Jean Claude Nshimiyimana, a Commercial Lawyer with ENS Rwanda.

Rwanda’s continued commitment to environmental protection has led to the promulgation of Law nº 010/2025 of 27/05/2025 establishing an environmental levy on imported items packaged in plastic materials (the “New Environmental Levy Act”).  This New Environmental Levy Act, published in the Official Gazette on 29/05/2025, comes into force on July 1, 2025, and carries significant implications for businesses involved in importing goods into Rwanda.

Background to the environmental levy

The concept of an environmental levy on imported goods packaged in plastic materials is not entirely new in Rwanda. It was initially introduced by Law n° 17/2019 of 10/08/2019 relating to the prohibition of manufacturing, importation, use and sale of plastic carry bags and single-use plastic items (the “Plasban Act”). Article 5 of Plasban Act subjects imported goods packaged in plastic materials to environmental levy in accordance with relevant laws. However, a critical gap existed, Plasban Act did not provide the necessary modalities for the administration of this environmental levy.

Recognising this administrative gap, the need arose for a specific legal framework to detail how this environmental levy would be applied. The New Environmental Levy Act has been promulgated with the explicit purpose of regulating the rate and base, modalities for its collection and management, and establishing a list of imported items subject to the environmental levy. This New Environmental Levy Act also aims to create a balance and favorable competition between imported and domestically produced goods packaged in plastic material, while supporting medium-term domestic resource mobilisation for national development plans (National Strategy for Transformation (NST2)).

Key Provisions and New Changes in the New Environmental Levy Act

The New Environmental Levy Act provides the specifics that were missing from the Plasban Act, clearly outlining how environmental levy will operate. The New Environmental Levy Act defines the “levy” as a charge applied to imported items packaged in plastic materials, aiming at the management of the resulting waste. “Items” are defined broadly as tangible or intangible property packaged in plastic materials, and “plastic materials” include lightweight, soft, non-compostable materials, such as plastic carry bags, derived from petrochemicals.

Article 3 of the New Environmental Levy Act provides that environmental levy applies to a list of imported items included in an annex, with specific exceptions. The exceptions are for imported items of single use exempted in accordance with the East African Community Customs Management Act (EACCMA), and pharmaceutical products. Particularly, the New Environmental Levy Act includes a provision allowing the Minister of Finance and Economic Planning (MINICOFIN) to expand or narrow down the list of items subject to the environmental levy via a Ministerial Order (Article 3(2) of New Environmental Levy Act). Examples of items included in the initial list provided in the annex to the New Environmental Levy Act are water, all types of juice, energy drinks, carbonated non-alcoholic beverages, clothes, shoes, all types of soap, and toilet papers.

A key detail provided by the New Environmental Levy Act is the rate of the levy. Imported items subject to this New Environmental Levy Act will be subject to an environmental levy of 0.2% calculated on their customs value.

Regarding the administrative modalities, the New Environmental Levy Act clearly states that the levy on imported items packaged in plastic material is collected at the customs point in accordance with the East African Community Customs Management Act. The collected levy is then to be deposited into a sub-account of the Treasury Single Account.

With New Environmental Levy Act taking effect on July 1st, 2025, it is important for all parties involved in importing goods into Rwanda to become familiar with New Environmental Levy Act provisions. Importers of items packaged in plastic materials must understand whether their goods are included in the annexed list and not covered by the specified exemptions.

Businesses should also stay informed about any potential Ministerial Orders that may modify the list of items subject to the environmental levy.

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About the Author

Jean Claude Nshimiyimana is the Corporate and Legal Services Lead at Andersen Rwanda. A member of the Rwanda Bar Association, he excels in advising and representing clients on commercial aspects of Rwandan law, which include trademarks, business structuring, company and NGO registration and de-registration, mergers and acquisition, real estate acquisitions, employment law and data protection and privacy, fintech and regulatory compliance. He is fluent in English, Kinyarwanda, French and Kiswahili and can be reached via +250788921438.

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