Regional spotlight: Extended Producer Responsibility (EPR) in Sub-Saharan Africa — what's different and why it matters

South Africa's EPR regulations, which took full legal effect in November 2021 under Section 18 of the National Environmental Management: Waste Act, made the country the first in Sub-Saharan Africa to mandate producer responsibility across packaging, paper, electrical and electronic equipment, and lighting products. By the end of 2025, registered producer responsibility organizations (PROs) in South Africa had collected over 1.4 million tonnes of packaging waste, yet only 37% of the country's municipalities had functioning collection infrastructure linked to PRO systems (DFFE, 2025). This gap between regulatory ambition and on-the-ground implementation defines the EPR landscape across Sub-Saharan Africa: a region where policy frameworks are advancing faster than the infrastructure, institutional capacity, and market systems needed to make them work.

Why It Matters

Sub-Saharan Africa generates approximately 174 million tonnes of municipal solid waste annually, a figure projected to double by 2050 as urbanization accelerates across Lagos, Nairobi, Dar es Salaam, Kinshasa, and dozens of secondary cities (World Bank, 2024). Formal waste collection rates average 44% across the region, compared to 90% or higher in the EU. Without functioning EPR systems, the financial burden of waste management falls entirely on municipal governments that already operate under severe fiscal constraints. Lagos State, for instance, spends roughly $200 million per year on solid waste management, representing nearly 25% of its total recurrent budget, while recovering less than 15% of that cost through user fees (Lagos Waste Management Authority, 2025).

EPR shifts financial responsibility for end-of-life product management from municipalities and taxpayers to the producers and importers who place products on the market. For investors evaluating circular economy opportunities in Africa, understanding the region's EPR trajectory is essential for three reasons. First, EPR regulations create captive revenue streams for PROs, collection operators, and recyclers. Second, the informal waste sector, which employs an estimated 3.7 million people across Sub-Saharan Africa, must be integrated into formal EPR systems or face displacement, creating both social risk and opportunity. Third, the regulatory fragmentation across 49 countries means that market entry strategy, compliance architecture, and partnership models look fundamentally different from those in Europe or North America.

Key Concepts

Producer Responsibility Organization (PRO): An entity established by producers to collectively fulfill EPR obligations, typically by organizing and financing collection, sorting, and recycling. In Sub-Saharan Africa, PROs often must build physical infrastructure simultaneously with compliance systems, unlike European PROs that inherited decades of municipal collection capacity.

Informal Waste Sector Integration: The process of incorporating informal waste pickers and aggregators into formal EPR collection chains. Sub-Saharan Africa's informal sector recovers an estimated 50 to 80% of all recycled materials in major cities, making integration a practical necessity rather than a social add-on.

EPR Fee Modulation: The practice of varying EPR fees based on product recyclability, recycled content, or environmental impact. Most Sub-Saharan African EPR schemes have not yet implemented fee modulation due to limited data on material flows and recycling economics.

Transboundary Material Flows: The movement of waste materials and recyclables across national borders for processing. Sub-Saharan Africa's limited domestic recycling capacity means significant volumes of collected materials are exported to South and Southeast Asia for processing, creating dependency on global commodity markets.

What's Working

South Africa's EPR system, despite implementation challenges, has demonstrated that mandatory EPR can function in an African context. The paper and packaging sector achieved a 63.5% recovery rate for paper products in 2024, driven by well-established PROs including PETCO (PET plastics), Polyco (polyolefins), and The Glass Recycling Company. PETCO alone facilitated the collection of 136,760 tonnes of post-consumer PET bottles in 2024, supporting a recycling rate of 68% for PET, which exceeds rates in several European countries (PETCO, 2025). The success of PET recycling in South Africa stems partly from the economic viability of bottle-to-bottle recycling and partly from PETCO's deliberate strategy of integrating informal collectors into its supply chain, paying market rates and providing PPE, training, and access to buy-back centers.

Rwanda has taken a different but effective approach through its 2019 ban on single-use plastics, which, while not a traditional EPR framework, functions as an upstream producer restriction that has eliminated a major waste stream. Kigali's streets are visibly cleaner than comparable African capitals, and the country's waste management costs for plastic cleanup have dropped by an estimated 40% since the ban's enforcement tightened in 2021 (Rwanda Environment Management Authority, 2025). Rwanda is now developing a formal EPR framework for electronics and packaging that builds on the institutional capacity created by the plastics ban enforcement infrastructure.

Kenya's 2020 EPR regulations under the Sustainable Waste Management Act have catalyzed private sector investment in collection and recycling infrastructure. The Kenya Extended Producer Responsibility Organization (KEPRO), launched in 2022, has signed agreements with 73 brand owners and importers covering approximately 60% of packaged goods sold in the Kenyan market. KEPRO's model uses mobile money payment systems to compensate informal collectors per kilogram of material delivered to aggregation points, achieving collection costs 30 to 45% lower than traditional formal-sector collection models (KEPRO, 2025).

What's Not Working

The most significant challenge across Sub-Saharan African EPR systems is enforcement. South Africa's Department of Forestry, Fisheries and the Environment (DFFE) has registered over 32,000 producers and importers under EPR regulations, but compliance audits conducted in 2024 found that only 54% of registered entities were making required financial contributions to PROs. Free-rider producers, who benefit from competitors' EPR-funded collection systems without contributing, undermine the financial viability of the entire system. The DFFE's enforcement capacity is limited to 23 full-time compliance officers for the entire country, compared to hundreds in equivalent European regulatory bodies (DFFE, 2025).

Infrastructure gaps persist as a binding constraint. EPR regulations assume the existence of collection, sorting, and processing infrastructure that simply does not exist in most Sub-Saharan African countries. Nigeria, the region's largest economy and waste generator, has drafted EPR regulations since 2019 but has not enacted them, partly because policymakers recognize that mandating producer fees without functioning collection and recycling systems would generate revenue with nowhere productive to deploy it. The country has fewer than 15 materials recovery facilities operating at commercial scale, serving a population of 223 million (Federal Ministry of Environment, 2025).

Data quality is another critical weakness. Effective EPR requires accurate measurement of products placed on market, collection volumes, recycling yields, and material flows. Most Sub-Saharan African countries lack the statistical infrastructure to generate this data. South Africa's PROs report collection volumes, but reconciling these against products placed on market remains imprecise because import data from customs authorities, production data from manufacturers, and informal cross-border trade volumes cannot be reliably integrated. Without accurate denominator data (products placed on market), recycling rate calculations carry uncertainty ranges of 10 to 20 percentage points.

The economics of recycling in Sub-Saharan Africa differ fundamentally from Europe. Virgin material costs are often lower than recycled material costs because import tariffs on virgin plastics and packaging materials are low, while recycled materials face additional processing costs, quality variability, and logistical challenges. Glass recycling in Nigeria, for example, is economically unviable at current scale because virgin glass cullet imported from Asia costs less than locally collected and processed cullet, once transport from collection points to the two operational glass furnaces in Lagos is factored in.

Key Players

Established Organizations

PETCO South Africa: The PET plastic PRO that has operated since 2004 and serves as the benchmark for successful EPR implementation in Africa, with a network of 58,000 informal collectors feeding into 27 recycling facilities.

Plastics SA: The industry body representing South Africa's plastics value chain, operating the Plastics Pact and coordinating industry EPR compliance across multiple polymer types.

African Development Bank: Provides concessional financing for waste management infrastructure, including a $250 million urban waste management facility supporting EPR system development across West and East Africa.

KEPRO (Kenya Extended Producer Responsibility Organization): The multi-material PRO coordinating producer compliance in Kenya, notable for its mobile-money-based collector payment system.

Startups and Innovators

Mr. Green Africa (Kenya): A certified B Corp operating materials recovery facilities in Nairobi that processes 3,000 tonnes of plastic waste monthly, providing traceable recycled feedstock to multinational brand owners and integrating over 2,500 informal collectors into formal supply chains.

WeCyclers (Nigeria): A Lagos-based social enterprise using cargo bicycles and mobile technology to collect recyclables from households, compensating participants with redeemable points. WeCyclers has collected over 8,000 tonnes of recyclables and registered 50,000 households.

The Recycler (Ghana): Operates Accra's largest integrated materials recovery facility, processing PET, HDPE, and cardboard with a focus on export-grade bale quality for international markets.

TakaTaka Solutions (Kenya): A vertically integrated waste management company in Nairobi processing 70 tonnes per day, achieving 95% diversion from landfill through composting, recycling, and refuse-derived fuel production.

Investors and Funders

Circulate Capital: An investment management firm focused on preventing ocean plastic, with active investments in African collection and recycling infrastructure totaling $35 million across three Sub-Saharan African markets.

Global Environment Facility (GEF): Provides grant funding for EPR policy development and pilot implementation, supporting regulatory framework design in Ghana, Nigeria, and Tanzania.

DOB Equity (Netherlands/East Africa): A private equity firm investing in waste management and recycling enterprises across East Africa, with a portfolio of five companies processing over 15,000 tonnes of recyclables annually.

KPI Benchmarks

Metric	South Africa	Kenya	Sub-Saharan Africa Average	EU Average
Formal waste collection rate	64%	45%	44%	96%
PET recycling rate	68%	12%	8-15%	52%
EPR fee per tonne (packaging)	$45-80	$25-50	$15-60	$150-400
Informal sector share of collection	60-80%	70-85%	50-90%	5-15%
PRO operational cost ratio	35-45%	40-55%	N/A	15-25%
Producer compliance rate	54%	38%	20-40%	85-95%

Action Checklist

• Map the regulatory status of EPR across target markets: enacted (South Africa, Kenya, Rwanda), drafted (Nigeria, Ghana, Tanzania), or absent (most others)
• Assess informal sector dynamics in target cities, including collector density, material flows, existing aggregation networks, and prevailing buyback prices
• Evaluate PRO licensing requirements and fee structures, noting that most Sub-Saharan African EPR systems allow multiple competing PROs rather than monopoly models
• Model recycling economics using local cost structures, not European or North American benchmarks, accounting for lower labor costs but higher logistics and energy costs
• Identify export dependency risk by mapping where collected materials are processed and the commodity price sensitivity of those export markets
• Engage with municipal governments early, as collection franchise agreements and landfill access are typically controlled at the municipal level regardless of national EPR frameworks
• Build informal sector integration into business models from day one, both for operational efficiency and to meet emerging social safeguard requirements from development finance institutions

FAQ

Q: Which Sub-Saharan African countries have mandatory EPR regulations in force? A: As of early 2026, South Africa has the most comprehensive mandatory EPR framework, covering packaging, paper, e-waste, and lighting products under the 2020 Extended Producer Responsibility Regulations. Kenya enacted EPR regulations in 2020 under the Sustainable Waste Management Act. Rwanda has upstream product bans functioning as de facto EPR and is developing formal EPR regulations. Ghana, Nigeria, and Tanzania have draft EPR frameworks in various stages of consultation. The East African Community is also developing harmonized EPR guidelines that could cover Kenya, Uganda, Tanzania, Rwanda, Burundi, South Sudan, and the Democratic Republic of Congo.

Q: How does the informal waste sector affect EPR system design in Africa? A: The informal sector is not peripheral but central to EPR implementation in Sub-Saharan Africa. Informal collectors and aggregators recover 50 to 90% of all recycled materials in most African cities, operating at costs 40 to 60% below formal collection systems. Any EPR scheme that attempts to bypass the informal sector will face higher costs and lower collection rates. Successful models, including PETCO in South Africa and KEPRO in Kenya, integrate informal collectors as contracted service providers with guaranteed buyback prices, access to collection equipment, and social protections. The International Labour Organization estimates that formalizing informal waste workers increases their average income by 30 to 50% while improving material recovery quality and traceability.

Q: What return profiles should investors expect from EPR-linked businesses in Sub-Saharan Africa? A: EPR-linked businesses in Sub-Saharan Africa generally offer lower margins but higher growth trajectories than comparable European businesses. PRO management and compliance services typically operate at 8 to 15% net margins. Collection and aggregation businesses operate at 5 to 12% margins, heavily dependent on commodity prices for recyclables. Recycling and processing businesses can achieve 15 to 25% margins for materials with strong end markets (PET, HDPE, cardboard) but face margin compression for lower-value streams (mixed plastics, glass). Development finance institution co-investment, concessional debt, and carbon credit revenues can improve blended returns by 3 to 8 percentage points. Typical investment horizons are 7 to 10 years given the infrastructure build-out required.

Q: What are the biggest risks for EPR investments in the region? A: The primary risks include regulatory reversal or non-enforcement (EPR regulations may be enacted but poorly enforced, undermining revenue certainty for PROs), currency depreciation (most recyclable commodity prices are denominated in USD while operating costs are in local currencies), infrastructure gaps (inadequate roads, electricity, and water access at recycling facilities in secondary cities), and political economy dynamics (incumbent waste management operators and informal sector leaders may resist formalization). Mitigants include structuring contracts with EPR fees denominated in hard currency equivalents, investing in off-grid energy at processing facilities, and building relationships with informal sector cooperatives before regulatory mandates create adversarial dynamics.

Sources

• Department of Forestry, Fisheries and the Environment (DFFE). (2025). Extended Producer Responsibility: Annual Compliance and Performance Report 2024. Pretoria: Government of South Africa.
• World Bank. (2024). What a Waste 3.0: A Global Snapshot of Solid Waste Management to 2050, Africa Regional Update. Washington, DC: World Bank Group.
• Lagos Waste Management Authority. (2025). Lagos State Waste Management Budget and Performance Analysis. Lagos: LAWMA.
• PETCO South Africa. (2025). Annual Review 2024: PET Plastic Recycling in South Africa. Johannesburg: PETCO.
• Rwanda Environment Management Authority. (2025). Plastic Ban Impact Assessment: Five-Year Review. Kigali: REMA.
• KEPRO. (2025). Kenya Extended Producer Responsibility Organization: First Operational Report 2022-2024. Nairobi: KEPRO.
• Federal Ministry of Environment, Nigeria. (2025). National Waste Management Infrastructure Assessment. Abuja: FME.
• Global Water Intelligence & Circulate Capital. (2025). Investing in African Waste Infrastructure: Market Sizing and Opportunity Analysis. Oxford: GWI.