Manufacturers Association Urges Suspension of NESREA’s Proposed Single-Use Plastics Ban Pending Regulatory Impact Assessment

The Manufacturers Association of Nigeria (MAN) has expressed deep concern over the proposed implementation of the National Environmental (Plastic Waste Control) Regulations 2026 by the National Environmental Standards and Regulations Enforcement Agency (NESREA). The Regulations seek to prohibit the production and use of single-use plastic products below 80 microns in thickness pursuant to Section 26(1), impose taxes on shopping bags with wall thicknesses ranging from 30 to 50 microns under Section 26(2), and restrict a wide range of plastic products listed in the Eleventh Schedule. MAN notes that the proposed measures could significantly disrupt industrial production, undermine investments in the plastics value chain, threaten thousands of direct and indirect jobs, and impose substantial socio-economic costs on manufacturers and consumers alike.

While recognizing the need to address environmental pollution and promote sustainable waste management practices, MAN believes that the proposed regulation is premature, lacks sufficient empirical justification, and poses significant risks to Nigeria’s economy, industrial sector, employment landscape, and the livelihoods of millions of citizens.

NNPAP Plastic Circularity Roadmap

The Association notes that the Federal Government, through the National Plastic Action Partnership (NNPAP), developed a comprehensive Plastic Circularity Roadmap in 2024 in collaboration with the Federal Ministry of Environment. The roadmap provided a strategic framework for achieving plastic waste reduction through enhanced collection systems, recycling infrastructure, Extended Producer Responsibility (EPR), circular economy initiatives, public awareness campaigns, and investments in waste management. Unfortunately, many of the critical recommendations contained in that roadmap are yet to be fully implemented.

It is therefore difficult to understand why the government is proceeding with a new prohibition regime without first evaluating the effectiveness of existing measures and implementing the agreed roadmap designed specifically to address plastic pollution in a sustainable and inclusive manner.

More importantly, there has been no publicly available assessment of the impact of previously restricted single-use plastic products in Nigeria. There is no evidence showing the extent to which earlier bans have reduced environmental pollution, improved waste collection rates, enhanced recycling performance, or changed consumer behavior. Public policy should be driven by evidence, measurable outcomes, and stakeholder consultation rather than assumptions.

International Evidence: A Critical Asymmetry

International experience shows that banning thin plastic bags and other thin plastic products without adequate recycling infrastructure rarely delivers the intended environmental outcomes. Kenya’s 2017 ban led to factory closures and job losses, yet banned bags continue to circulate through smuggling. Bangladesh’s 2002 ban remains largely unenforced after two decades, while South Africa and India experienced only temporary reductions before usage rebounded. By contrast, countries such as Germany, South Korea, and the Netherlands have achieved high recycling rates through Extended Producer Responsibility (EPR) systems without disrupting local industry or increasing the daily cost of living.

A critical lesson from these experiences is the asymmetry of the risks involved.

First, when enforcement weakens, plastic consumption returns. Demand for affordable, lightweight packaging is structural, and thin bags inevitably re-enter the market through informal channels, imports, and cross-border trade. The anticipated environmental gains are therefore short-lived.

Second, the domestic industry does not recover as easily. Closed factories, displaced workers, lost investments, broken supply chains, and abandoned export markets are not automatically restored when policies are relaxed. Kenya’s polybag industry, for example, remains significantly diminished years after the ban, and has left the industry sector uncompetitive.

Third, the country becomes increasingly dependent on imports. Products once manufactured locally are sourced from abroad, consuming scarce foreign exchange while eroding domestic employment, tax revenues, and industrial capacity.

Economic Implications

The proposed ban raises serious concerns regarding its economic implications. Nigeria’s plastic manufacturing industry remains one of the country’s largest and most significant light manufacturing sectors, supporting hundreds of manufacturing facilities, thousands of small and medium enterprises, and an extensive value chain that stretches from petrochemicals and packaging to food processing, pharmaceuticals, retail trade, agriculture, logistics, and recycling.

The implementation of an 80-micron threshold would require substantial changes in manufacturing processes, machinery configurations, and raw material consumption. Such changes could render existing investments obsolete, increase production costs significantly, reduce competitiveness, and expose manufacturers to substantial capital losses.

The consequences extend beyond manufacturers. Increased production costs will inevitably be passed on to consumers, many of whom are already grappling with unprecedented inflationary pressures and declining purchasing power. Small businesses, market traders, food vendors, and informal sector operators who rely heavily on affordable packaging solutions will face additional operational costs, with potentially severe implications for business sustainability and household welfare.

Furthermore, the proposed regulation may inadvertently accelerate deindustrialization by increasing dependence on imported alternatives and imported raw materials. At a time when Nigeria is pursuing industrialization, job creation, import substitution, and export diversification, policies that undermine domestic manufacturing capacity should be carefully reconsidered.

The Association is equally concerned about the potential impact on government revenue. Reduced industrial output, factory closures, declining investments, and job losses would inevitably affect tax revenues, customs duties, value-added tax collections, and other fiscal contributions generated by the manufacturing sector.

Environmental sustainability remains a shared objective. However, international experience has consistently demonstrated that sustainable outcomes are achieved through effective waste management systems, recycling infrastructure, circular economy initiatives, and strong enforcement of anti-littering regulations, not through blanket prohibitions alone.

Plastic pollution is  a waste management challefundamentallynge. The problem lies not in the material itself but in inadequate collection, sorting, recycling, and disposal systems. Addressing these systemic deficiencies should remain the priority of public policy.

The Manufacturers Association of Nigeria, therefore, calls on NESREA and the Federal Government to:

Suspend the implementation of the proposed ban on single-use plastics below 80 microns pending a comprehensive Regulatory Impact Assessment (RIA);

Conduct an independent assessment of the environmental, economic, social, fiscal, and employment implications of the proposed regulation;

Evaluate the outcomes and effectiveness of previously implemented plastic restrictions before introducing additional prohibitions;

Fully implement the recommendations contained in the 2024 NNPAP Plastic Circularity Roadmap.

Strengthen the Extended Producer Responsibility (EPR) framework and accelerate investments in recycling and collection infrastructure;

Establish a broad-based stakeholder working group comprising government agencies, manufacturers, recyclers, academia, consumer groups, environmental organizations, and development partners to develop a practical and evidence-based transition strategy.

Nigeria must pursue environmental sustainability without sacrificing industrial growth, economic competitiveness, employment, and social welfare. Effective regulation should strike a balance between environmental protection and economic development.

The Association remains committed to working collaboratively with government and all stakeholders to advance practical, science-based, and economically sustainable solutions to plastic waste management in Nigeria.

Plastic pollution should be addressed at its source through effective waste management and resource recovery systems. The challenge lies not in the production of plastics, but in the inefficient collection, sorting, recycling, and disposal of post-consumer waste. Sustainable environmental outcomes will be achieved through stronger waste management infrastructure, expanded recycling capacity, enforcement of extended producer responsibility regulation, and greater public awareness, rather than through measures that restrict production without addressing the underlying causes of pollution.

Segun Ajayi-Kadir, mni

Director General,

Manufacturers Association of Nigeria