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Executive Summary: Study on the Trade and Use of Lead Chromates in Paint in Kenya

Despite Kenya's 90 ppm lead limit for paints, lead chromate pigments continue to be imported in large volumes to produce bright yellow, orange, and red paints. This study exposes the regulatory gap and recommends stronger import controls and a phased shift to safer alternatives

Introduction
Lead is highly toxic. Kenya adopted a 90 ppm lead limit for paints in 2018, but regulatory gaps remain; existing standards do not restrict the import or use of raw lead chromate pigments. These pigments are commonly used to produce bright yellow, orange, and red paints and have been found in both road-marking and residential paints on the Kenyan market.

Methodology
The study combined quantitative analysis of Kenya Revenue Authority (KRA) customs data (2021–2025) and UN Comtrade statistics (2021–2024) with qualitative insights from key informant interviews with paint manufacturers.

Key Findings

  • Kenya imported 983.62 tons of chromium-based pigments between 2021 and 2025, with annual volumes consistently exceeding 160 tons.
  • Imports were concentrated among 18 companies, with six accounting for 80% of total volume.
  • India supplied 98.6% of imports; other sources include China, the USA, Japan, and Portugal.
  • No domestic production of lead chromates was identified.
  • A clear discrepancy emerged: manufacturers reported no longer using lead chromates, yet customs records show continued imports, including by some of the interviewed companies, highlighting the limits of voluntary self-reporting.

Conclusion
Lead chromates remain actively traded in Kenya despite the 90 ppm limit. The findings point to gaps in regulation, import controls, enforcement, and supply chain traceability. Strengthening these frameworks through importer registration, mandatory lead-content controls, and phased restrictions would support the transition to safer alternatives.

Policy Recommendations

  1. Strengthen import controls and market transparency (NEMA and KRA).
  2. Develop regulations under EMCA to restrict lead chromates in paints.
  3. Support listing lead chromates under the Rotterdam Convention's PIC procedure.
  4. Support industry transition to safer alternatives through guidance and incentives.
  5. Promote public awareness and regional cooperation through the EAC.

Download the full Executive Summary (PDF)