shape the system which will become mandatory
ii) Be connected with the public authorities
iii) Be well prepared instead of only reacting
iv) Give them an indirect benefit compared to their non-participating competitors as they are better prepared

In order to do so effectively, it is recommended to found an organisation which will act as pre-organisation
to the PRO (so called PRO pre-organisation). Voluntary participation is, however, not limited to the obliged
companies – developing a tailored system should be done by all companies and organisations along the plastic
supply chain.

The following measures should be organised, prepared and financed by the pre-organisation. However, these
funds are independent from the fees which are paid within a mandatory EPR system by the obliged companies.

Implementing a pre-organisation is a lengthy process with several tasks and steps to take. Hence, to supporting the
development of the pre-organisation through international funds should be discussed. For instance, this includes
the implementation of a suitable legal status of the organisation as well as the preparation and development of
internal sections and departments.

Which measures on a voluntary basis are recommended?
Prior to the formalised implementation of and EPR system it is recommended to first gain practical
experiences on a voluntary basis; these will then be evaluated in regards to the further development. These
are voluntary projects and have to be clearly defined in order to keep the costs calculable and the risk low.
This is crucial for the voluntarily participating companies. Suitable pilot projects relate to the evaluation and
improvement of collection, recycling and monitoring, e.g.

• Separate collection and recycling of plastics or recyclables in general in specified sectors (e.g. schools,
universities, retailers/malls, eco-tourism etc.) and/or areas (rural touristic areas, inner city etc.) that serve
as a role-model character to scale up nationwide.

• Increase sorting, e.g. through providing technical plants, space and/ or aggregates tailored to the regional
conditions.

• Increase of technical equipment and knowledge for the respective operation, e.g. press and fork lifter to
optimise transport processes.

• Increase environmental education and communication, e.g. through creating a forum and consumer awareness
campaigns with a focus on middle income households.

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Kenya Plastic Action Plan 87

Promote segregation at source as best practice and waste collection
As waste segregation at source is only done to a very limited extent, it is important to initiate pilot projects for
waste segregation to start gaining first experiences and introduce the consumers gradually to this practice.
Such pilot projects can be introduced in various fields, as shown below:

• Waste segregation in schools and universities: Schools and universities are ideal places to initiate waste
segregation at source as the children and students can be well educated there, can impact their families at
home and their community, and ensure a long-term impact if educated at an early stage of life. Moreover,
schools and universities offer less anonymous environments. Segregation should be easy yet effective; for
instance, by collecting all dry recyclables (plastics, paper, metals) and the rest as residual waste. Such projects
have already been initiated in Kenya in several schools (see Mr. Green Africa). The material segregated and
collected at the schools needs to be regularly collected by either the counties / municipalities or private
companies and verifications about the collected quantities, sorted and recycled quantities and revenues and
finances. Simultaneously, a corresponding sorting needs to be developed.

• Companies, organisations, ministries and other public agencies: Similar to the set-up at schools and universities,
waste segregation projects can also be initiated at companies, organisations, ministries and other public
agencies, which are willing to become role models in this field and educate their employees and members.
Also here, these sites offer less anonymous environments (compared to for instance big markets) and the
material segregated and collected needs to be regularly collected by either the counties / municipalities
or private companies and verifications about the collected quantities, sorted and recycled quantities and
revenues and finances.

• Eco-tourism: In the field of eco-tourism, waste segregation projects can be well established in this field with
additional focus to reduce plastics as much as possible (where suitable) and collect the remaining plastic
waste and forward it to suitable sorters and recyclers.

• Waste collection at the household level in urban areas: It is recommended to initiate pilot projects for waste
segregation at source and collection with bring banks, where the containers are set-up in the streets. It
is important to set up these containers in sufficient numbers within a defined district so that it is within a
comparably short walking distance for the inhabitants so that separating waste is a convenient activity.
Moreover, the inhabitants of this district need to be properly informed and educated about the need for
waste segregation. Additionally, a few sites for piloting kerbside collection is also recommended.

• Waste collection at the household level in rural areas: Establishing central point for waste collection, from
which the waste is collected by trucks and the recyclables directly sorted out on the truck.

• Integration of the informal sector in collection: It is important to ensure that all waste (valuable and non-
valuable) is collected opposing to collecting only the valuable waste as this leads to cherry picking (e.g. PET
bottles) while non-valuable waste (e.g. mixed plastics) as well as waste, which is difficult to collect (e.g. sweet
wrappers), remains littered, i.e. a transition from material picking to cleanliness as service is crucial. As waste
collection is mainly in the hands of the informal sector, it is important to include them in this transition. For
instance, it is possible to divide a certain area/district and assign parts of this district to informal collectors,
which are tasked to collect all littered waste and sort is subsequently after collection. They are paid for the
cleanliness of the area instead of the amounts of recyclables they collect. The amount of payment should
equal the revenues they would make from picking valuables. It is important to note that implementing such
pilot projects require a very high amount of organisation and controlling to ensure that the cleanliness is
provided.


Kenya Plastic Action Plan 88

In regards to the collection at the household level, it is targeted to establish regular collection rhythm
through formal collection. Therefore, both the Counties / municipalities as well as already existing formal
collection services need to be included in this.

In case of mixed waste collection, it is important to ensure suitable sorting as subsequent step. Thus, space
need to be identified in collaboration with the counties / municipalities, which will be assigned as sorting spaces.
These spaces should be located close to the following treatment steps and easily accessible transportation-wise.
The technical steps of the sorting should be complemented through manual sorting steps like drum sieves (for
separating particles with a size < 40 mm, which should include mainly organic particles). Moreover, the usage of
magnetic separators for removing the ferrous metals is recommended; however, this could otherwise be manually
done. Generally, the sorting should regard the existing recycling and marketing possibilities of recyclables to
generate a residual waste stream, which contains as less valuables as possible for the following disposal.

To increase the effectiveness of the transportation, baling machines that can compress the material should
be utilized on site. By making use of these, the volume of the waste is compacted; i.e. more material can be
transported per vehicle. In turn, this requires transport vehicles which are suitable for transporting the increased
weight and additional equipment to load the bales up on the vehicles are needed (e.g. forklifts).

Last but not least, collection can become also legal defined target of the EPR system, e.g. by defining how many
collection bins should be set up within a defined period of time in the public space.

Recommendation on integrating the informal sector
The informal sector plays an important part in Kenya for the collection and marketing of recyclable waste.
These pre-recycling activities should be integrated into the EPR system. The affected informal workers should
not lose their source of income. Furthermore, these workers are experienced regarding the value of recyclables,
possibilities to market the recyclables as well as challenges and problems and are thus well-qualified for formalised
companies that need employees for collection, sorting and/ or recycling. The payment for their work in a formalised
context should be higher than their revenues from selling recyclables informally. As estimated from the research
conducted for this report, their individual revenue marginally exceeds the current minimum wage. Moreover,
it is recommended to implement respective pilot projects to gain experiences on how to best integrate them.

As a functioning EPR system offers reliable organizational structures as well as a permanent financing basis,
integrating informal workers into the system offers many benefits. Generally, there are two possibilities for how
the informal worker can be integrated: either as an employee (see Table 7) or as a business partner, which offers
them the possibility to remain independent as a person but formally cooperate with established companies and
organisations (see Table 8).

Table 7: Integration of the informal sector as employees

Informal sector Integration as employees

Irregular income Regular income

Insecure social situation Improvement of the social situation

High health risk Minimisation of health risks

Vulnerability to unfair business practices Reliable and fair business partners

Lack of access to social security systems Access to social security systems

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Kenya Plastic Action Plan 89

Table 8: Integration of the informal sector as business partners

Informal sector Integration as business partners

Uncertain commercial base Fixed service agreements

Uncertain marketing conditions Reliable acceptance of recyclables

Uncertain situation for employees Improvement of employee situation

High operational risks Risk minimisation

Vulnerability to unfair business practices Controlled business practices

Waste collection will become formalised through the implementation of a mandatory EPR system, which will
increase the pressure on informal workers to integrate themselves into the system through formalisation. If not,
they face the risk of having limited access to the waste. Thus, it is crucial to integrate informal workers from
an early point onwards and inform them on possibilities and solutions. In particular, the following aspects are
crucial for the integration:

• Confidence building, trust building and highlighting potential benefits,
• Information and professional support,
• Legal advice,
• Employment contracts for employees,
• Service contracts for business partners

Promote recycling
By increasing the amounts and effectiveness of collection and sorting of plastic waste, more and more reliable
quantities of recyclable plastic waste become available for recycling. To support the formally registered recyclers,
it is possible to apply for grants or support for e.g. equipment (funds, for instance, granted by the PRO). These
applications need to be approved by an independent body and consider usefulness and necessity.

Moreover, it is recommended to identify which plastic converters would use the produced recyclates for non-
food packaging and other non-food items as food-grade applications for recyclates are very critical. As long
as recycling capacities for plastic waste are not fully developed within Kenya, it is recommended to search for
recycling possibilities abroad as an intermediate solution (until the recycling capacities have been sufficiently
increased). Please note that it is recommended to only export sorted plastic fractions which are already
prepared for recycling, but no mixed waste.

Promote product design for enhanced recycling
In light of the current Kenyan situation, it is recommended as a first step to strengthen collection and recycling
before measures like modulated EPR fees are introduced. Against this background, a recurring forum should be
established which offers a platform for exchange between recyclers, aggregators and collectors with packaging
and product designers and converters in order to;

i) share insights on recyclable product and packaging
design,

ii) discuss current developments and challenges, and
iii) jointly develop strategies and solutions to increase

recycling. Moreover, it is recommended to prepare
guidelines which entail the insights on recyclable design.
These measures should be financed by the PRO. A suitable
contact for exchanging with recyclers is, for instance,
‘The Kenya Association of Waste Recyclers’.


Proposed National Recycling Rate


Kenya Plastic Action Plan 90

From a mid- and long-term perspective, this should be followed by the development of standards for specific
product and packaging groups as well as a modulated fee once the EPR system has been set up.

Recommendation on biodegradable, bio-based and oxo-fragmentable plastics
The usage of biodegradable plastics is seen as problematic and is only recommended for limited application
purposes including those which are in a direct connection with organic application sectors (e.g. agricultural foils
remaining in the environment). It is crucial to ensure that these biodegradable plastics are degraded under the
given climatic conditions within a short timeframe. For all other applications, the biodegradable plastics are not
regarded as suitable, as they can only be degraded effectively under laboratory conditions.

The usage of bio-based plastics is not affected by this. However, it is important to note that farming the raw
materials for manufacturing these bio-based plastics competes with farming for food. Moreover, they need to
equal fossil-based plastics in the sense that they are not obstacles to recycling them.

Since oxo-fragmentable plastics fragment into plastic particles, which remain in the environment as microplastics
litter and contribute to environmental degradation, it is highly recommended not to use these oxo-fragmentable
plastics for any application; or even enact a ban on them.

Promote consumer awareness
The EPR compliance scheme should involve a strong collaboration with all stakeholders ranging from public
authorities to inhabitants and waste operators – each with a designated role to play. Recommendation: Precisely
put down in the law that the PRO needs to inform the inhabitants and all stakeholders involved in a proper and
suitable way by using various forms of media and publishing on a regular basis. There are multiple channels
which can be used for promoting consumer awareness, including social media.

It is also possible to initiate campaigns on different scales (national, regional and/ or local), e.g. in the form of
a national clean-up day or “waste week”-campaigns in schools. Waste Week is a programme designed to help
schools tackle waste and recycling both on campus and in the classroom. The Waste Week campaign is designed
to comprehensively educate and help students see the difference they can make and encourages schools to
work towards Eco-Schools accreditation (a formal award). The campaign has unique student-led activities for
the classroom and eco-teams – students are informed, inspired and empowered though the campaign to activate
change. In 2018, over 1,800 schools took part in international Waste Week. According to an evaluation of the
success;

• 84 % of schools said it helped raise students’ awareness of the issues
• 70 % of teachers said it helped encourage students to take action outside of lessons
• 98 % of Primary students and 91 % of Secondary students said the campaign made them want to protect

the environment.

6.3 Implementation Matrix
Specific measures to start action need to be continued based on the approaches which were developed as part
of the Kenya Plastic Action Plan. The central element for the implementation is the outlined EPR system (see
chapter 6.1). This revolves around a complex process in which multiple stakeholders need to be included.

6. Implementing the Action Plan


Kenya Plastic Action Plan 91

Based on the experiences from other countries, it is also a process which takes time and needs a long-term
orientation. Thus, we recommend starting with a group of stakeholders working on a voluntarily basis towards
the establishment of a legal frame. For participating companies and organisations, this would prove to be
advantageous as they can actively engage and therefore shape the implementation process (see also chapter 6.1).

Accordingly, implementation of a mandatory EPR scheme requires three main steps, which are outlined in the
following tables:

i) Establishing a legal basis for a mandatory EPR system (see ): It is recommended that a mandatory EPR
system is established through a corresponding law. This requires agreements and discussions between
competent authorities and the private industry.

ii) Establishing a pre-organisation on a voluntary basis (see Table 10): To initiate this process, a PRO on a
voluntary basis should be established as a pre-organisation for a later mandatory PRO, when the law comes
into force. Although such a voluntary system is limited in performance and effectiveness, it is suitable
in establishing the organisational and regulatory foundation and control mechanisms. Furthermore, this
pre-organisation has to fulfil self-set targets (e.g. annual amount of plastic recycled). Besides this, the pre-
organisation will conduct essential projects and measures to gain experience on how to best apply certain
measures in a Kenyan context (e.g. in terms of collection and recycling as well as creating registers and
control mechanisms, determining the fees etc.).

iii) Improving an optimising mechanism when the mandatory EPR system comes into force (see Table 11):
Even after a legal framework has been established and a mandatory EPR system is in place, steps must be
taken to ensure that the EPR system and the PRO are continuously being optimized and evolve.

Short term measures: describe actions that can be taken immediately, given a political consensus. They
entail, with respect to the legislative framework, enacting bans and other orders. They also include measures
put into place by the private sector, possible within the current framework of policies and laws, e.g. changing
behaviours and business practices. Starting projects, discussions and initiatives that enable medium and
long term measures are also part of this category.

Medium term measures: describe actions that need preparatory time in order to fulfil their functions. The
set-up of a new institution with its tasks, its organizational structure and its role in the given regulatory
framework is included here. It also refers to processes of coordination that determine how to share tasks
and responsibilities in between different organizations and institutions.

Long term measures: build on discussions started as short term measures and on institutional and
organizational set-ups initiated as medium term measures. In addition to the aforementioned, experiences
have to be built in order to achieve incremental change and improve structures and processes.

(see Table 11): Even after a legal framework has been established and a mandatory EPR system is in place, steps
must be taken to ensure that the EPR system and the PRO are continuously being optimized and evolve.


Kenya Plastic Action Plan 92

Table 9: Establishing a legal basis for a mandatory EPR system

No. Objective Activities Target Actor Time frame

1
Prepare for legal
framework

Present and discuss
outcomes of Kenya Plastic
Action Plan with relevant
stakeholders of plastic
supply chain

Align understanding
of an EPR scheme,
PRO and KPAP across
all relevant parties
involved (private
industry)

KAM (optional with
other aligned asso-
ciations)

Short-term (should start
immediately)

2
Prepare for legal
framework

Present and discuss
outcomes of Kenya Plastic
Action Plan with national
and local authorities

Align understanding
of an EPR scheme and
plan across all relevant
parties involved

KAM (optional with
other aligned asso-
ciations)

Short-term (after launch
of KPAP)

3
Prepare for legal
framework

Set up a competent body
in order to control reach-
ing the objectives of a
mandatory EPR scheme

Prepare for EPR being
put into force by a
competent govern-
ment body

National authority
(ideally coordinat-
ing with the initiat-
ing private sector)

Mid-term

4
Prepare for legal
framework

Establish knowledge,
human and structural
resources of the compe-
tent body

Prepare for EPR being
put into force by a
government body

National authority
(ideally coordinat-
ing with the initiat-
ing private sector)

Mid-term

5
Tailor EPR frame-
work to Kenyan
conditions

Define

- Responsibilities and
obliged companies

- plastics covered by EPR
- targets
- control by competent

body

- exemptions

Create a mandatory
EPR scheme that is
practical, clearly de-
fined, substantial and
measurable

Competent body in
cooperation with
private industry

Mid-term

6
Tailor EPR frame-
work to Kenyan
conditions

- Coordinate with paral-
lel legislation to avoid
double payment

- Harmonising existing
(environmental) law
(e.g. transport)

- Use existing laws for
licensing/registration

- Laws to support recy-
cling in general (e.g.
landfill tax)

- exemptions

Create a mandato-
ry EPR system that
doesn’t conflict with
but is ideally support-
ed by laws

Competent body Mid-term

7
Tailor EPR frame-
work to Kenyan
conditions

Evaluate drafted legal
framework and its impact
on the private sector

Insights on benefits,
upcoming issues
and potential future
consequences for the
private sector in order
to observe these after
implementation and
act accordingly

Competent body Mid-term

8
Roll out of legal
EPR framework

Put developed framework
into force

Mandatory EPR system National authority Long-term

6. Implementing the Action Plan


Kenya Plastic Action Plan 93

Table 10: Establishing a pre-organisation on a voluntary basis

No. Objective Activities Target Actor Time frame

1

Present and discuss
a pre-organisation
on a voluntary
basis

Present and discuss
outcomes of Kenya
Plastic Action Plan
with relevant stake-
holders of plastic
supply chain

Align understanding of
an EPR scheme, PRO
and KPAP across all rel-
evant parties involved
(private industry)

KAM (optional with
other aligned associ-
ations)

Short-term (should start
immediately)

2
Set up a pre-organ-
isation on volun-
tary basis

Identify, connect and
combine relevant
Stakeholders and
obliged companies
that are willing to
participate

Establish parameters
for a pre-organisation

Create an organisation
that participates active-
ly in the development
of a legal framework
(see )

KAM (optional with
other aligned associ-
ations)

Short-term (should start
immediately)

3
Set up a pre-organ-
isation on volun-
tary basis

Define

- Responsibilities
- Targets and aims
- membership
- membership fees
- reporting

Prepare a pre-organi-
sation that is meant to
become the mandatory
PROS

KAM (optional with
other aligned associ-
ations)

Short-term

4
Initiate a pre-or-
ganisation

Establish knowledge,
human and structur-
al resources of the
competent body

Prepare a pre-organi-
sation that eventually
becomes the mandato-
ry PRO

KAM (optional with
other aligned associ-
ations)

Short-term

5
Initiate a pre-or-
ganisation

Public relations work
and acquisition of
members

All companies and
organisations along the
plastic supply chain can
become member in the
voluntary PRO, not just
the future obliged com-
panies. Developing a
tailored system should
be done by all compa-
nies and organisations
along the plastic supply
chain.

KAM (optional with
other aligned associ-
ations)

Short-term

6
Start pre-organi-
sation

Establishing and roll
out of pre-Organi-
sation

Implement an organ-
isation that partici-
pates actively in the
development of a legal
framework (see )

KAM (optional with
other aligned associ-
ations)

Mid-Term

7
Run pre-organisa-
tion

Run measures and
pilot projects in order
to develop an entire
and proper plastic
collection and recy-
cling and waste data
gathering, evaluation
of insights

Create a waste man-
agement structure
that can be scaled up
through a multi-step
approach and be the
basis for a national
implementation

Pre-organisation to-
gether with partners
of supply chain

Mid-term


Kenya Plastic Action Plan 94

8
Run pre-organisa-
tion

Run measures and
pilot projects in order
to develop a sound
mandatory PRO. This
would include:

- registering obliged
companies

- calculating their
fees and establish-
ing a controlling
system to avoid
free riders or false
reporting

- measures for mass
flow validation

- raising awareness
- integrating infor-

mal sector

- reporting to meas-
ure goal progress

Create necessary
mechanisms to pre-
pare for transition to
a mandatory PRO

Pre-organisation
together with
partners of supply
chain

Mid-term

9
start mandatory
PRO

Transition from a
voluntary pre-organi-
zation to a mandatory
PRO

Create a proper,
well-prepared manda-
tory PRO to achieve
aims of the EPR
framework

Pre-organisation Long-term

Table 11: Improving an optimising mechanism when the mandatory EPR system comes into force

No. Objective Activities Target Actor Time frame

1
Run mandatory
PRO

- Collect fees
- Run registration

system

- Run waste man-
agement practices
by using fees

- Run controls
- Report regularly
- Raise awareness

Fulfil requirements of
legal framework

Mandatory PRO
Long term (after EPR frame-
work is in place)

2
Optimise mandato-
ry PRO

Use modulated fees
to give financial in-
centives to strength-
en recycling

Fulfil requirements
of legal framework,
optimising recycling
amounts

Mandatory PRO
Long term (after EPR frame-
work is in place)

3
Optimise mandato-
ry PRO

Raise the demand for
recyclates by giving
incentives (finan-
cial and/or quota/
amount)

Fulfil requirements
of legal framework,
optimising recycling
amounts

Mandatory PRO
Long term (after EPR frame-
work is in place)

4
Optimise mandato-
ry PRO

Harmonise and
formalise collection
schemes for Kenya

Fulfil requirements
of legal framework,
optimising collection
amounts

Mandatory PRO
Long term (after EPR frame-
work is in place)

5
Optimise mandato-
ry PRO

Optimise internal
control mechanism

Formalise informal
packaging user and
waste operators

Close financial and
organisational gabs

Mandatory PRO
Long term (after EPR frame-
work is in place)

6. Implementing the Action Plan


Kenya Plastic Action Plan 95


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Kenya Plastic Action Plan 105

8.1 Annex 1: Background to Plastics
The term ‘plastics’ describes a huge group of polymers. The main distinction can be made between two groups: the
thermoplastics comprising all plastics which will melt when heated and harden when cooled down in a reversible
manner. Polymers of this group are for instance, polyethylene (PET), polypropylene (PP), polystyrene (PS), polyvinyl
chloride (PVC), and polyethylene terephthalate (PET). On the other hand, there are the thermosets – a group
which entails all plastics that will change their chemical structures when heated leading to the creation of a three-
dimensional network. This change is irreversible meaning that these plastics cannot be re-melted once they have
hardened. Examples for thermoset polymers are polyurethane, silicone and epoxy resins [PlasticsEurope, 2018].

Through a process called polymerisation the monomers are chained together forming the polymers, which is why
polymers are usually very heavy molecules as there are composed of thousands of monomers. Each monomer
combination, the chemical binding of different elements and compounds to the polymer chain, the inclusion of
additives, and the use of crystallizability yield plastic fractions with different properties. The resulting plastics can
be melted to form many different plastic products allowing for this vast range of application as aforementioned
[American Chemical Council, n.y.].

The production of plastics is mainly concentrated in Asia, which accounted for more than 50 % of the global
plastics production in 2017 – Middle East and Africa only accounted for 7.1 % (see Figure 28; PlasticsEurope
2018). This is also reflected in Kenya’s import of plastics material in comparison to the domestic production, in
which the import strongly dominated [Ipsos, 2019].

Figure 28: Distribution of the global plastics production, 2017 [PlasticsEurope, 2018]

8. Annexes


Kenya Plastic Action Plan 106

However, plastics are not necessarily consumed where they are produced. While Asia is the hub for plastics
manufacturing globally, the consumption ranges between 0 to 0.2 kg per capita per day while the highest plastics
consumption takes place in Germany (0.48 kg per capita per day), Guyana (0.59 kg per capita per day) and
Kuwait (0.69 kg per capita per day).

On a global scale, the produced plastics quantities and the generated waste vary significantly per sector as shown
in the research of Geyer at l. [2017]. A visualisation of this table can be found in chapter 2.1, Figure 3 and Figure 4.

Table 12: Quantities of produced primary plastics and generated waste acc. to sector, 2015 [Geyer et al.,
2017]

Produced quantities in 2015 [Mt] Waste quantities in 2015 [Mt]

Packaging 146 141

Building and construction 65 13

Other sectors 62 43

Textiles 47 38

Consumer & industrial products 42 37

Transportation 27 17

Electrical/electronic 18 13

8. Annexes


Kenya Plastic Action Plan 107

8.2 Annex 2: The polymer types
Each industrial sector uses several polymer types. In the following, the most important polymer types are
presented following the international seven plastic codes.

PET is a thermoplastic polymer, which originates from the group of polyesters. It is derived from the esterification
of ethylene glycol with terephthalic acid or dimethyl terephthalate and a subsequent condensation process.
Through a moulding process, the eventual PET product is then created. PET is a semi-crystalline plastic resin,
which stands out through properties such as great tensile strength and chemical resistance as well as its light
weight, elasticity, and stability over a wide range of temperatures (-60° to 220 °C) [Robertson, 2014]. Products
made of PET were introduced on the markets as early as in the 1950s, however, as fibre for textiles. The global
production of PET started to increase dramatically in the 1970s as it’s suitability for applications such as food
packaging had been discovered. Today, PET is used as packaging material for foods and beverages (particularly
drinking water bottles), electronic components and as fibres in clothes [Plastikatlas, 2019]. The internationally
assigned number is 1.

HDPE (high density polyethylene) is polymer made from PE, which is derived from the gas ethane, which is split
into ethylene (and hydrogen) when heated. Through a subsequent low pressure polymerisation reaction, the
polymer is formed. Moreover, polyethylene is also the basis for LPDE as well as PET through the creation of
ethylene glycol [Posch, 2011]. Due to its lower degree of branching, HDPE processes a greater tensile strength,
stiffness and chemical resistance in comparison to LDPE. Thus, HDPE is an ideal material for structural applications
and rigid packaging such as bottles for milk and household chemicals. Other common applications are heavy
duty items like pellets, crates and intermediate bulk containers as well as numerous medical and pharmaceutical
applications [Emblem, 2012; Sastri, 2010]. The internationally assigned number is 2.

PVC was one of the earliest plastics discovered and until now is still one of the most widely used polymers
globally. It is created from vinyl gas, which is derived from salt (57 %) and oil or gas (43 %). The vinyl chloride
is polymerised through free radicals in suspension, bulk, emulsion or solution methods [Sastri, 2010]. There are
two forms of PVC: rigid and flexible. PVC is generally very durable, light, strong, fire resistant, has excellent
insulating properties and a low permeability. Through the combination with additives, applications of PVC can
be found in all kinds of sectors. For instance, it is commonly used for building products (such as window frames,
floor and wall covering, and linings for tunnels), coatings (such as rainwear or corrugated metal sheets), pipes,
automotive applications, as well as medical products (including blood bags, surgical gloves, and transfusion
tubes) [PlasticsEurope, n.y.]. The internationally assigned number is 3.

LDPE (low density polyethylene) is a polymer derived from PE as aforementioned and is generated in a similar
but high pressure process like HDPE resulting in a product with a significantly higher degree in branching. Thus,
LDPE as a material is more flexible and has a higher clarity than HDPE yet has a good breakage and puncture
resistance. It softens around 100 °C, which makes it unsuitable for cock-in applications, but economically highly
attractive to process. Thus, LDPE is widely used for packaging applications such as foils, trays, plastic bags for
food and non-food purposes and as a protective film on other materials like paper, textiles and other plastics
[Bayer et al., 2017; Sastri, 2010]. The internationally assigned number is 4.


Kenya Plastic Action Plan 108

PP is the polymer, which is generated through the catalytic polymerisation reaction of propylene gas into long-
chained polymers of propene. There are two processing methods:

i) low pressure precipitation polymerisation, and
ii) gas phase polymerisation, which is the more common one.

As a subsequent step, the powder is processed into granulate. PP is currently the fast growing polymer globally.
This is due to its ability to replace both conventional materials, like glass or wood, and other thermoplastic
polymers at lower costs. PP has an excellent strength, low surface energy, low gas and liquid permeability and
is relatively easy to process. It resembles HDPE in many regards. However, due to its molecular structure, it
exhibits a higher stiffness and resistance to creep as well as high temperature capabilities. Thus, PP is used for
a wide range of applications. It is used in films and multilayer applications such as consumer packaging, medical
packaging, labels, stickers, personal hygiene and construction films. Moreover, it is used to form fibres, which
represents the single largest use. These fibres are used for instance in carpeting, ropes, and automobile interior
[Massey, 2007; Sastri, 2010]. The internationally assigned number is 5.

PS consists of a monomer styrene, which is a liquid petrochemical. PS is generally clear, hard and brittle and
available in two forms: rigid PS and foamed PS. It has an excellent transparency, high tensile strength, but
poor barrier properties in regards to moisture vapour and gases, which is why PS is a suitable material for
‘breathable’ films. Typical applications of PS are packaging, take-away food cartons, household applications,
consumer electronics products, building and construction and medical applications [Görtz, 2001; Sastri, 2010].
The internationally assigned number is 6.

Number 7 is given for the group ‘others’ and comprises all other plastics, which are not part of the previous groups
as for instance nylon, polycarbonates or mixed plastic, which is a material consisting of various polymer types.
Differentiating according to these seven polymer groups, the global primary production and waste generation
per polymer in 2015 is as follows (Table 13):

Table 13: Quantities of produced plastics and generated waste acc. to polymer, 2015 [Geyer et al., 2017]

Produced quantities in
2015 [Mt]

Waste quantities in 2015
[Mt]

Percentage of waste quantities
in regards to production

PET 33 32 97 %

HDPE 52 40 77 %

PVC 38 15 39 %

LDPE 64 57 89 %

PP 68 55 81 %

PS 25 17 68 %

Others 127 86 68 %

The table above shows that the plastics fraction which are mainly used for packaging applications have a
significantly shorter in-use phase than those which are also used for applications in sectors such as building and
construction, as for instance seen in PET and LDPE in comparison to PVC.

8. Annexes


Kenya Plastic Action Plan 109

8.3 Annex 3: Recycling the different polymer types
Recycling plastic polymers is highly dependent on the purity of the waste polymer fractions meaning the presence
of contaminants from other waste materials as well as other polymer types as many plastic polymers are not
compatible to create recyclates. Another important factor for recycling is the distinction between thermoplastics
and thermoset as only thermoplastics can be mechanically recycled due to their ability to be re-melted (see
chapter 2.2, [Hopewell et al., 2009]. The typical steps in mechanical recycling are cleaning (e.g. the removal of
labels), grinding, washing and re-extrusion, in which the material is melted and formed into pellets, granules or
fibres. Moreover, there are often filtration steps in the recycling process to separate the polymers from other,
contaminating polymers [Plastic Recyclers Europe, n.y.].

PET is a polymer, which can be well mechanically recycled: the simplest and most cost-effective recycling process
is the re-extrusion in which the PET waste recycled into fibres or granules and pellets. This recyclate is used
for fibres in the nonwoven and textiles industry as well as PET bottles and other PET packaging applications. In
fact, PET is the only polymer yielding recyclates which can be reused for food-grade applications – although this
require specific processes to yield very high-quality recyclates. Feedstock recycling of PET waste is also possible
albeit being significant more expensive due to the energy-intensive process of de-polymerising by hydrolysis,
methanolysis or glycolysis [Park & Kim, 2014].

Just as PET, HPDE, LDPE, and PP are polymers which can be well mechanically. The HDPE recyclate can be used
to manufacture several typical HDPE applications, such as pipes, films and sheets, ropes, toys and even packaging
applications such as bottles (although not for food-grade packaging) [Garrian et al., 2007]. The LDPE recyclate
is used to produce piping, trash bags, sheeting and films for building and agricultural applications, composite
lumber, and other products [Plastic Recyclers Europe, n.y.] while PP recyclates are used for manufacturing
for instance battery cables, rakes and bins, bottle caps or auto case batteries. HDPE, LDPE and PP can also
be chemically recycled through a thermal pyrolysis at temperatures >700 °C. However, just like the chemical
recycling of PET, the process is consumes great amounts of energy [Achialias et al., 2007].

Also PVC is a polymer, which can be both mechanically and chemically recycled. As PVC is widely used in
the building and construction industry, a great share of the PVC waste is industrial waste and not household
waste, which is why the PVC waste is relatively pure and less contaminated with other polymers. Moreover, it is
critical to recycle PVC separate from other polymers as the high chlorine content in raw PVC and high levels of
hazardous additives added to the polymer to achieve the desired material quality cause a deterioration of the
recyclates of other polymers. In the mechanical recycling process, PVC is recycled in a comparable fashion to
the other polymers. When different kinds of PVC waste are mechanically, it is difficult to predict the resulting
product’s leading to problems as most PVC products require a specific PVC content. Thus, material recycling
is more suitable for post-industrial waste than for post-consumer waste. For the chemical recycling, pyrolysis,
hydrolysis and heating are used to convert the waste into its chemical component. The resulting products like
sodium chloride, calcium chloride, and hydrocarbon products are used to produce new PVC, as feed for other
manufacturing processes or as fuel for energy recovery. The advantage is that it is able to treat mixed or unsorted
PVC waste. However, chemical recycling is associated to very high costs [Rubio, 2019].

PS – being a thermoplastic – is also recyclable: As many PS products are so-called expanded polystyrene
(EPS) foams, a critical step in the mechanical recycling is the compacting, densification or dissolving as EPS
foam contains a significant share of air. After this step, the EPS is filtered to remove impurities and shredded
(depending on the previous step) and can be used for non-food packaging and products. Another bottleneck is
that at present, it is more economical to produce new EPS foam products than to recycle it [Rubio, 2018]. PS is
currently not recycled in Kenya [Eunomia, 2018].


Kenya Plastic Action Plan 110

As aforementioned, there is a great difference in regards to recycling thermoplastics and thermosets. As the
group ‘others’ is an umbrella for all other polymers, as well as mixed plastics, meaning that no general statement
regarding the recycling can be made which is applicable for all plastic in this group.

22%

28%

29%

43%

45%

50%

64%

0% 10% 20% 30% 40% 50% 60% 70%

PVC

PET

PS

Others

LDPE

HDPE

PP

51%

19%

30%

12%

7%

7%

7%

5%

0% 10% 20% 30% 40% 50% 60%

Packaging

Others

Building & construction

Transportation

Medical purposes

Technical equipment

Agriculture

Electrical / electronic

8.4 Annex 4: Recyclate usage
The ‘European Plastic Converters’ analysed the usage of recyclates across sectors and polymer types [EuPC,
2017]. Please note that the percentage numbers represent the number of plastic producers in this field using
recyclates (Figure 29) as well as the number of plastic converters using a certain polymer type (Figure 30).

Figure 29: Recyclate use according to polymer fraction [based on EuCP, 2017]

Figure 30: Recyclate use according sectors [based on EuCP, 2017]

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Kenya Plastic Action Plan 111

Additionally to that, a German study carried out by the Trade Association Germany (Handelsverband Deutchland
HDE e.V.) in 2018 examines the usage of recyclates, in particular what and how many obstructions come along
with the usage of different types of recyclates stemming from different types of plastic packaging available in
Germany. The study [GVM, 2019] identifies obstructions in five dimensions: availability, function, law, costs and
ecology.

To identify the overall results of the recyclates, the study assembled a chart from 0 to 10, 0 meaning that there
are no obstructions to the usage of recyclates and 10 meaning that the usage of recyclates is impossible. The
scores were summarised in five fields: 0-<2 equal no or very little obstructions, 2-<4 equal little obstructions,
4-<7 equal moderate obstructions, 7-<9 mean large obstructions, 9-10 mean very large obstructions [GVM, 2019].

The results of the study show that packaging segments with the fewest obstructions were non-food segments
such as boxes, palettes, plant pots, non-food cans and barrels, transportation foils, labels and carrier bags. The
packaging segments which provided the largest obstructions were those used in connection with perishables,
such as foam plastics used for food, compound foils, plastic bags, containers and other cups. In general, the
largest obstructions are related to the availability of high-quality recyclates, the look-and-feel of the recyclates
in terms of odour or missing transparency, and the insufficient physical and mechanical aspects of the majority
of recyclates currently available [GVM, 2019].

In Germany, approximately 3.2 million tons of plastic packaging are used, of which merely 10 % provide none
or little obstructions for the usage of recyclates. The rest of the market provides an equal share of moderate
obstructions (~45 %) and of large to very large obstructions (~45 %) [GVM, 2019].

The study states that plastic recyclates will always provide worse technical characteristics than comparable
virgin materials. Requirements such as durability are significant obstructions for plastic recyclates and could, if
feasible, only be resolved by mixing recyclates with primary materials. In the long run, however, mixing recyclates
with new materials will inevitably have a negative impact on the quality of the material life cycle [GVM, 2019].

Political regulations or stakeholder commitments for the usage of recyclates would increase the demand for
recyclates and set directions for the market development. At the same time, however, certain types of obstructions
would be intensified through such a procedure. Due to the rising demand and unchanged availability of recyclates,
the rather favourable material costs will immediately become more expensive. Moreover, without introducing
quality standards, the quality of the material life cycle would diminish [GVM, 2019].

Sustainable improvements for the usage of recyclates would be the introduction of a mandatory quality standard,
the quickening and de-bureaucratisation of the approval of recyclates being in contact with edibles and the
increase of consumer acceptance of recyclates and the resulting consequences. For example, packaging does
not need to be transparent [GVM, 2019].

As mentioned above, binding regulations and stakeholder commitments could enforce a significant development
on the market of recyclates. Mandatory quality standards should ensure that recyclates meet the requirements
so that they may be used on par with new material. Correct labelling and certification is essential to gain trust
of manufacturers and consumers to use recyclates for their packaging and buy products packed in recycled
materials. In that sense, it would be recommendable to establish the required recycling infrastructure prior to
the introduction of such regulations. As compound materials are rarely recycled, ideally the packaging should
be made of mono-material.


Kenya Plastic Action Plan 112

8.5 Annex 5: The circular economy concept in detail
The circular economy offers a more efficient resource use, which has economic, environmental, and social
benefits. Economic benefits are the result of the decreased resource dependency on raw materials and thus
less import dependency as well as the creation of employment possibilities. Moreover, less resource extraction
and disposal of waste also offers significant ecological benefits, since the environmental threats connected to
extraction and disposal will be reduced if the cause is removed. Last but not least, this offers also social benefits
as the threat for human health driven by environmental impacts of extraction and disposal is reduced and the
need to reintroduce resources into the economic system instead of disposing them offers new employment
possibilities [Stahel, 2014; Wilts, 2016].

The circular economy is based on three overarching principles: reduce, reuse, and recycle [Ghisellini et al., 2015;
Wilts, 2016]. As the name implies, the reduction principle pursues the maximum reduction of raw material and
energy demand, which are needed for production as well as waste that is generated during production and/
or consumption. This can be achieved by improving both the production and consumption processes, e.g. by
developing more efficient technology, downsizing the packaging material or changing consumers’ demand [Feng
& Yan, 2007; Su et al., 2013].

The reuse principle describes that products or components of products, that are not waste, are reused again or – if
they have turned into waste – are prepared for reuse [Ghisellini et al., 2015]. This offers especially environmental
benefits as it decreases the resource and energy demand since the product is not newly manufactured [Castellani
et al., 2015]. The last principle, the recycle principle, refers to any process, in which waste is recovered through
reprocessing the material or its chemical constituents thereby making it available for new manufacturing
processes [Ghisellini et al., 2015, Hopewell et al., 2009].

Shifting to a circular economy as a response to the current plastic situation would focus on closing the loop
by reducing the overall amount of plastics used where possible, e.g. for instance through redesigning plastic
products, substitution with other materials or banning certain products where more sustainable alternative
materials exist, and increasing the recycling and preparing for reuse of the generated plastic waste to reduce
the amount of plastic waste that is disposed and to prevent littering and improper waste management practices.

A circular economy has important implications for all steps of the value chain and the respective measures cover
a broader field than just waste management measures and are operationalised at different scales – ideally done in
a complementing fashion (Figure 6). However, this is usually not the case and most initiatives, despite being often
promising, remain fragmented and measures across scales are often not well aligned [WEF, 2016]. To overcome
this, a good coordination and collaboration between the actors of the various circular economy measures is
vital. An important prerequisite for that is to align various measures is acknowledging the importance of actors
outside the waste management and eventually broadening of the circle of the involved actors. Particularly actors
from the industry are important to include as e.g. their product design strongly influences if a waste item can be
reused or at least recycled [Silva et al., 2017; Wilts, 2016]. Moreover, a stronger consideration of the consumers’
influence on circular economy measures is also important as they ultimately determine if they buy a product,
which can be reused or recycled, or not, as well as if and how well waste is separated, which also plays a critical
role if reusing or recycling is even possible [Wilts, 2016]. Thus, a well-executed circular economy benefits from
including and cooperating with multiple actors from all sectors.

8. Annexes


Kenya Plastic Action Plan 113

Figure 31: Three principles and ten corresponding strategies towards circular economy [PWC, 2019]


The following Figure 31 illustrates the three main principles and ten corresponding strategies towards circular
economy.


Kenya Plastic Action Plan 114

8.6 Annex 6: Global trends
To push circular economy also on a global scale, there are several global commitments driven by both governments
as well as private sector initiatives to transit to a waste-free circular plastics economy, both will be examined
in this chapter. In particular, emphasis is put on the G7 Oceans Charter and the Sustainable Development Goals
(SDGs) as well as ‘The New Plastics Economy’ published by the Ellen MacArthur Foundation (EMF).

Government driven initiatives – G7 Ocean Plastic Charter
Marine littering poses a serious threat to the environment worldwide.
Based on the urging need to address this issue through a global
commitment, five of the G7 countries adopted the Ocean Plastics Charter
on June 9, 2018 to demonstrate their commitment to stop the growing
marine littering problem by taking concrete actions to address and
eventually solve the issue (Figure 32). Canada, France, Germany, Italy
and the UK thereby committed to a more sustainable approach in their
usage of plastics [Government of Canada, 2018].

As envisioned, the Ocean Plastics Charter brings together partners such
as local governments, businesses and civil rights movements to take
action and move toward a more responsible, sustainable use of plastics.
To put this into practice, the Charter frames five specific resource-
efficient approaches in the management of plastics:

1) Sustainable design, production and after-use markets to create 100 % reusable, recyclable of recoverable
plastics by 2030, reduce single-use plastics (SUP), creating secondary plastics markets and alternatives to
plastics through green public procurement, policy measures and international incentives, and – together
with the industry – reduce microbeads in cosmetics and personal care products

2) Collection, management and other systems and infrastructure to significantly increase recycling rates
through collective actions with the industry and local governments, increase a proper plastic waste management
to reduce leakages, shift to a whole supply chain approach towards greater responsibility, significantly
increase public-private funding and capacity development for waste management particularly in hot spot
areas including small islands and remote communities

3) Sustainable lifestyles and education to support industry lead initiates and knowledge exchange through
existing alliances and platforms, strengthening preventive measures for marine litter and empower consumer
choices through labelling and promote sustainable consumption particularly through giving woman and the
youth a leadership role in this regard

4) Research, innovation and new technologies to promote research and development through sustainable
technologies, design and production methods by the private sectors and innovators for;

• reducing the plastic leakages at all steps of the value chain,
• removing plastics and micro plastics from the marine habitat, and
• assessing the impact on human health, analyse the current plastic consumption by major sector use, harmonise

the G7 monitoring methods

5) Coastal and shoreline action to raise public awareness through campaigns, collect data and target investments
to remove debris from coasts and shorelines, accelerate the implementation of already existing action plans
and programmes as for instance the 2015 G7 Leaders’ Action Plan to Combat Marine Litter through the
Regional Seas Programs [Government of Canada, 2018].

Figure 32: G7 Ocean Plastic Charter

8. Annexes


Kenya Plastic Action Plan 115

By now, 21 governments, including Kenya, and 63 business and organisations, like KAM [Government of Canada,
2019] joined the G7 Ocean Plastics Charter.

Additionally in June 2019, the G20 member states declared during their meeting in Japan, to combat marine
litter and committed to develop a comprehensive approach preventing and reducing plastic litter discharge into
the marine habitat. Moreover, they announced to share their best practices with other nations. However, all
measures are on a voluntary basis [Zeit, 2019].

Government driven initiatives – Sustainable Development Goals
Described by the UN as a ‘blueprint to achieve a better and more sustainable future for all’, the Sustainable
Development Goals (SDGs) are 17 interconnected goals to address global challenges and improve global living
standards by 2030 [UN, n.y.]. To work towards these identified goals, the concept of a circular economy has been
identified as a central element in regards to SDG 7 on energy, SDG 8 on economic growth, SDG 11 on sustainable
cities, SDG 12 on sustainable consumption and production, SDG 13 on climate change, SDG 14 on oceans, and
SDG 15 on life on land. In particular, this means for the respective SDGs (Figure 33):

Figure 33: The 17 SDGs of the UN


Kenya Plastic Action Plan 116

Circular Economy and SDG 7 (Affordable and Clean Energy): The current systems of energy
production depend on non-renewable resources such as coal, oil and natural gas. In 2018, the
global electricity demand rose by 4 %, which was met to a significant share with energy generated
from coal and gas-fired power plants increased significantly which in its turn increased CO2
emissions form the sector by 2.5 % [IEA, 2018]. Transforming to a circular economy means

shifting the focus on enhancing and increasing the efficiency of the current renewable power production as the
main source of energy, instead of a subsidiary one as well as designing efficient systems to store and distribute
energy to satisfy the demand with as less waste of energy as possible.

Circular Economy and SDG 8 (Economic Growth): As mentioned, the linear economy, which is
currently the dominant economic system, is built on the principle of take-make-dispose which
grants only limited sustainability since the resource availability is limited and most resources
are lost after becoming waste. Within a circular economy, this is changed as reflected in
the principles of reduce, reuse, and recycle. The circular economy creates a new market for
secondary materials and end-of-life applications, which will create jobs and opens the door to

more specialised fields of study and development adding to the growth of the economy in turn.

Circular Economy and SDG 11 (Sustainable Cities): Industrialized growth increases the
urban population and density as well as the consumption. The resulting effects of urbanization
deeply influence the development of cities around the world. According to UN estimates, the
urbanized population increased from 14 % to 54 % between 1900 and 2015 and is predicted
to rise to 66 % by 2050, which will put tremendous pressure on cities and their management.
The situation also calls for better ways on how to address waste management and minimise

the negative effects related to an improper waste management, thus, highlighting the need for a shift to Circular
Economy [WEF, 2018]. This approach will change cities by improving the living qualities and creating more jobs
(see previous SDG).

Circular Economy and SDG 12 (sustainable consumption and production): As resources
are limited, the current economy will face an inevitable resources scarcity that threatens the
industrial sector and all related sectors. Circular economy provides a solution to these issues
by using secondary materials as resource and less virgin material through the approach of
recycling and reusing. Moreover, a circular economy also focuses on enhancing resource
management along the value chain, e.g. through design for recycling, to maintain resources for

longer periods and to avoid waste in production, supply, use, and disposal - all of which grant a more sustainable
consumption and production [Ministerial Conference Page, 2019].

Circular Economy and SDG 13 (Climate Change): Climate Change is a result of the increase
in earth’s temperature due to the greenhouse gas emissions. 62 % of global greenhouse gas
emissions — excluding those from land use and forestry — are released during the extraction,
processing and manufacturing of goods to serve society’s needs [UN, 2019]. Circular economy
through its three principles of reduce, reuse, and recycle, represents a crucial part of the
solution to cut down the effects of climate change and global warming by reducing greenhouse

emissions through decreasing the need to constantly extract and produce virgin materials, and eliminating waste
form the natural environment.

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Kenya Plastic Action Plan 117

Circular Economy and SDG 14 (Life below Water): The UN estimates that 40 % of the oceans
are significantly impacted by human activities, including pollution, overfishing, and loss of coastal
habitats. According to the UNESCO, over 220 million tons of plastics are produced each year,
but inappropriate disposal of plastics is often not addressed as huge quantities of plastics and
micro-plastics end up in seas and oceans threatening the marine ecosystems [UNESCO, n.y.].
Circular economy is a solution to this problem as leakages would be stopped during the steps

of the value chain but also particularly leakages of waste would be dramatically cut down as waste would be
recycled and not lost to the environment.

Circular Economy and SDG 15 (Life on Land): According to UN, around 1.6 billion people depend
on forests for their livelihoods, 2.6 billion people depend directly on agriculture for a living,
[UN, 2017] and until now, there are around 7.7 billion humans living in 2019. The current linear
economy and waste disposal are endangering lives of species living on land by accumulating
waste (especially plastic and micro-plastic) in land and soil as for example ‘chlorinated plastic
can release harmful chemicals into the surrounding soil, which can then seep into groundwater

or other surrounding water sources, and also the ecosystem. This can cause a range of potentially harmful
effects on the species that drink the water’ [UNEP, n.y.]. Circular economy provides a solution to this by keeping
more resources and materials for as long as possible in use. This can be achieved in a number of different ways,
including increased product durability, reuse and recycling.

Private driven initiatives – Ellen MacArthur Foundation (EMF)
In 2010, the EMF was launched as a charity with the mission to accelerate the transition to a circular economy
on a global scale. One of their key topics is the so-called ‘The New Plastics Economy’, which envisions a circular
economy in which plastics never becomes waste but remains a resource. To achieve its vision, the New Plastic
Economy frames six key points through which such a circular economy could become possible:
1) Elimination of problematic or unnecessary plastic packaging through redesign, innovation, and new delivery

models is a priority.
2) Reuse models are applied where relevant, reducing the need for single-use packaging.
3) All plastic packaging is 100 % reusable, recyclable, or compostable.
4) All plastic packaging is reused, recycled, or composted in practice.
5) The use of plastic is fully decoupled from the consumption of finite resources.
6) All plastic packaging is free of hazardous chemicals, and the health, safety, and rights of all people involved

are respected [EMF, n.y.].

The first report ‘The New Plastics Economy – Rethinking the future of plastics’ was published in January 2016.
In light of the question of how to initiate the system effectiveness of the global plastics economy with focus on
the global plastics packaging value chain and material flow- The first report proposes to create an alternative
mind-set by approaching plastics as an integral part of an effective global material flow, which is aligned with
the circular economy principles. As key findings, the report highlights that;

i) the predominant share of 95 % of plastics is only used once, which equals a resource loss of USD 80-120
billion annually, and

ii) plastic packaging generates severe, negative environmental impacts. This impact is coined by the now famous
forecast that in a business-as-usual scenario ‘there may be more plastic than fish in the ocean, by weight,
by 2050’ (EMF, 2016, p. 29).


Kenya Plastic Action Plan 118

As a conclusion, the report urges to create an effective after-use economy, drastically reduce the leakages into
the environment and decouple plastics from fossil fuels [EMF, 2016].

Following up in this report, ‘The New Plastics Economy: Catalysing action’ was published in 2017 mapping a global
action plan to transition towards 70 % reuse and recycling of plastic packaging complemented with a redesign
and innovation for the remaining 30 %. Thereby, this report delivered a global transition strategy, which is
captured through five mutually reinforcing building blocks for;

i) cross value chain cooperation (‘Dialogue Mechanism’),
ii) cross value chain developments for a design shift enhancing the recycling economics and material health

(‘Global Plastic Protocol’),
iii) two innovation challenges for the proposed fundamental redesign (‘Innovation Moonshot’),
iv) assessing the socio-economic impact on the marine habitat (‘Evidence Base’) and
v) broad stakeholder exchange to accelerate the system shift (‘Stakeholder Engagement’) [EMF, 2017b].

In 2018, the EMF launched the ‘Global Commitment’ in which more than 400 stakeholders including consumer
good companies, packaging producers and packaging designers which collectively are responsible for 20 % of
the produced plastic packaging worldwide committed to change how plastics are produced, used and reused. In
the latest update in June 2019, the report highlights the commitment of consumer good companies and retailers
to increase the recycled content from 2 % (current global average) to 25 % in 2025, increasing piloting refill
and reuse scheme in 50 retailer and brands and the publicly reporting the annual volumes of plastic packaging
production and use, including major consumer packaged goods companies and retailers like Nestlé, The Coca-
Cola Company, Unilever, Carrefour, Colgate Palmolive, Danone, L’Oréal, and Mars [EMF, 2019].

Other private sector driven initiatives
In January 2019, 27 companies from all steps of the plastics value
chain initiated The Alliance to End Plastic Waste as a private-sector
initiative to push actions on reducing the plastic litter in the aquatic
environment by combining their expertise, resourced and outreach
to create a global vision and a respective strategy. In particular, the alliance targets;

i) the infrastructure development for waste collection and proper waste management to increase recycling,
ii) innovation for waste minimising technology, better plastics recycling and creation of post-use applications,
iii) education and engagement of all stakeholders including governments from all levels, businesses and

communities, and
iv) clean-ups of already polluted habitats. In July 2019, the number of committed business has risen to 39 [The

Alliance to end Plastic Waste, 2019].

8. Annexes


Kenya Plastic Action Plan 119

Moreover, there are also several private sector initiatives founded in several middle-income countries to foster
circular economy measures in their respective countries. Examples are for instance:

• PARMS: The Philippine Alliance for Recycling and Material Sustainability; member include Coca-Cola
Philippines, Nestlé Philippines, Pepsi-Cola Products Philippines, Procter & Gamble Philippines and Unilever
Philippines [PARMS, n.y.].

• PRAISE: The packaging and Recycling Alliance for Indonesia Sustainable Environment; members include
Nestlé Indonesia, Coca-Cola Indonesia, Tetra Pak Indonesia, Unilever Indonesia, Titra Investama, Indofood
Sukses Makmur [1PRAISE, n.y.].

• GRIPE: The Ghana Recycling Imitative by private Enterprises; members include Dow Chemical West Africa,
Nestlé Ghana, Coca-Cola Ghana, Unilever Ghana, Voltic, Fan Milk Ghana, Guinness Ghana Breweries, PZ
Cussons Ghana [GRIPE, n.y.].

• TIMPSE: Thailand Institute of Packaging and Recycling Management for a Sustainable Environment; members
include Nestlé Thailand, Unilever Thailand, Coca-Cola Thailand, Pepsi-Cola Thailand, Tetra Pak Thailand
[TIMPSE, n.y.]

Nevertheless, it needs to be acknowledged that the successes of these initiatives are limited as the companies,
who are working voluntarily on this issue, are competing with those companies who are not participating in such
an initiative in the respective country.


Kenya Plastic Action Plan 120

8.7 Annex 7: Questionnaire for online survey

8. Annexes


Kenya Plastic Action Plan 121

8.8 Annex 8: Circular Economy and The Big4 Agenda
Circular economy represents also a tool which can contribute to achieving the Big4 Agenda goal of manufacturing
expansion in the blue economy, agro-processing, leather and textile industries:

Circular economy and blue economy:
The Blue Economy encourages a better stewardship of the ocean’s or ‘blue’ resources, which includes a significant
reduction of environmental risks for and ecological scarcities of the marine resources [The Commonwealth,
n.y.]. Based on a circular economy approach, recycling of plastic waste would contribute to an improved blue
economy as plastic litter is a serious threat for the marine habitat.

Circular economy and agro-processing industry:
Food-processing is a sector of the agro-processing industry that includes the methods and techniques used
to transform raw ingredients into food for human consumption. The relationship between the plastic and food
sector is complicated: More than 50 % of food waste takes place in households while nearly 20 % is wasted
during processing. Plastic packaging contributes in preserving food by preventing damage during transport,
and extending shelf life, which help reducing food waste. That makes it hard to eliminate plastic from the food
industry. At the same time, improper disposal of plastic packaging is the leading source for plastic litter in the
environment [Dora & Iacovidou, 2019]. Thus, redesigning plastic packaging that it is easy to recycle and reuse
(if possible), reusing packaging where possible and a comprehensive collection system and following recycling
- or other environmentally sound treatment method if packaging waste cannot be recycled - as envisioned in
a circular economy, is important.

8.9 Annex 9: Alternatives to plastics
Kenya has currently no comprehensive waste collection and treatment infrastructure for waste in general and
plastics in particular. In light of the prevailing waste management conditions (predominantly landfill, low recycling
structure for glass, plastics and paper, no relevant reusable systems), the use of resources for instance in the
form of packaging should be reduced as much as possible in order to minimize resource losses and unordered
deposits with the associated ecological consequences. From a resource conservation point of view of, the
development of an orderly and comprehensive recycling structure is the preferred alternative. A strategy in
dealing with plastics and plastic waste is developed in the Action Plan. This must be taken into account in the
following alternatives to plastics.

The results for three different material comparisons are based on the insights of the Kenyan waste management
situation (see chapter 0). The following comparisons have been made:

i) water bottles (which also apply for cooking oil and yoghurt cups, see Table 21),
ii) grocery carrier bags (see Table 22), and
iii) construction pipes (see Table 26).

Plastics are utilised in many areas in which other materials are used to fulfil the same purpose. Firstly, the
raw materials utilized in the further processing will be compared in regards to the emissions which result in
their production as well as other environmental aspects, if available. Therefore, this Table 14 identifies the
Global Warming Potential (GWP). The GWP is a substance’s / material’s potential contribution to the so-called
greenhouse effect. This contribution is portrayed as an equivalent in relation to the GWP of carbon dioxide (CO2).
For evaluation the figures GWP100 are utilised, which identify the contribution of each particular substance or
material averaged for a time span of one hundred years. The lower the figure of the CO2 equivalent, the lower
is the potential impact on global warming and the relating environmental effects. [BMVBS, 2013]


Kenya Plastic Action Plan 122

Table 14: Global Warming Potential for different raw materials

Category GWP100
[kg CO

2
equi.] per kg

Database

Plastics
ABS 3.76 Bath Uni via [Carbon Footprint Ltd, ny]
ABS 3.10 [PlasticsEurope, 2019]
(Expanded) Polystyrene (EPS) 3.29 Bath Uni via [Carbon Footprint Ltd, ny]
(Expanded) Polystyrene (EPS) 2.37 [PlasticsEurope, 2019]
Polystyrene (PS) 2.25 [PlasticsEurope, 2019]
HDPE 1.93 Bath Uni via [Carbon Footprint Ltd, ny]
HDPE 1.80 [PlasticsEurope, 2014]
Recycled HDPE 0.93 [Liebich, 2016]
LDPE 2.08 Bath Uni via [Carbon Footprint Ltd, ny]
LDPE 1.87 [PlasticsEurope-A, 2014]
Recycled LDPE 1.41 [Liebich, 2016]
Polypropylene 1.63 [PlasticsEurope, 2019]
PP, Injection Moulding 4.49 Bath Uni via [Carbon Footprint Ltd, ny]
PP, Orientated Film 3.43 Bath Uni via [Carbon Footprint Ltd, ny]
PP 1.63 [PlasticsEurope-B, 2014]
Recycled PP 0.95 [Liebich, 2016]
Polycarbonate 7.62 Bath Uni via [Carbon Footprint Ltd, ny]
PVC 3.10 Bath Uni via [Carbon Footprint Ltd, ny]
PET 5.56 Bath Uni via [Carbon Footprint Ltd, ny]

Glass
Primary Glass 0.91 Bath Uni via [Carbon Footprint Ltd, ny]
Secondary Glass 0.59 Bath Uni via [Carbon Footprint Ltd, ny]

Aluminium
Aluminium Cast products (primary) 13.10 Bath Uni via [Carbon Footprint Ltd, ny]
Aluminium Cast products (secondary) 1.45 Bath Uni via [Carbon Footprint Ltd, ny]
Aluminium Cast products (typical) 9.22 Bath Uni via [Carbon Footprint Ltd, ny]
Aluminium Extruded (primary) 12.50 Bath Uni via [Carbon Footprint Ltd, ny]
Aluminium Extruded (secondary) 2.12 Bath Uni via [Carbon Footprint Ltd, ny]
Aluminium Extruded (typical) 9.08 Bath Uni via [Carbon Footprint Ltd, ny]
Aluminium Rolled (primary) 12.80 Bath Uni via [Carbon Footprint Ltd, ny]
Aluminium Rolled (secondary) 1.79 Bath Uni via [Carbon Footprint Ltd, ny]
Aluminium Rolled (typical) 9.18 Bath Uni via [Carbon Footprint Ltd, ny]

Steel
Steel Bar & rod - Primary (100% hypothetical
virgin)

2.77 Bath Uni via [Carbon Footprint Ltd, ny]

Steel Bar & rod - Secondary 0.45 Bath Uni via [Carbon Footprint Ltd, ny]
Steel General Steel - World Typical - World
39% Recy.

1.95 Bath Uni via [Carbon Footprint Ltd, ny]

Steel Coil – Galvanised (100% hypothetical
virgin)

3.01 Bath Uni via [Carbon Footprint Ltd, ny]

Steel Coil – Galvanised (typical 35.5 % Recy.) 2.12 Bath Uni via [Carbon Footprint Ltd, ny]

Paper
Paper (primary) 0.96 [Raschke, 2016]
Paper (primary) 1.28 [Ifeu, 2018]
Recycled Paper 0.68 [Raschke, 2016]
Recycled Paper 1.14 [Ifeu, 2018]

Concrete
General Concrete 0.11 Bath Uni via [Carbon Footprint Ltd, ny]
Concrete – depending on composition from 0.10 till 0.15 Bath Uni via [Carbon Footprint Ltd, ny]
Concrete (Precast Mix 1) 0.214 [Marceau et al., 2007]
Reinforced Concrete 0.204 [Struble, Godfrey, 2004]

8. Annexes


Kenya Plastic Action Plan 123

Information: These figures serve the purpose of orientation and classification of each particular material and
result from surveys which do not explicitly consider the Kenyan frame conditions. Among other things, this applies
to the basic processing technique, utilised electricity mix. However, these base figures in relation to each other
portray the contribution to the greenhouse effect, such as aluminium which has a relatively high contribution
compared to plastics or paper.

Table 14 clarifies, that the GWP of;

• Glass ranges within the scope of approximately 1 kg CO2-equiv. per kg,
• Paper ranges between approximately 1 to 1.3 kg CO2-equiv. per kg,
• Plastics range from approximately 1.7 to 3.4 kg CO2-equiv. per kg (depending on the type of plastic),
• Steel ranges from approximately 2 kg CO2-equiv. per kg (depending on the portion of recycled material) to

approximately 2.7 kg CO2-equiv. per kg (for primary material),
• Aluminium ranges of the scope of about 9 (depending on the portion of recycled material) to > 12 kg CO2-

equiv. per kg (for primary material).

It also becomes evident that the usage of recycled or secondary materials relates to a relatively low GWP in
regards to each particular type of material. Furthermore, through a comparison on the item-base (e.g. bottles,
pipes) one many take into consideration that the GWP is largely related to the specific weight of the materials,
the usage of materials (e.g. plastics vs. glass), as well as the user behaviour (single-use vs. multiple use) and the
aligned waste management or recycling opportunities.

Bottles (for water): PET-bottles substituted by glass, aluminium can
or liquid packaging board
Beverages like water are generally sold in different types of packaging, amongst them PET bottles, glass bottles,
aluminium cans and drink cartons. Especially usage, as well as the transport is significant when making an
environmental performance evaluation.

The manufacture of glass bottles and aluminium cans is energy-intensive, which means that the environmental
performance evaluation only results positively, if these products are used multiple times (e.g. within the frame
of a circular system) and are not transported over long distances. This and other frame conditions need to be
considered when making an environmental performance evaluation on item level.

Information: Due to the greatly differing frame conditions, in which the following data and results were investigated,
it is important to illustrate the functional mechanisms which occur in the production and usage, as well as in the
disposal, as they do not exist in Kenya in such an adequate form. Thus, the mentioned examinations will provide
insights which may apply to Kenya in a similar manner, so that resulting advantages and disadvantages could
be distinguished.

This kind of comparison was intensely examined in Germany conducting the research ‘Ökobilanz für
Getränkeverpackungen II / Phase 2’ [Schonert et al., 2002]. Detzel et al, [2016] validated and updated these
results. During this examination different scenarios were created, according to the ISO 14040 environmental
performance evaluations. These also include analysis in relation to transportation and existing waste infrastructure.
Specifically, PET bottles (single use incl. recycling) and glass bottles (single-use and multiple use incl. recycling)
with a filling volume of 1 l were compared. The following Table 15 portrays the results in a simplified way per
category qualitatively next to each other, acc. to which reusable water bottles are preferred in comparison with
one-way PET bottles and one-way glass bottles.


Kenya Plastic Action Plan 124

Table 15: Ranking of different water bottles related to selected environmental criteria [Schonert et al., 2002]

Criteria Glass multiple use Glass single-use PET single-use

Aquatic eutrophication 1 3 2

Terrestrial eutrophication 1 3 2

Depletion of resources 1 3 2

GWP kg CO
2
per 1 l 1 3 2

Acidification 1 3 2

A further examination compared PET single-use systems to PET multiple use systems. According to Schonert
et al. [2002] the environmental impacts as shown above from single-use were halved through adjustment to a
multiple use system, however, slightly exceeds the impacts of reusable glass bottles.

Glass multiple use bottles provide a better environmental performance compared to aluminium cans and steel
cans for a filling volume of 0.5 l (see Table 16) meant for immediate consumption.

Table 16: Ranking of different beverage packaging for immediate consumption related to selected environmental
criteria [Schonert et al., 2002]

Criteria Glass multiple use
Aluminium can

single-use
Steel can

Aquatic eutrophication 1 2 3

Terrestrial eutrophication 2 1 3

Depletion of resources 1 2 3

GWP kg CO
2
per 1 l 1 2 3

Acidification 1 2 3

Similar examinations have been done in Austria with the research ‘Ökobilanz von Getränkeverpackungen in
Österreich Sachstand 2010’ [Kauertz et al., 2011]. A comparison is possible on a manufacturing basis of the
different arrangements without the influences of the following chain mechanisms, because the proportions
of the different functional mechanisms were classified in categories (such as hollow-glass production, PET
production). Thus, the GWP of the production of a 1 l glass bottle (water, multiple use), including labels and caps
is approximately 22 kg CO2-equiv per 1 l and the GWP of a 1.5 l PET bottle (water, multiple use), including labels
and caps is approximately 39 kg CO2-equiv per 1 l.

Acidification and fossil resources depletion resulting of the glass bottle production are half as much as they are
for the PET bottle production. If the distribution afterwards is taken into consideration, the effects align. The
following Table 17 identifies which categories have negative effects.

8. Annexes


Kenya Plastic Action Plan 125

Table 17: Phase depending negative effects for different beverage packaging relating to selected environmental
criteria [Kauertz et al., 2011]

Criteria Glass multiple use PET single-use

Global Warming Potential
(GWP)

Distribution

Filling

Hollow-glass production

PET production

Distribution

Disposal

Fossil resources depletion

Distribution

Production of labels and caps

Filling

PET production

Distribution

Production of packaging for sale and
transport

Acidification Distribution
PET production

Distribution

On closer examination, these two sectors of the functional mechanisms responsible for more than 50 % of the
system load. The biggest influential factor for the results of the PET single-use systems are the contributions
from the sector PET production.

These studies are widely confirmed by the study ‘Studie Life Cycle Assessment of PET (Polyethylene Terephthalate)
bottles and other packaging alternatives’ [Schmidt et al., 2000]. During the comparison of the global warming
potentials, in which credits from the following chain mechanisms for the recycling etc. are neglected, it is stated
that single-use PET bottles 1 l with 123 to 160 kg CO2-equiv per 1,000 l beverages provide a relatively higher GWP
than returnable light glass bottles (70.1 kg CO2-equiv), or returnable PET bottles (59.5 kg CO2-equiv). So far the
credits for the secondary materials are taken into account as a ‘net calculation, the contributions reduce for all
examined materials, especially for PET bottles, which continue to provide the comparatively largest contribution
(98.2 to 120 kg CO2-equiv per 1,000 l).

The goal of this examination ‘The Global Warming Potential analysis of beverage: Which is the best option?’
Paqualino et al., [n.y.] was to evaluate the contribution of packaging to the environmental profile of a product’s life
cycle (beverage production, transport, packaging production and final disposal). The disposal methods considered
are landfilling, incineration and recycling, and the packaging types are aseptic carton, glass, HDPE, aluminium
can and PET, and their sizes are from 200 ml to 8 l. Recycling was found to be the most environmentally friendly
disposal option for all the packaging alternatives compared, and landfilling was considered the second best
option. The packaging options with the lowest environmental impacts were aseptic carton and plastic packaging
(for sizes greater than 1 l). The influence of beverage production on the life cycle varies according to the type
of beverage. Global Warming Potential has been considered as the environmental indicator in this study (incl.
Caps and lids). The following arrangements were examined, which parallel a filling volume of 1l.

• Liquid packaging board (aseptic carton), size 0.2 l (50 g/l) till 1.5 l (35.2 g/l)
• Aluminium can, size 0.33 l (67.9 g/l) till 0.5 l (34.7 g/l)
• Glass brown, size 0.33 l (722.7 g/l) till 1.0 l (468.8 g/l)
• Glass white, size 0.33 l (722.7 g/l) till 1.0 l (492.2 g/l)
• HDPE, size 0.2 l (91.1 g/l) till 1.5 l (32.7 g/l)
• PET, size 0.33 l (42.4 g/l) over 1.5 (19.3 g/l) till 8.0 l (17.5 g/l)


Kenya Plastic Action Plan 126

Also according to other studies (i.a. [Schmidt et al. 2000], the specific weight per 1 l filling volume is corresponding
to the following list (Table 18).

Table 18: Masses of different packaging types

Packaging type Mass per 1 l

PET (one way) Approx. 33 to 46 g

Beverage carton Approx. 35 g (highly depending on size)

Alumnium can Approx. 35 to 68 g (depending on size)

PET (returnable) Approx. 71 g

Glass (light) Approx. 470 to 490 g

Glass (heavy) > 700 g

Contrary to the mentioned studies, this analysis focuses on the effects of the subsequent disposal methods
(landfill, incineration and recycling):

• Landfill: includes the dump infrastructure, the use of land, the effect of landfilled waste, and the emissions
to the soil, air and groundwater released by waste disposed of in landfills.

• Incineration: covers the incineration plant infrastructure, the incineration process, the electricity generated
and the disposal of residual ashes (to landfill). Electrical energy recovery was considered as an avoided
environmental load.

• Recycling: takes into account the recycling plant infrastructure, the sorting and recycling processes, the
products obtained and the wastes generated. The products obtained from the recycling process are considered
to displace virgin raw materials and are thus an avoided load.

The first result is that larger packages always have a lower environmental impact than smaller packages, and
optimal packaging sizes guarantee minimum product losses and maximum ease of use for consumers. As shown
in Table 19 , beverage cartons and plastic packaging (for sizes greater than 1 l) present the lowest GWP for the
three disposal methods. Except for glass, the GWP figures of an existing recycling are within a comparable range.
However, the GWP of disposal of aluminium in a landfill was significantly lower [Paqualino et al., ny].

Table 19: GWP of different packaging types relating to different disposal scenarios [Paqualino et al., ny]

Type beverage Landfill Incineration Recycling

Beverage carton (1.5 l to 200 ml) Juice 0.057 to 0.091 0.069 to 0.113 0.048 to 0.074

Glass white (1 l to 330 ml) Juice/water 0.557 to 0.727 0.729 to 0.975 0.352 to 0.513

PET (8 l to 330 ml) Water 0.079 to 0.224 0.130 to 0.311 0.036 to 0.101

Aluminium can (500 ml to 330 ml)
Beer, also
applicable for
water

0.439 to 0.859 0.458 to 0.895 0.039 to 0.077

8. Annexes


Kenya Plastic Action Plan 127

For India, a comparable LCA for glass and PET bottles was conducted [Stichling, Singh, 2012]. Based on the
chosen reference scenarios for glass bottles (focus on 100 %), following functional mechanism categories were
compared (Table 20).

Table 20: Comparison of PET-bottles with glass-bottles according to [Stichling, Singh, 2012]

Criteria
PET-bottle compared with

glass-bottle (same functional unit)

Acidification Potential [kg SO2-equiv.] Lower (60 %)

Eutrophication Potential [kg PO4-equiv.] Lower (69 %)

GWP100 [kg CO2-equiv.] Lower (57 %)

Human Toxicity [kg DCP-equiv.] Higher (123 %)

Photochem. Ozone Creation Potential [kg Ethene-equiv.] Higher (136 %)

Terrestic Ecotoxicity Potential [kg DCB-equiv.] Higher (246 %)

Primary energy demand from ren. And non ren resources [MJ] Lower (74 %)

The study ‘Comparative Life Cycle Assessment of Tetra Pak® carton packages and alternative packaging systems
for liquid food on the Nordic market’ comissioned by Tetra Pak International SA liquid packaging board was
comapred with competitive liquid food packaging made of PET and HDPE for the Swedish, Finnish, Danish, and
Norwegian market. A considerable role for these generally low environmental impacts of beverage cartons plays
the renewability of their paperboard components and a high use of renewable energies. They benefit from the
use of renewable materials and energies in the production processes. Especially the use of paperboard as the
main component leads to low impacts compared to the use of plastics or glass for bottles [Markwardt et al., 2017].

In general the examined beverage carton systems analysed for these markets show lower burdens in all of the
impact categories than their competing systems. These impact categories are

• Climate change,
• Acidification,
• Photo-Oxidant Formation,
• Ozone Depletion Potential,
• Terrestrial Eutrophication,
• Aquatic Eutrophication,
• Particulate Matter,
• Total Primary Energy,
• Non-renewable Primary Energy,
• Use of Nature,
• Water use (related to water input).

An exception to this occurs in some categories if the carton contains a high share of bio-based PE.
The use of bio-based polyethylene, though does not deliver such an unambiguous benefit. While the utilisation of
bio-based PE instead of fossil-based material leads to lower results in ‘Climate Change’ the emissions from the
production of this bio-polyethylene, including its agricultural background system, increase the environmental
impacts in all the other impact categories regarded.

A comparsion of the different material solutions is shown in Table 21.


Kenya Plastic Action Plan 128

Table 21: Comparison of different materials for bottles for water

Comparison: Bottles for water

Criteria PET-bottle Glass Aluminium can Liquid packaging
board

GWP +
Relatively low GWP, if
returnable, relatively higher
than glass bottles

0
Light glass bottles have
smaller GWP than sin-
gle-use PET, but larger
than reusable PET

-
Highest GWP, compared
to PET, glass and tetra
pack

0
Relatively low GWP,
nearly on par with light
glass bottles, depend-
ing on whether they
are reusable

Water
footprint

+
smallest water foot print,
as PET is made from fossil
resources

-
A lot of water is needed
in the manufacture of
glass, more than for
manufacture of PET

-
A lot of water is needed
in the manufacture of
aluminium, more than
for PET

--
A lot of water is
needed to produce
the cardboard, which
is then coated to hold
liquids

Use of
renewable
resources

-
The resource for PET is fos-
sil based; a finite resource,
can possibly changed into
bio based plastics such as
corn starch, may result in
competition over cultiva-
ble land and higher water
demand

+
In large portions, glass
is made of sand; which is
available in abundance

+
One of the most
abundantly available
elements on Earth;
however, may also be
found in many other
minerals; yet it still is a
finite source

0
In large portions made
from cardboard and
thus paper fibres,
which are manufac-
tures from cutting
down trees

Use of
secondary
material

0
Although PET bottles are
recyclable, the PET bottles
oftentimes are not being
turned into new PET bottles,
but the plastic fibres are
processed for a different
purpose

+
Today, glass manufac-
ture uses a lot of waste
glass to mix with during
the manufacture of new
glass items; it is a mixed
of old and new glass

0
If the aluminium can is
made up of different
materials, such as com-
pounds, the aluminium
waste may be recycled
for a different purpose
(down cycling)

0
It is difficult to tell how
much recycled materi-
al is used for new liquid
packaging boards, as
they are no labels yet
indicating it

Health
aspects

0
May be used multiple times,
but needs to be washed be-
fore reuse, as bacteria can
infest the bottle

+
Easier to clean for reuse,
no health hazards known

0
The top should be wiped
before cleaning, to
avoid germs leaching
into the water when
pouring out

+
Manufactured and
filled at high tempera-
ture, no information on
germ infestation

Safety
aspects:
handling,
usage

+
Do not break easily, light
weight

-
Breakable, also drinking
straight from the bottle
may cause harm if top
is damaged or if glass
knocks against teeth;
heavy weight may be
difficult for disabled or
elderly people to handle

+
Does not break easily,
may create dents, light
weight, needs small
storage space

+
Does not break easily,
lighter weight, com-
pared to glass

8. Annexes


Kenya Plastic Action Plan 129

Economics
(world-
wide)

0
Production requires least
amount of resources, is
made from fossil resources

--
Production process is
longer, requires more
resources, also trans-
portation is more energy
intensive as they are heav-
iest in comparison with
PET, aluminium and liquid
packaging boards, this
also counts for collection

-
Production process
is longer, requires
more resources, also
transportation is more
energy intensive as
they are heavier,
this also counts for
collection

-
Production process
is longer, requires
more resources, also
transportation is more
energy intensive as
they are heavier, also
counts for collection

Economics
(price)

+
Usually cheaper than glass,
aluminium cans and tetra
packs, especially consider-
ing filling volume, PET has
biggest filling volume

-
Most expensive, but filling
volume across many
ranges

0
Less expensive than
glass, more expensive
than tetra packs and
PET, considering the
filling volume

0
More expensive than
PET and cans, but less
than glass

Consumer
aspects

0
Light weight, thus easy to
transport and carry around,
more difficult to clean

+
Heavy weight, thus may be
more difficult to transport,
may look aesthetically
pleasing, easier to clean

0
Single-use, refilling
does not work, small
units, small filling
volume, may be an
alternative for trav-
elling as they do not
need much space

+
Can be disposed of
in the plastic waste;
recyclable, single-use,
heavier weight than
PET, but lighter than
glass

Waste
manage-
ment

0
Returnable PET bottle
system not available every-
where yet, adequate waste
management infrastructure
needs to be established

0
Returnable glass bottle
system not available
everywhere yet; ade-
quate waste management
infrastructure needs to be
established

0
Returnable alumin-
ium can system not
available everywhere
yet; adequate waste
management infra-
structure needs to be
established

--
Tetra pack techni-
cally recyclable, but
only in specific paper
mills which are not
available everywhere,
therefore disposal in
waste-paper should
be avoided as regular
paper mills cannot
process liquid packag-
ing boards; adequate
waste management
infrastructure needs
to be established

The same principles apply to the comparison for cooking oil (HDPE vs. metal and glass) and yoghurt cups (PP
vs. liquid packaging board and glass).

Carrier bags: LDPE vs. paper, cotton and non-woven PP
As mentioned (see chapter 3), the Kenyan government passed a ban prohibiting on the use, manufacture and
importation of all plastic bags for commercial and household packaging, which includes PE carrier bags and PE
flat bags, to reduce the amount of littered plastic bags as well as the associated negative externalities of littered
plastics in the environment. However, many concerns have been voiced after that questioning if the alternatives
provide are indeed better from an environmental perspective.


Kenya Plastic Action Plan 130

The Danish Ministry of Environment and Food published the ‘Life Cycle Assessment of grocery carrier bags’ in
2018 [Bisinella, 2018] researching the life cycles and environmental impacts of different types of carrier bags,
as well as how many times they needed to be reused to break even with the environmental impact of an average
LDPE plastics grocery shopping bag.

The study examined the following types of carrier bags available in stores in Denmark:

• LDPE, four types: average, soft handle, rigid handle, recycled
• PP, two types: non-woven, woven
• Recycled PET
• Polyester (of virgin PET polymers)
• Starch-complexed biopolymer
• Paper, two types: unbleached, bleached
• Cotton, two types: organic, conventional
• Composite (jute, PP, cotton)

A Life Cycle Assessment (LCA) takes into account the potential environmental impacts related to the resources
which are necessary to produce, use and dispose of the product. The LCA also examines the potential emissions
that may occur during the disposal. To assess the carrier bags and their environmental impact, the different
materials as shown above were compared to the characteristics of an average LDPE carrier bag which is available
in Danish supermarkets.

End-of-Life scenarios for carrier bags
The study examines three main end-of-life (EOL) scenarios for the different types of carrier bags. EOL1 would
be incineration of the carrier bag. After serving its primary function (carrying groceries from supermarkets to
another destination) the bag is disposed of, collected and incinerated. The electricity and heat produced during
incineration allows for avoiding the production of electricity and heat from another source.

The second EOL is recycling of the material. After disposal with separately collected material of the same type,
the collected waste is sent to material recycling. The recycled secondary material allows for avoiding production
of the same amount of material from primary sources. The residues of the recycling process are incinerated
which results in the production of electricity and heat, which allows for avoiding the production of heat and
electricity from other resources.

The third EOL is the reuse as waste bin bag. After serving its primary function, the carrier bag is reused for
another function, which is collecting residual waste. This practice allows avoiding the production and disposal
of a traditional waste bin bag. The electricity and heat produced during incineration process allows for avoiding
production of the same amount of electricity and heat from other resources.

Factors not included in the study
This Life Cycle Assessment does not consider behavioural changes or consequences of introducing further economic
measures. Also economic consequences for retailers and carrier products are not taken into consideration.
Moreover, this report does not include the effects of environmental littering. Neither does it include construction
and decommissioning of capital goods such as infrastructure and machinery, nor does it analyse the existing
capacities or new capacities requirements.

8. Annexes


Kenya Plastic Action Plan 131

Environmental indicators examined in this study
In determining the carrier bag with the smallest environmental impact, the study examined the life cycle of the
different types in relation to recommended environmental indicators as stated by the European Commission.
These indicators were:

• Climate change
• Ozone depletion
• Human toxicity, cancer effects
• Human toxicity, non-cancer effects
• Photochemical ozone formation
• Ionizing radiation
• Particulate matter
• Terrestrial acidification
• Terrestrial eutrophication
• Freshwater eutrophication
• Marine eutrophication
• Ecosystem toxicity
• Resource depletion, fossil
• Resource depletion, abiotic
• Water resource depletion

In the study, the different types of carrier bags were examined in relation to the environmental indicators as
shown before. The indicator climate change was also viewed separately for the different types of carrier bags.
This indicator includes factors such as global air temperature change or concentrations of CO2 in the atmosphere.

Results of Life Cycle Impact Assessment
In almost all categories, grocery bags made of LDPE provided the lowest environmental impact out of the materials
examined. Overall, light carrier bags such as LDPE, paper and biopolymer were the carrier bag alternatives which
provided the lowest environmental impact. Heaver multiple-use carrier bags such as composite and cotton bags
obtain the highest environmental impacts across all impact categories. Therefore, it is useful to determine how
many times a type of bag needs to be reused to lower the environmental impacts related to their production
to values comparable to lighter carrier bags. Thus, the study also calculated how many times different types of
carrier bags would have to be reused to provide the same environmental performance as the LDPE carrier bag:

• All environmental indicators considered, a recycled LDPE bag would have to be reused twice, before being
used as a waste bin bag and then disposed of.

• Non-woven PP bags should be reused 52 times, before being recycled.
• Woven PP bags need to be reused 45 times, and then recycled, to break even with LDPE bags.
• Bags made from recycled PET would need to be reused 84 times to have the same environmental impact as

LDPE bags, before they are being recycled.
• Polyester PET needs to be reused 35 times and then recycled.
• Considering all indicators, bags made from biopolymers need to be reused 42 times, before they are either

used as a waste bin bag or incinerated.
• Unbleached paper bags should be reused 43 times before they are either used as waste bin bags or are

incinerated.
• Bleached paper also needs to be reused 43 times, until it is either used as a waste bin bag or incinerated.
• Organic cotton should be reused 20,000 times before it is either used as a waste bin bag or incinerated to

break even with LDPE bags.
• Conventional cotton needs to be reused 7,100 times, before it is used as a waste bin bag or incinerated.
• Composite bags should be reused 870 times before they are used as waste bin bags or are incinerated.


Kenya Plastic Action Plan 132

The comparable study ‘Life cycle assessment of supermarket carrier bags: a review of the bags available in 2006’
commissioned by the UK Environment Agency and published in 2006 [Edwards, Frey, 2011], comes to overall
similar conclusions as the 2018 Danish report.

In the Life Cycle Assessment, grocery carrier bags available in UK supermarkets were examined. However,
contrary to the 2018 study, the UK Environment Agency then used conventional HDPE bags as reference, as
they were the average bags being handed out for free in grocery stores at the time. One of the goals of this
study was to determine a life cycle inventory of environmental impacts associated with the production, usage
and disposal of lightweight carrier bags. Another goal was to compare the environmental impacts arising from
lightweight plastic carriers to those caused by alternatives. In this study, however, several factors were not
taken into consideration. These include the consequences of carrier bag taxes, the effects of littering, the ability
to and willingness of consumers to change their behaviour, any adverse impacts of degradable polymers in the
recycling stream and potential economic impacts on the UK industry.

Environmental impact indicators as used in the research
To determine the environmental impact of the different types of carrier bags, the study formulated a total of
nine environmental indicators:

• Global warming potential
• Abiotic depletion
• Acidification
• Eutrophication
• Human toxicity
• Fresh water and aquatic ecotoxicity
• Marine aquatic ecotoxicity
• Terrestrial ecotoxicity
• Photochemical oxidation

The indicators as shown above are largely comparable to the set of environmental indicators which the Danish
study used in their 2018 life cycle assessment report.

Results of life cycle assessment
The study concluded that conventional HDPE bags provided the lowest environmental impact of lightweight bags
in eight out of nine environmental impact categories.

• LDPE bags need to be reused five times in order to reduce their environmental impact below that of the
conventional HDPE bag.

• A paper bag would need to be reused four times to reduce its global warming potential to below that of a
conventional HDPE bag. However, many reuses are unlikely due to its low durability.

• Cotton bags provided a greater environmental impact than conventional HDPE bags in seven out of nince
categories. 173 reuses are required to reduce the environmental impact below of that of a conventional HDPE
bag with average secondary reuse impact.

8. Annexes


Kenya Plastic Action Plan 133

Overall, when compared to a conventional HDPE bag which is disposed of and is not used to serve a secondary
use as, e.g. a waste bin liner, then a paper bag needs to be reused 3 times, an LDPE bag should be reused four
times, a non-woven PP bag should be reused 11 times and a cotton bag needs to be reused 131 times, to reduce
their environmental impact to that of a conventional HDPE bag.

Both studies that were used as a reference concluded that grocery shopping bags out of LDPE and HDPE respectively
provided overall lower environmental impacts than paper, cotton und non-woven PP bags. That being said it is
important to consider that factors such as environmental littering were not taken into consideration during both
life cycle assessments as both studies analysed the different materials for carrier bags from a superordinate
angle. A comparsion of the different material solutions is shown in Table 22.


Kenya Plastic Action Plan 134

Table 22: Comparison of different materials for carrier bags

Comparison: Grocery carrier bags
Criteria LDPE Paper Cotton Non-Woven PP

GWP

+
Overall best climate
change performance

-
More impact than LDPE
and non-woven PP, due
to trees being cut down,
heavier weight

-
More impact than
LDPE, paper and
non-woven PP due
to longer production
process of cotton
fibres, heavier weight

0
More impact than
LDPE but better
than cotton and
paper

Water footprint

+
Overall smallest water
footprint, resource for
conventional plastic is
fossil-based

-
Bigger water footprint
than LDPE, much water
is needed in production
of paper fibres

--
Bigger water footprint
than LDPE and paper,
much water is needed
to produce cotton
yarn and fertilizer
production

0
More water is used
than for LPDE bags,
but less than for
paper and cotton
bags

Use of

renewable

resources

-
Resource for convention-
al plastic is fossil-based,
a finite resource, can
possibly changed into bio
based Plastics such as
corn starch, may result in
competition over cultiva-
ble land and higher water
demand

0
Made out of renewable
resources but trees need
to be cut down to gain
paper fibres, results in
deforestation; usage
of fertilizers result in
terrestrial and freshwa-
ter eutrophication, high
water demand

0
Made of renewable re-
sources but deforest-
ation due to growing
demand for cotton
fibres and therefore
cotton plants; usage
of fertilizers results
in terrestrial and
freshwater eutrophi-
cation, plants need a
large amount of water
to grow

-
Resource for con-
ventional plastic is
fossil-based, a finite
resource, can possi-
bly changed into bio
based Plastics such
as corn starch, may
result in competi-
tion over cultivable
land and higher
water demand

Use of

secondary

material

+
Highly eligible for use of
secondary material, al-
ready done in many cases

+
Highly eligible for use
of secondary material,
already done in many
cases

-
Normally no use of
secondary material

+
Highly eligible for
use of secondary
material, already
done in many cases

Health aspects

-
LDPE has slightly more
human toxicity

0
On par with non-woven
PP, provided the least
human toxicity

--
Cotton provided the
most human toxicity;
may become habitat
for bacteria, fungi and
mould

0
On par with paper,
provided the least
human toxicity

Safety aspects:
handling, usage

--
LDPE bags fly away eas-
ily, littering, potentially
dangerous when ingested
(wildlife), breeding spot
for mosquitoes

0
Paper bags tear easily,
especially when wet, dif-
ficult to clean, takes up
more space than plastic

+
Not sanitary for
handling edibles, but
generally meant for
multiple use, wash-
able

+
Generally meant for
multiple use, sturdy,
durable

8. Annexes


Kenya Plastic Action Plan 135

Economics

(worldwide)
- to 0

Bags used world-
wide, banned
in some places,
customer incentive
in favour of multi-
ple-use

0
Generally avail-
able for fee, not
commonly used in
supermarkets, yet
some retailers (tex-
tile) give them out
for free

-
Usually available for
purchase, but produc-
tion requires a lot of
resources related to
manufacture of cotton
fibres

0
In places with bans
against single-use plastic
bags, they are commonly
used, usually available for
purchase

Economics

(price)
++

Price for LDPE is
cheapest, retailers
make profit when
they sell bags for
e.g. 20 ct

0
More expensive
than LDPE bag but
cheaper than cot-
ton, less durable

-
Most expensive bag
compared to LDPE,
non-woven PP and
paper bag

+
Generally less expensive
than cotton bag, but more
expensive than LDPE and
paper bags

Consumer

aspects
- to 0

Meant for single to
multiple use, flexi-
ble, lightweight

-
Multiple-use is diffi-
cult because paper
has low durability,
especially when wet,
recycling oftentimes
easier

0
Meant for multiple use,
doesn‘t tear easily,
repairable, washable,
not sanitary for edibles,
(attractive design)

0
Meant for multiple use,
sturdy, usually large
capacity, some stores give
discount when one shops
with such a bag

Waste

management
-

Collection with oth-
er PE, plastics but
hard to collect, flies
away, danger of
littering, pollution,
recyclable

+
Can be collected
with other papers,
degradable in envi-
ronment, recyclable

-
Can be collected with
waste textiles if exist-
ent, no proper recycling

N/A


Kenya Plastic Action Plan 136

Construction Pipes: Plastics vs. (galvanised) steel and concrete
Construction pipes are used in areas such as sewerage and drainage or water supply and waste water disposal.
For the following examination it is assumed that the pipes, which are made of different kinds of materials, are
equally suitable for the required utilisation, as they are subject to standard such as technical norms.

The table identifies the GWP100 of the different types of pipes in Table 23. According to this the different materials
lie within a comparable range at a GWP value of 1.94 (steel) to 3.23 (PVC) per kilogram.

Category GWP100
[kg CO

2
equi.] per kg

Database

HDPE Pipe 2.52 Bath Uni via [Carbon Footprint Ltd, n.y.]

PVC Pipe 3.23 Bath Uni via [Carbon Footprint Ltd, n.y.]
Steel Pipe - World Typical -
World 39% Recy.

1.94 Bath Uni via [Carbon Footprint Ltd, n.y.]

Steel Pipe - Galvanised
(typical 35.5 % Recy.)

> 2.12
Bath Uni via [Carbon Footprint Ltd, n.y.], data for
steel coil plus contribution for pipe construction

Table 23: Selected GWP100 for construction pipes

Different surveys examined the environmental performance evaluation of different kinds of pipes. Due to the
multitude of possible types of piping system, usually comparable applications are balanced. These are portrayed
as follow: The survey ‘Polypropylene Materials for Sewerage & Drainage Pipes with Reduced Energy and Carbon
Footprints’ Wassenaar [2016] compares the environmenteal impact in terms of GWP and non renewable energy
demand (NRED) of innovatively produced PP pipes (based on high modulus propylene block copolymers [HM] and
mineral modified propylene [MD]) with standard block copolymer [B] PP pipes, as well as concrete materials. The
study has been conducted according to the international ISO 14020 and 14021 standards governing environmental
claims, particularly their accuracy. The compliance of the LCA with these standards has been verified by an
external independent auditor.

The functional unit is 1 m of installed plain wall pipe with a ring stiffness of >8 kN/m². The base case considers
a DN of 250 mm for plastic pipes and the closest equivalent concrete pipe size (DN 225 mm). The weight which
results from the functional unit is pivotal for further examination:

• PP-MD (DN 250 mm): 8.0 kg per m
• PP-HM (DN 250 mm): 5.9 kg per m
• PP-B ((DN 250 mm): 6.6 kg per m
• Concrete (DN 225 mm): 97.6 kg per m

It is evident that the specific weight of concrete compared to PP (or plastics in general) for the same application is
many times higher (12 to 16 times). If the diameter is bigger, this proportion decreases. For a diameter of 800 mm
for plastic pipes and 750 mm for concrete pipes, the proportion ranges at seven to nine times [Wassenar 2016].

8. Annexes


Kenya Plastic Action Plan 137

In comparision, the following results appear: Concrete pipes have a higher GWP due to the production of raw
materials (nearly twice, see Figure 34). Generally, the raw materials production accounts for that, which is
comparable to the raw material production of PP, as well as the related transformation. If transportation is
taken into consideration, the GWP results in a higher figure for concrete pipes, predominantly due to the heavier
specific weight.

Contrary to that, plastic pipes generally provide a higher NRED due to the fact that for plastic pipes the largest
contributor to NRED is associated with the internal energy component of the raw material (see Figure 35).

Figure 34: GWP for 1 m of installed plain wall sewerage and drainage pipe [Wassenaar, 2016]

Figure 35: NRED for 1 m of installed plain wall sewerage and drainage pipe [Wassenaar, 2016]


Kenya Plastic Action Plan 138

The survey ‘Life Cycle Analysis for Water and Wastewater Pipe Materials’ [Du et al., 2013] examines the LCA
damages of six commonly used pipe materials (PVC, ductile iron, cast iron, HDPE, concrete and inforced concrete).
The function unit is a 12-inch pipe (30.5 cm) per km. Table 24 identifies the results of the GWP according to
different phases. The installation phase for iron is highest due to the joining technology, while the transportation
phase is highest for concrete, due to its weight. Both of these phases are nearly irrelevant for the total GWP,
because the highest GWP contributions result from the production.

Table 24: Phase-Dependent and Total GWP per km of 30.5 cm (12 in.) diameter pipes for different Materials
[Du et al., 2013]

Pipe materials
(12-in. pipe)

Total GWP (10³
kg CO

2
/km)

Production phase
(10³ kgCO

2
/km)

Installation phase
(10³ kgCO

2
/km)

Transportation phase
(10³ kg CO

2
/km)

PVC 318 315 2.81 0.26

Ductile iron 472 468 3.28 0.88

Concrete 68.3 63.1 2.91 2.26

HDPE 218 215 2.81 0.17

Reinforced
concrete

152 146 2.91 2.47

Cast iron 353 349 3.28 0.84

For the 12-inch diameter example, iron pipes contributed the greatest increment to GWP among the six kinds of
pipe materials compared. Concrete pipe had the lowest GWP, despite the energy demand associated with cement
production. This is contrary to survey of Wassenaar [2016], as mentioned above, although nearly similar basic
data was used for the examination of concrete pipes (main reference Marceau et al. [2007]). Further, Du et al.
[2013] identifes that PVC yields the greatest GWP per unit pipe legnth at diameters ≥76.2 cm (30 inch). This
seeming anomaly arises from the material-dependent schedule of pipe thicknesses, which increase dramatically
for plastic water pipes of diameter greater than 61.0 cm (24 in.).

Appropriate to EPA [2000] the different types of pipe systems provide advantages and disadvantages (Table 25).

8. Annexes


Kenya Plastic Action Plan 139

Table 26: Comparison of different materials for construction pipes

Comparison: construction pipes
Criteria Plastics Concrete Steel / iron
GWP +

Provide smallest GWP impact

-
Provide highest impact com-
pared to plastics and steel,
also, but not only because of
larger specific weight

0
Provide higher impact than
plastics, but lower than con-
crete

Water footprint +
Smallest water footprint com-
pared to concrete and steel

-
Largest Water footprint as it is
used to manufacture concrete

0
Larger water footprint than
plastic, but not as large as
concrete

Table 25: General advantages and disadvantages of plastic, concrete and steel/iron pipes [EPA, 2000]

Category Plastics Concrete Steel / iron

Advantages • Very lightweight

• Easy to install

• Economical

• Good corrosion resistance

• Smooth surface reduces
friction losses

• Long pipe sections reduce
infiltration potential

• Flexible

• Good corrosion resistance

• Widespread availability

• High strength

• Good load supporting capacity

• Good corrosion resistance
when coated

• High strength

Disadvantages • Susceptible to chemical attack,
particularly by solvents

• Strength affected by sunlight
unless UV protected

• Requires special
bedding

• Requires careful
installation to avoid cracking

• Heavy

• Susceptible to attack by H
2
S and

acids when pipes are not coated

• Heavy

A cost comparison identifies that concrete pipes per meter are generally the cheapest, however they are only
offered with larger diameters. Plastic pipes are usually cheaper than comparable stell/iron pipes [EPA, 2000;
Rafferty, 1998].2

A comparsion of the different material solutions is shown inTable 26.


Kenya Plastic Action Plan 140

Use of renewable
resources

-
Resource for conventional
plastic is fossil-based (a finite
resource), can possibly changed
into bio based plastics such as
corn starch, may result in com-
petition over cultivable land and
higher water demand

-
Manufacture requires a lot
of energy, sand as resource
is not abundantly available

-
Manufacture requires a lot
of energy; one bases of steel
is iron ore, which is a finite
resource

Use of secondary
material

0
If made from mono-material:
technically possible to recycle
them, otherwise down cycling is
possible

0
Generally recyclable if it
is free of contaminants;
concrete can be used in
the manufacture of new
concrete

++
Generally high recycling rates,
secondary steel is commonly
used in today’s steel manufac-
ture

Health aspects

0
Do not rust; drinking water from
plastic pipes older than 1970s
could potentially be harmful;
solvents may attack pipe

0
Do not rust; acids and H2S
may damage pipes if not
coated

0
If galvanized, it does not rust;
acidic and alkaline water dam-
ages them

Safety aspects:
handling, usage

+
Light weight, corrosion resist-
ance; good resistance against
electric current; relatively easy
to repair / replace; long pipe sec-
tion reduces infiltration poten-
tial, strength affected by sunlight
unless UV protected, requires
special bedding

0
Heavy, weight corrosion
resistance; high strength
and long durability, heat
resistance; supposedly last
35 to 50 years, difficult to
repair

-
Heavy weight; corrosion
resistance when coated; high
strength, supposedly last
around ten years; can be joined
easily, cutting, bending and
threading is easy; higher risk
for potential damage at joints
at larger diameter

Economics (world-
wide)

+
Easy to install; smooth surface
reduces friction losses; flexible

+
Widespread availability;
good load supporting ca-
pacity

+
Relatively easy to install, not as
heavy as concrete

Economics (price)
+

Generally cheapest compared to
steel and concrete

-
Pipes generally offered at
larger diameter

0
Cheaper than concrete, more
expensive than plastic pipe

Consumer aspects

+
Economical, easier to transport
and install

-
Transportation is more dif-
ficult compared to steel and
plastics because of larger
weight

-
Longevity may be needed
to consider, as they may be
threatened by corrosion

Waste manage-
ment

0
Industrial waste oftentimes
provides more mono-materials
as household waste, therefore
recycling is theoretically possible
at larger scale, but adequate
waste management infrastruc-
ture needs to be established

0
If free of contaminants such
as wood or paper, concrete
may be recycled to be used
in the manufacture of new
concrete; adequate waste
management infrastructure
needs to be established first

+
Steel can technically be recy-
cled without any forms of ma-
terial loss; however, adequate
waste management infrastruc-
ture needs to be established

8. Annexes


Kenya Plastic Action Plan 141

8.10 Annex 10: Global examples of education and awareness programmes
In California, the California Education and the Environment Initiative exists. The initiative is one of CalRecycle’s
(California’s Department of Resources Recycling and Recovery) Office of Education and the Environment (OEE)
programs that aim encourage environmental literacy among all California students from Kindergarten to 12th
grade. The initiative provides curricula that combine the environment with the teaching of traditional academic
subjects such as science, history, English language, and arts. Some of the topics discussed in the curricula are
about earth and its resources, the history of the impact the human behaviour had on the environment, and the
critical environmental issues the modern world faces [California Education and the Environment Initiative, n.y.].

One more example is the 2012 cooperation between the Paper Recycling Association of South Africa (RecyclePaperZA)
and the Department of Education to incorporate recycling in the maths curriculum. The topic of recycling was
integrated in the syllabus of grades R through seven. In partnership with E-CLASSROOM, a website that provides
curriculum-based educational resources, the recycling-focused lessons are found in grade three, Life Skills content
on the website. More content has also been developed to integrate recycling in Mathematics (data handling)
and English for Grade one to six, using paper products as examples. Recycling as a curriculum topic ensures
that learners grow up with an awareness of waste and the importance of recyclability [RecyclePaperZA, n.y].

Fostplus, Belgium (the Belgian PRO) launched multiple campaigns that target litter problem in Belgium. In 2016
with the support of the Fevia and Comeos sector organisations, Fostplus signed an agreement with the Flemish,
Walloon and Brussels authorities to tackle the problem through campaigns and events. One example is the Grand
Nettoyage de Printemps (Great Spring Clean) campaign in Wallonia in April 2016, where 40,000 participants
cleared plots of land, streets and parks of litter. Another campaign was the Retail Clean-Up Days, November
2016. 1,100 shops in Flanders and Wallonia participated in the Retail Clean-Up Days. Each shop agreed to clean
up the area within a 25 m radius of its premises. A surface area of 5.7 million m2 was cleaned up in total, the
equivalent of more than 1,150 football fields. There are other campaigns launched by Fostplus that aim to raise
awareness in communities about the correct way of sorting waste, and to stress the importance of sorting and
its positive impact on the environment and future [Fostplus, n.y.].

Another example of is the Orange Bin Campaign in Israel: Recycling corporations collecting packaging waste from
all of Israel launched the online campaign to raise public awareness about recycling and proper waste disposal.
The campaign used YouTube as a platform to spread its message by creating a video that features young Israelis
combining extreme sport with garbage collection to eliminate the negative idea about waste and recycling. The
video went viral gaining around 900,000 views. And according to a statistic released in 2014 by the Israel Union
for Environmental Defense and Migal, a Galilee research institute, over 300,000 Israeli households separate dry
and wet waste, representing a 400 % increase in two years (Weißenbacher, 2016).


Kenya Plastic Action Plan 142

8.11 Annex 11: Flow chart for determining the recyclability

8. Annexes


Kenya Plastic Action Plan 143

Notes


Kenya Plastic Action Plan 144

Sustainable Development Goals


Inner back cover


Kenya Plastic Action Plan 146

November 2019

Accelerating a Circular Economy in Kenya

Kenya Plastic
Action Plan

Kenya Association of Manufacturers
15 Mwanzi Road opp West Gate Mall, Westlands

P.O. Box 30225 – 00100 Nairobi, Kenya

E: info@kam.co.ke
M: +254 (0) 722201368, 734646004/5

T: +254 (020) 2324817
Twitter: @KAM_Kenya

Facebook: KenyaAssociationOfManufacturers

www.kam.co.ke

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targets

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legal frameworks and measures established
to support;

EPR scheme/ Producer Responsil
(PRO)

Incentives to create an enabling environment for
waste recycling

National and County coordination on waste
management


ity Organization


Delegation of German Industry
and Commerce in Kenya
Delegation der Deutschen Wirtschaft
in Kenia


THE BUSINESS ADVOCACY FUND

Supporting Private Public Dialogue


Packaging

users
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Greater Nairobi
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Electrical / Electronic
Transportation 44%
6.6%


Consumer & Industrial Products
10.3% Packaging

35.9%

Textiles
11.5%

Other Sectors

15.2% Building & Construction

16%


Transportation 4.3%
5.6%


Consumer & Industrial Products
12.3%

Packaging
46.7%

Textiles
12.6%

Other Sectors

14.2% Building & Construction

4.3%


Products (non-waste) Prevention


—_ least favoured option Disposal


%

REGERINGEN

Plastic without waste

+ The government's action plan plastic


ane


Waste Collection Sorting Recycling & Composting Output & Sales
‘Manufacturing
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Residual Landfill
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TRADING RECYCLABLE MATERIALS WHILE ACHIEVING
TANGIBLE SOCIAL AND ENVIRONMENTAL IMPACT


SOCIAL IMPACT SMART TECHNOLOGY FAIR TRADE PRODUCTS
@


Integrating informal Waste | averaging technology to manage Fairly sourced recycled materials
Collectors into our value chain and streamline operations for local and international markets

& 6 la
2,500 110 3,000 to

Waste Direct Jobs Plastic Waste
Collectors crealed recycled.


quantities
exported raw
material *


quantities
exported products
& packaging *


quantities
exported
waste *


Informal secto

* Differentiated into fractions of PET (1), HDPE (2),
PVC (3), LDPE (4), PP (5), PS (6); and others (7)


converting


pelletizing

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waste

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Purchases through distributor and later
disposal


Packaging flow


Regulations and Monitoring

Cash flow

Packaging flow

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Heian Management of operators
paid contributions (WMo)
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COLLECTIVE RESPONSIBILITY

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es

—"
Botellas y envases de Papel y cajas de cartén: Botellas de vidrio: vino, Contenedor de restos:
plastico: productos de envases de alimentacion, cavaolicores. este es el contenedor para
higiene y limpieza, calzado, productos otro tipo de residuos como
tarrinas, bandejas, congelados, papel de Frascos de vidrio: alimentos, plantas,
envoltorios y bolsas. envolver, papel de uso perfume, colonia o similar. materiales organicos.

diario, etc.

Envases metélicos: latas, Tarros de alimentos:
bandejas de aluminio, mermelada, conservas,
aerosoles, botes de vegetales, etc.
desodorante tapas y

tapones metélicos.
Briks de leche, zumos,

sopas, etc.

2Y dénde van productos como el aceite, las pilas, los muebles o los electrodomésticos? Ponte en contacto con tu Ayuntamiento para que
te informe del Punto Limpio mas cercano a tu domicilio.

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Import of plastic goods
plastic items know the weight


to Kenya and the material _——_

of these items.


29.4% China
3.9% Japan
16.8% Rest of Asia


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3 Principles & 10 Corresponding Strategies


, Circular...
Prioritise sourcing
renewable
A Sustainable
inputs design “-""
Resource ___
efficiency
Maximise
product use
Product as
aservice
Lieto
by-products
and waste Production /
Distribution


* Circularity can be centred around three overarching
principles, which define ten corresponding strategies.

* The diagram illustrates the continuous flow of resources
in both the production/ distribution phase and the
consumption phase.

* Circularity in the production/ distribution phase is
anchored in four strategies (1-4) that aim to maximise the
use of renewables and minimise value leakage across the
value chain.

Source: PwC analysis


a> Primary


1r

Recyeling from

material consumption
Recyeling from
Design / R&D manufacturing
Refurbishing/
Manufacturing Temanufacture
(or constructing) (up-cycling)
rae Reuse/
Distribution / ~ redistribution
retail
Usage / Usage
. optimization!
Cee oon maintenance
~» Sharing
virtualizing


Value leakage
Consumption

Circularity in consumption has six strategies (5-10)

that reduce value leakage by circulating products and
materials at their highest utility through sharing, reuse,
repair, remanufacturing, and recycling.

The end-of life of a product represents value leakage as
important by-products are not collected for productive
use. Instead of leaking value by discarding products and
materials after use, the circular economy stops this value
leakage in order to yield more value.


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a PLASTICS
ot aia


9 deveiopnent GALS

i aN) erty ua
EN ate ah 6 iw BUT

a v

eT ia UFE a Hans Su a
eH as OTE) 16 EU 1 FORTHE GOALS @
ial i SUSTAINABLE
6- a a DEVELOPMENT
G@ALS


6 ALLIANCE TO
END PLASTIC WASTE


EF
i
i
;
A

‘Can you specify on the respective volumes you purchase eg. per month or per year?

4. Arethere challenges faced by industry at county and national level inthe implementation
fof a sustainable waste management practices? Can youbbriefly describe if applicable?

|S, Hasyour company put in place a take back scheme for your packaging products? If so,
please give 2 brief description |


GWP (kg CO, eq/fu)

35
30
25
20
15
10


PP-MD


PP-B


Concrete
(DN 225)

Pipe Installation

Pipe Transport
®Transformation
Transport of raw materials

Production of raw materials


NRED (MJ/fu)

=> Ny ® RB DO @YN
es S& 5S 8 SS
cS 5S SF SF FS SB


I _
N


seooas
PaaDD
sa 3a3 5
gs 338

26S 5 @

2
27 FoF
= 6
ag37 8


_—
plastic packaging &
non-packaging items

eo

|<" __ recyclable contents?

vyes/ percentage

no___ collection and recycing
i. structure available?

vyes/ percentage

no. targetoriented
i. sorting possible?
vyes/ percentage
no. technically
<—— recoverable?

vyes/ percentage

< = regenerable?

yes/ percentage
reket =

i ecateator?

high quality


mt’

LTT by

PRODUCTION,
PROCESSING


CIRCULAR ECONOMY

WASTE REMAINS 00
— MM

USE, REUSE,
aN

Email

  • G@ALS
  • info@kam.co.ke

Email domain

  • kam.co.ke
  • ALS

Phone numbers

  • 2823021070245502823
  • 37030283502835
  • 218215281017
  • +2540202324817
  • 800008000100001000
  • 40900109001050
  • 6600066000570005700
  • 904482010
  • 472003770
  • 244002200
  • 152146291247
  • +2540722201368
  • 810008100081001220012200125001250
  • 3800106001230
  • 24052019
  • 1340013400077000100001000134001340
  • 5213561240
  • 6100058000610001000
  • 18500062001850
  • 149001490
  • 220015800223002230
  • 13300133001330
  • 55000550005500100001000
  • 3876038760120001200
  • 892008920089200758
  • 353349328084
  • 9788793614734
  • 472468328088
  • 312002470
  • 231902319
  • 318315281026
  • 26062019
  • 683631291226

Phone numbers

  • 2319 0.2319
  • 550 0.0550 0.0550 0.1000 0.1000
  • 2440 0.2200
  • 4720 - 0.3770
  • 892 0.0892 0.0892 0.0758
  • 1340 0.1340 0.0770 0.0100 0.0100 0.1340 0.1340
  • 4090 0.1090 - 0.1050
  • 24.05.2019
  • 800 0.0800 - - - 0.1000 0.1000
  • 26.06.2019
  • +254 (0) 722201368
  • 1850 - - 0.0620 - 0.1850
  • 3120 - - 0.2470
  • 472 468 3.28 0.88
  • 810 0.0810 0.0810 0.1220 0.1220 0.1250 0.1250
  • 353 349 3.28 0.84
  • 904.48 2010
  • 5213-5612-40
  • 6100 - - 0.5800 - 0.6100 0.1000
  • 1490 0.1490
  • 318 315 2.81 0.26
  • 6600 0.6600 - 0.5700 0.5700
  • 3876 0.3876 - 0.1200 0.1200
  • 68.3 63.1 2.91 2.26
  • 3703 0.2835 0.2835
  • 380 0.1060 0.1230
  • +254 (020) 2324817
  • 1330 0.1330 0.1330
  • 2823 - 0.2107 0.2455 - 0.2823
  • 220 - 0.1580 - 0.2230 0.2230
  • 218 215 2.81 0.17
  • 152 146 2.91 2.47
  • 978-87-93614-73-4

Law clause

Article 42

Law code

Filename extension

pdf

Countries

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Chroma_ColorSpaceType:
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Chroma_NumChannels:
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Component_1:
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert
  • Y component: Quantization table 0, Sampling factors 2 horiz/2 vert


Component_2:
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cb component: Quantization table 1, Sampling factors 1 horiz/1 vert


Component_3:
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert
  • Cr component: Quantization table 1, Sampling factors 1 horiz/1 vert


Compression_CompressionTypeName:
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Compression_Lossless:
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Compression_NumProgressiveScans:
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Compression_Type:
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Creation-Date:
2019-12-04T11:20:06Z

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Data_PlanarConfiguration:
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Data_Precision:
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Dimension_ImageOrientation:
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Dimension_PixelAspectRatio:
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Exif_IFD0_Compression:
T6/Group 4 Fax

Exif_IFD0_Image_Height:
1181 pixels

Exif_IFD0_Image_Width:
1181 pixels

Exif_IFD0_Photometric_Interpretation:
WhiteIsZero

Exif_IFD0_Resolution_Unit:
Inch

Exif_IFD0_Rows_Per_Strip:
1181 rows/strip

Exif_IFD0_Samples_Per_Pixel:
1 samples/pixel

Exif_IFD0_Software:
PDFBOX

Exif_IFD0_Strip_Byte_Counts:
11351 bytes

Exif_IFD0_Strip_Offsets:
183

Exif_IFD0_X_Resolution:
72 dots per inch

Exif_IFD0_Y_Resolution:
72 dots per inch

File_Modified_Date:
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  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.jpeg.JpegParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.jpeg.JpegParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.jpeg.JpegParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.jpeg.JpegParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.image.ImageParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.image.ImageParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.image.ImageParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.image.ImageParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.jpeg.JpegParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.jpeg.JpegParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.jpeg.JpegParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.jpeg.JpegParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.jpeg.JpegParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.jpeg.JpegParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.jpeg.JpegParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.jpeg.JpegParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.image.ImageParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.image.ImageParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.image.ImageParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.image.ImageParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.jpeg.JpegParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.jpeg.JpegParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.jpeg.JpegParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.image.ImageParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.jpeg.JpegParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.jpeg.JpegParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.jpeg.JpegParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.jpeg.JpegParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.jpeg.JpegParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.image.ImageParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.jpeg.JpegParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.jpeg.JpegParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.jpeg.JpegParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.jpeg.JpegParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.jpeg.JpegParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.image.ImageParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.image.ImageParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.jpeg.JpegParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.jpeg.JpegParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.jpeg.JpegParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.jpeg.JpegParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.jpeg.JpegParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.jpeg.JpegParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.image.ImageParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.jpeg.JpegParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.image.ImageParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.image.ImageParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.image.ImageParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.jpeg.JpegParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.image.ImageParser]
  • [org.apache.tika.parser.DefaultParser, org.apache.tika.parser.ocr.TesseractOCRParser, org.apache.tika.parser.jpeg.JpegParser]


etl_enhance_extract_text_tika_server_time_millis_i:
16405

etl_enhance_extract_text_tika_server_b:
1

etl_enhance_pdf_ocr_time_millis_i:
8

etl_enhance_pdf_ocr_b:
1

etl_enhance_detect_language_tika_server_time_millis_i:
45

etl_enhance_detect_language_tika_server_b:
1

etl_enhance_contenttype_group_time_millis_i:
1

etl_enhance_contenttype_group_b:
1

etl_enhance_pst_time_millis_i:
1

etl_enhance_pst_b:
1

etl_enhance_csv_time_millis_i:
0

etl_enhance_csv_b:
1

etl_enhance_extract_hashtags_time_millis_i:
39

etl_enhance_extract_hashtags_b:
1

etl_enhance_warc_time_millis_i:
5

etl_enhance_warc_b:
1

etl_enhance_zip_time_millis_i:
1

etl_enhance_zip_b:
1

etl_clean_title_time_millis_i:
0

etl_clean_title_b:
1

etl_enhance_rdf_annotations_by_http_request_time_millis_i:
31

etl_enhance_rdf_annotations_by_http_request_b:
1

etl_enhance_rdf_time_millis_i:
0

etl_enhance_rdf_b:
1

etl_enhance_regex_time_millis_i:
760

etl_enhance_regex_b:
1

etl_enhance_extract_email_time_millis_i:
511

etl_enhance_extract_email_b:
1

etl_enhance_extract_phone_time_millis_i:
454

etl_enhance_extract_phone_b:
1

etl_enhance_extract_law_time_millis_i:
733

etl_enhance_extract_law_b:
1

etl_export_neo4j_time_millis_i:
1024

etl_export_neo4j_b:
1

X-TIKA_content_handler:
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler
  • ToTextContentHandler


X-TIKA_embedded_depth:
  • 0
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1
  • 1


X-TIKA_parse_time_millis:
  • 16204
  • 151
  • 128
  • 54
  • 62
  • 54
  • 47
  • 51
  • 48
  • 46
  • 43
  • 46
  • 55
  • 47
  • 45
  • 45
  • 46
  • 45
  • 46
  • 52
  • 50
  • 48
  • 51
  • 55
  • 53
  • 46
  • 48
  • 103
  • 61
  • 53
  • 102
  • 116
  • 76
  • 49
  • 43
  • 51
  • 50
  • 46
  • 72
  • 49
  • 72
  • 111
  • 87
  • 76
  • 70
  • 77
  • 54
  • 49
  • 60
  • 48
  • 53
  • 109
  • 88
  • 51
  • 77
  • 61
  • 67
  • 52
  • 102
  • 48
  • 49
  • 46
  • 45
  • 57
  • 61
  • 87
  • 73
  • 81
  • 52
  • 67
  • 76
  • 57
  • 55
  • 45
  • 57
  • 77
  • 49
  • 54
  • 71
  • 45
  • 46
  • 109
  • 84
  • 94


X-TIKA_embedded_resource_path:
  • /image0.tif
  • /image1.jpg
  • /image2.png
  • /image3.jpg
  • /image4.jpg
  • /image5.jpg
  • /image6.jpg
  • /image7.jpg
  • /image8.png
  • /image9.png
  • /image10.jpg
  • /image11.jpg
  • /image12.jpg
  • /image13.jpg
  • /image14.jpg
  • /image15.jpg
  • /image16.jpg
  • /image17.jpg
  • /image18.png
  • /image19.jpg
  • /image20.jpg
  • /image21.png
  • /image22.jpg
  • /image23.jpg
  • /image24.jpg
  • /image25.png
  • /image26.png
  • /image27.png
  • /image28.png
  • /image29.jpg
  • /image30.png
  • /image31.jpg
  • /image32.jpg
  • /image33.jpg
  • /image34.jpg
  • /image35.jpg
  • /image36.png
  • /image37.png
  • /image38.png
  • /image39.png
  • /image40.jpg
  • /image41.jpg
  • /image42.jpg
  • /image43.jpg
  • /image44.jpg
  • /image45.jpg
  • /image46.jpg
  • /image47.jpg
  • /image48.png
  • /image49.png
  • /image50.png
  • /image51.png
  • /image52.jpg
  • /image53.jpg
  • /image54.jpg
  • /image55.png
  • /image56.jpg
  • /image57.jpg
  • /image58.jpg
  • /image59.jpg
  • /image60.jpg
  • /image61.png
  • /image62.jpg
  • /image63.jpg
  • /image64.jpg
  • /image65.jpg
  • /image66.jpg
  • /image67.png
  • /image68.png
  • /image69.jpg
  • /image70.jpg
  • /image71.jpg
  • /image72.jpg
  • /image73.jpg
  • /image74.jpg
  • /image75.png
  • /image76.jpg
  • /image77.png
  • /image78.png
  • /image79.png
  • /image80.jpg
  • /image81.png
  • /image82.jpg





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