Nairobi’s waste pickers and the scrap metal they recover

Nairobi’s waste pickers recover metal the formal sector never sees, and the question the country’s first extended producer responsibility rules will settle is whether they are treated as a cost or as a collection network. Kenya’s national monitor has just measured the national stream for the first time, and what it did not measure is how much of that stream the pickers take, because nobody has asked them. The rules arriving in draft will decide who the country counts, and the evidence from the comparable markets is that the countries which count their collectors get numbers and the ones which do not get estimates.

The Kenyan sequence is unusual, and it is the reason the country has a chance to get this decision right. The National E-waste Monitor, published in 2026, estimates the country generated 56,000 tonnes of electronic waste in 2025, more than seven times the level recorded in 2000, which is a measured baseline most of the region does not have. The regulatory side sits behind it in draft: the Environmental Management and Coordination (Extended Producer Responsibility) Regulations drafted in 2021 are described by UN monitors as at an advanced stage of preparation but not yet approved. The WEEE Centre in Nairobi, established in 2012, offers training and disposal services and is the visible formal operator, and household surveys by the ITU and UNITAR found up to 98 per cent of Kenyan households interviewed possessed at least one mobile phone. The equipment base is known, the collector workforce is known, and the legal instrument that joins them is what is still on the table.

The continental statistics say what is at stake in that instrument. Africa documented 25 million kilograms of formal collection against generation of 3.5 billion kilograms, a rate of 0.7 per cent, and the Monitor estimates that 18 billion kilograms of global e-waste is handled in low- and lower-middle-income countries with no developed management infrastructure, mostly by the informal sector, producing around 12 billion US dollars of processed metals. Kenya’s own generation, about 88 million kilograms in 2022 at 1.6 kilograms per person in the international dataset, is a fraction of the continental total, and the recovery work on Nairobi’s dumps is part of the large number that the global report counts without seeing.

Why now is the draft’s timing against the monitor’s finding, and the answer is that the two arrive together for the first time. The country has a sevenfold growth figure over twenty-five years, a formal operator with a decade of training experience, and a draft text whose EPR fee could fund the collection layer the monitoring has just measured, while the world’s documented collection rate is projected to fall to 20 per cent by 2030 and the region’s has been static. Most countries draft such rules without a baseline; Kenya has one, which removes the usual reason for writing a collection rule blind.

The lesson the continental figures carry is what Kenya can avoid, because most countries have drafted extended producer responsibility rules before measuring their streams and produced compliance systems with no tonnage behind them. The three components Kenya already has are rare in combination: a national monitor with a published methodology, a formal operator that has been training for more than a decade, and a collector workforce whose recovery is visible inside the global estimate of 18 billion kilograms handled outside formal infrastructure. Joining them is a clause and a payment mechanism, and the country that does it first produces Africa’s first honest collection figure, worth more in the region’s data than any target a policy document could have assigned to itself.

What should happen is the inclusion clause every comparable system has had to add later and Kenya can add first. The draft rules should define the picker and the informal collector as licence categories, allow the EPR fee to pay per delivered kilogram into licensed aggregation points, and run the collection data into the monitoring methodology the country has already proved it can operate. The WEEE Centre’s training capacity is the obvious place to build the licensing around, and the mobile-phone-heavy equipment mix the surveys found is exactly the material a door-to-door or dump-based collector recovers by hand. A collection target in the regulations that does not reach the people collecting will produce the paper compliance other markets have shown the result to be.

For traders, Kenya’s current position is the region’s position: material in growing quantity, a formal sector measured at continental scale but locally small, and prices set at the point of collection by whoever is buying. The Monitor’s global figures, 91 billion US dollars of metal value in 2022’s e-waste of which documented management realises 28 billion, are the difference between the Kenyan stream’s measured share and its actual size. The National E-waste Monitor Kenya holds the national baseline, the Global E-waste Monitor 2024 holds the regional and global context, and platforms such as scrap.trade trade the documented material as it begins to move through licensed channels.

The waste pickers of Nairobi are the collection network the monitor could count and the draft rules have not yet named. The clause that names them decides whether Kenya’s first EPR system is built on the workforce it has, and the monitor the country just published is the evidence it can use to do so. A collection rate built on its actual collectors is the only version that produces an honest counterpart to the sevenfold growth figure, and the draft that writes them in will be the first in the region to have done it.