If you are importing goods from China into Kenya, the Certificate of Origin requirement deserves attention before your supplier releases the cargo.

Kenya introduced a broad Certificate of Origin requirement in 2025. Since then, the Finance Bill 2026 proposed removing that requirement, the final Finance Act 2026 introduced a new export-document rule, and different online sources have interpreted the changes in different ways.

For an importer, the practical question is much simpler:

Do you still need a Certificate of Origin for a shipment from China to Kenya, and what documents should you ask your Chinese supplier to prepare?

The safest approach in September 2026 is not to assume that the Certificate of Origin requirement has disappeared.

KRA’s 2025 notice required imported consignments to comply with Section 44A of the Tax Procedures Act. Although the Finance Bill 2026 proposed repealing Section 44A, that repeal was not retained in the final Finance Act according to enacted-law comparisons reviewed for this article. At the same time, the Finance Act 2026 introduced a separate requirement for importers to obtain and retain export documentation from the exporting country. KRA’s current import guidance also continues to list a Certificate of Origin among import-clearance documents.

For a China-to-Kenya shipment, this means document checking should happen before supplier pickup, consolidation, container loading, air departure or express dispatch, rather than after the cargo has already reached Mombasa or Nairobi.

Data Note: This guide reflects official KRA and KEBS information and the Finance Act 2026 position checked in September 2026. Import-document requirements and operational enforcement can change. Shipment-specific requirements should be confirmed with the Kenyan importer and licensed customs clearing agent before departure from China.

Quick Answer: Does Kenya Require a Certificate of Origin for Imports From China?

For practical shipment planning, you should still prepare for a Certificate of Origin unless the Kenyan importer or licensed clearing agent confirms that it is not required for the specific customs entry.

KRA introduced the mandatory Certificate of Origin requirement under Section 44A of the Tax Procedures Act in 2025. It took effect on July 1, 2025, and KRA provided a transition period until September 30, with full enforcement announced from October 1, 2025.

In 2026, the situation became more complicated.

The Finance Bill 2026 proposed repealing Section 44A. However, the proposed repeal was not retained in the final Finance Act 2026. The Act did delete the statutory definition of “certificate of origin”, while Section 44A itself was not removed in the enacted position reviewed for this article.

Separately, from September 1, 2026, Section 23B introduced another obligation requiring importers to obtain and retain an export declaration, export entry, customs export certificate or equivalent customs document evidencing lawful exportation from the exporting country.

These two issues should therefore not be simplified into:

“Kenya no longer needs a COO; just provide the Chinese export declaration.”

There is not enough current official KRA guidance to make that statement safely.

QuestionPractical approach
Should an ordinary China-to-Kenya importer plan for a COO?Yes. Do not assume it has been eliminated without shipment-specific confirmation.
Is a Chinese export declaration now important?Yes. Section 23B introduced a separate export-document requirement from September 1, 2026.
Does an export declaration automatically replace the COO?Do not assume so.
Should this be checked before shipment?Yes, especially before consolidation or cargo departure from China.

For the broader route, shipping-method, cost and customs context, see Shipping from China to Kenya.

What Changed Between 2025 and 2026?

Many importers are confused because search results currently contain two opposite messages:

  • “Certificate of Origin is mandatory for Kenya imports.”
  • “Kenya abolished the Certificate of Origin requirement in 2026.”

The reason is that the Finance Bill 2026 and the final Finance Act 2026 are not the same thing.

The 2025 Certificate of Origin Rule

The Finance Act 2025 inserted Section 44A into the Tax Procedures Act.

Under that provision, the requirement applied broadly to goods imported into Kenya and required a valid Certificate of Origin to be presented as evidence of origin.

KRA subsequently issued an implementation notice confirming:

  • the requirement took effect on July 1, 2025;
  • a transition period ran until September 30, 2025;
  • full compliance was expected from October 1, 2025.

Section 44A stated that a valid certificate should contain information including:

  • exporter name and address;
  • importer name and address;
  • port of origin;
  • accurate goods description;
  • quantity;
  • country of origin;
  • country of destination.

What the Finance Bill 2026 Proposed

The Finance Bill 2026 proposed repealing Section 44A.

Had that proposal passed unchanged, the blanket Tax Procedures Act requirement for a COO would have disappeared.

This is the source of many articles and summaries saying that Kenya “removed” its Certificate of Origin requirement.

But a Bill is a proposal, not the final law.

What Happened in the Final Finance Act 2026

The final Finance Act 2026 did not retain the proposed repeal of Section 44A according to enacted-law comparisons reviewed for this article.

The enacted Act does, however, delete the definition of “certificate of origin” from Section 3 of the Tax Procedures Act.

That creates an important distinction for importers:

Do not make shipping decisions based only on articles discussing the Finance Bill.

KRA’s current import information also continues to list a Certificate of Origin among documentation used for imported-goods clearance.

A New Export-Document Requirement Started on September 1, 2026

The Finance Act 2026 also inserted Section 23B into the Tax Procedures Act.

From September 1, 2026, a person importing or claiming to have imported goods into Kenya must obtain and retain an:

  • export declaration;
  • export entry;
  • customs export certificate; or
  • other qualifying customs document

from the exporting country as evidence that the goods were lawfully exported.

KRA tells importers to retain the relevant records for at least five years and produce them when requested.

A useful way to understand the timeline is:

DateChangeWhat importers should understand
July 1, 2025Section 44A took effectGeneral COO requirement introduced
September 30, 2025Transition period endedImporters were expected to complete compliance adjustments
October 1, 2025KRA announced full enforcementCOO became a major pre-shipment document check
2026 Finance BillProposed repeal of Section 44AProposal generated many “COO removed” reports
July 1, 2026Most Finance Act 2026 provisions commencedFinal Act must be distinguished from the earlier Bill
September 1, 2026Section 23B became effectiveExport-document retention requirement added

The operational takeaway is simple:

Treat the COO and the new export documentation as separate checks until your Kenyan clearing agent confirms otherwise for the specific shipment.

What Documents Should You Prepare for a China-to-Kenya Shipment?

A Certificate of Origin should not be reviewed in isolation.

For China-to-Kenya freight, the exporter, importer, forwarder and clearing agent should build the document set around the actual transaction.

1. Certificate of Origin

The Certificate of Origin is evidence concerning where the goods originate.

For shipments covered by the Section 44A requirement, the certificate should be issued through a competent authority in the exporting country and should contain sufficient information to identify the exporter, importer and cargo. KRA’s 2025 notice specifically refers to a COO issued by a competent authority in the country of export.

If your supplier says:

“The commercial invoice says Made in China, so you do not need a COO.”

do not accept that assumption without checking with the Kenyan clearing agent.

A commercial invoice and a Certificate of Origin serve different purposes.

2. Export Declaration or Equivalent Customs Export Document

From September 1, 2026, the Kenyan importer also needs to consider the Section 23B requirement.

KRA currently advises importers to request export documentation from their suppliers and ensure that it contains information covering the exporter, importer, goods, quantity, value, tariff classification and country of export.

Section 23B requires the importer to retain the export declaration and supporting records for five years and produce them when requested by KRA.

This makes the Chinese exporter-of-record structure more important than before.

For example, the factory producing the goods may not always be the company appearing on the China export declaration. A trading company, export agent or another authorized exporter may handle the export formalities.

That structure should be identified before shipping.

Country of Origin and Country of Export Are Not Always the Same

This distinction is useful when reviewing documents.

Country of origin generally relates to where the goods originate under the applicable origin rules.

Country of export is the country from which the goods are exported.

For a straightforward shipment manufactured and exported from China, both may point to China.

But not every international transaction is that simple.

A shipment can involve:

  • goods manufactured in another country but exported through China;
  • a Chinese trading company selling products from several manufacturers;
  • re-export arrangements;
  • multiple suppliers consolidated under one export process.

Do not assume that one document proving lawful export automatically proves every origin issue required for the Kenyan customs entry.

China export documents and shipping paperwork reviewed before cargo is sent to Kenya

What If the Certificate of Origin Is Not Available?

KRA’s September 2025 implementation notice provided provisional measures for exceptional situations where a Certificate of Origin was unavailable.

Subject to Customs verification and approval, KRA said the following could be considered:

  • an origin declaration containing origin details;
  • an export permit or licence;
  • a customs export declaration;
  • PVoC documentation issued through authorized KEBS-appointed agents.

The important words are “subject to verification and approval by Customs.”

These documents should not be presented as permanent, guaranteed alternatives to a Certificate of Origin.

A common mistake would be to tell the supplier:

“Just send your export declaration because KRA accepts it instead of the COO.”

That goes further than KRA’s published 2025 wording.

For a current 2026 shipment, confirm the treatment with the Kenyan clearing agent before relying on a provisional document.

Who Is Responsible for the COO and Export Documents?

The easiest way to avoid documentation problems is to separate responsibilities clearly.

Chinese Supplier or Exporter

The exporter in China should normally help prepare and coordinate the China-side export documentation.

Before dispatch, the supplier or exporter should:

  • confirm which legal entity will export the goods;
  • coordinate the required Certificate of Origin where applicable;
  • provide the required export declaration or export record;
  • provide an accurate commercial invoice;
  • provide an accurate packing list;
  • use consistent product descriptions;
  • confirm quantities and shipment values;
  • provide supporting product documents where required.

KRA has specifically advised importers to work with suppliers on required documentation.

Kenyan Importer

The Kenyan importer should not assume that the supplier or freight forwarder carries all regulatory responsibility.

Under the new Section 23B requirement, the importer must obtain and retain the prescribed export documentation and produce it to KRA when requested.

The importer should therefore:

  • confirm import requirements before purchase or shipment;
  • provide accurate consignee and importer information;
  • appoint a licensed Kenyan clearing agent;
  • review HS classification;
  • check whether KEBS or another regulator applies;
  • retain export documents;
  • resolve discrepancies before cargo arrives.

Kenyan Customs Clearing Agent

KRA states that clearance of imported goods normally requires engagement of a licensed customs clearing agent.

The clearing agent can help review:

  • the intended customs entry;
  • exporter and importer details;
  • product description;
  • HS classification;
  • COO;
  • export documents;
  • invoice;
  • packing list;
  • CoC where applicable;
  • permits or licences.

For questionable document structures, this review should happen before departure, not after the container reaches Mombasa.

Freight Forwarder in China

A freight forwarder can coordinate the logistics and help identify document gaps, but the forwarder should not be confused with the government or regulatory authority issuing official certificates.

For example, Winsail can coordinate with suppliers during pickup, consolidation and booking, but the actual regulatory documentation still depends on the exporter, importer and relevant issuing or regulatory authorities.

Pro Tip: When several Chinese suppliers are consolidated into one shipment, create a document matrix before the goods reach the consolidation warehouse. Record the supplier, invoice, exporter, HS code, COO status, export-document status and CoC status for each cargo line.

How the COO Fits With Other Kenya Import Documents

A compliant Certificate of Origin will not solve every customs-document problem.

KRA’s current import guidance lists several documents that may form part of an import file, including commercial invoices, packing lists, Bills of Lading or Air Waybills, Certificates of Origin, Certificates of Conformity for regulated products and relevant permits or licences.

For a shipment from China, think of the documents as one connected set.

DocumentMain purposeWhat to check
Certificate of OriginSupports origin informationExporter, importer, cargo and origin data
Export declaration / export recordEvidence of lawful export from ChinaExporter, importer, value, goods and tariff information
Commercial invoiceCommercial transaction and customs-value supportSeller or buyer, description, value, currency
Packing listPhysical cargo detailsPackages, quantities, weight, dimensions
Bill of Lading / Air WaybillTransport documentShipper, consignee, cargo description and routing
Certificate of ConformityProduct conformity where applicableCorrect product, shipment and applicant details
Permit / licenceProduct-specific regulatory approvalValidity and shipment coverage
Customs entryKenya import declarationClassification, value and importer details

The goal is not necessarily to make every field word-for-word identical.

The goal is to prevent material contradictions.

Watch for These Mismatches

Pay particular attention to:

  • importer names that differ between documents;
  • different exporter companies appearing without explanation;
  • generic descriptions such as “parts” or “equipment”;
  • different quantities or package counts;
  • incorrect origin information;
  • inconsistent invoice references;
  • questionable HS classifications;
  • different product models between the invoice and conformity documents.

For LCL consolidation, check this before warehouse cutoff.

For air freight and express shipments, the document-review window can be even shorter because the cargo may arrive in Kenya quickly. For mode-specific planning, see Air Freight from China to Kenya.

Certificate of Origin ≠ Certificate of Conformity

This is one of the most important distinctions for Kenya imports.

A Certificate of Origin and a Certificate of Conformity are not the same document.

They answer different questions.

Certificate of Origin (COO)Certificate of Conformity (CoC)
Main purposeSupports the origin of goodsSupports conformity with applicable Kenyan standards
Main Kenya authority relevant hereKRA / Customs frameworkKEBS
What it tells authoritiesWhere the goods originateWhether regulated goods comply with applicable requirements
China-side party involvedExporter and relevant competent issuing authorityExporter plus appointed PVoC contractor where applicable
Can one automatically replace the other?NoNo

KEBS describes Pre-Export Verification of Conformity, or PVoC, as a conformity-assessment program applied in exporting countries to check products against applicable Kenyan technical regulations, mandatory standards or approved specifications.

For products subject to PVoC, KEBS states that exporters should ensure compliance with the applicable requirements and obtain the necessary Certificate of Conformity through an appointed PVoC agent before shipment.

Why Do People Confuse COO and CoC?

Both documents can appear in the same import file.

Both may be arranged before goods leave China.

Both may contain exporter, product and shipment information.

But their regulatory purposes remain different.

A COO answers an origin question.

A CoC answers a product conformity question.

KRA’s 2025 transitional guidance did state that PVoC documentation could be considered in exceptional cases when a COO was unavailable, subject to Customs verification and approval.

That did not make a CoC legally identical to a Certificate of Origin.

If your product is subject to KEBS or PVoC, you may need to consider both requirements separately.

Certificate of Origin and Certificate of Conformity documents for Kenya imports shown as separate compliance requirements

Are There Exceptions to the Kenya Certificate of Origin Requirement?

KRA’s September 2025 implementation notice identified several categories that may be exempt from mandatory COO submission.

The published list included:

  • qualifying imports by privileged persons and institutions;
  • used goods, including used motor vehicles;
  • personal baggage;
  • personal effects;
  • mailbags and postal parcels;
  • human remains;
  • samples of no commercial value;
  • temporary imports;
  • certain small packages of prescribed medicines;
  • qualifying individual packages imported through registered couriers.

However, do not use this list as an automatic exemption checklist for every 2026 shipment.

The notice was published as part of the 2025 implementation of Section 44A, while Kenya’s import-document framework has since been modified by the Finance Act 2026.

If you intend to rely on an exemption, confirm that it still applies to the exact shipment.

What About Samples From China?

If you are shipping product samples, confirm whether they genuinely meet the applicable definition and conditions for samples of no commercial value.

Do not simply write “sample” on a commercial shipment to avoid documentation.

What About Courier and Express Shipments?

The 2025 KRA notice included certain qualifying courier packages among possible exemptions, but conditions relating to package type, weight or value may matter.

For commercial express cargo, confirm the current treatment with the courier and Kenyan clearing side rather than assuming all courier shipments are automatically exempt.

Dangerous Goods, Batteries and Project Cargo

Dangerous goods, lithium batteries, chemicals, oversized machinery and project cargo can require additional transport or regulatory documentation.

Being dangerous or oversized does not by itself mean that the cargo is exempt from origin or export-document requirements.

These shipments should be checked separately for both:

  1. Kenya import compliance
  2. Carrier and transport acceptance requirements

Common Certificate of Origin Mistakes for China-to-Kenya Shipments

Most documentation problems are easier to correct while the cargo is still in China.

Here are some of the most common mistakes to avoid.

1. Assuming “Made in China” on the Invoice Is Enough

A commercial invoice is not automatically a substitute for an official origin document.

Ask what the Kenyan entry actually requires.

2. Confusing COO With KEBS CoC

A Certificate of Origin supports origin information.

A Certificate of Conformity deals with compliance with Kenyan standards for applicable goods.

Do not request one when you actually need the other.

3. Reading a Finance Bill Article as Final Law

This is particularly relevant in 2026.

The Finance Bill proposed repealing Section 44A. The final enacted position was different. Always distinguish proposed legislation from enacted legislation and current KRA implementation.

4. Assuming the New Export Declaration Automatically Replaces the COO

Section 23B introduced an export-document obligation from September 1, 2026.

Do not automatically treat it as a complete replacement for every COO obligation unless that treatment is confirmed for the shipment.

5. Checking Documents Only After Cargo Reaches Kenya

Once a container has arrived at Mombasa, correcting China-side export documentation can be more complicated than correcting it before departure.

The same principle applies to air freight arriving in Nairobi.

Review the documents before shipment.

6. Ignoring the Actual Chinese Exporter

Suppose a Kenyan importer buys machinery directly from Factory A, but Trading Company B handles the export declaration.

The factory name, seller name and exporter-of-record information may therefore not be identical.

That does not automatically mean the shipment is invalid, but the structure should be understood and reviewed before departure.

7. Using Vague Cargo Descriptions

Descriptions such as:

  • spare parts;
  • accessories;
  • equipment;
  • samples;
  • machinery

may be too broad when used without enough product information.

Use commercially accurate descriptions that allow the cargo to be identified consistently across the document set.

8. Losing the Export Documentation After Clearance

Section 23B is not simply about showing a document at the time of shipping.

KRA states that the relevant export documentation should be retained for five years and produced when requested.

Keep the records even after the cargo is delivered.

Pre-Shipment Checklist for Imports From China to Kenya

Before your supplier sends the cargo to the forwarder’s warehouse or loads it for export, work through this checklist.

Importer Details

  • Confirm the legal Kenyan importer.
  • Confirm the importer name and address.
  • Confirm the consignee details.
  • Appoint or consult the licensed Kenyan clearing agent.

Supplier and Exporter Details

  • Confirm the Chinese supplier.
  • Confirm which company will appear as exporter.
  • Identify any trading company or export agent involved.
  • Check whether multiple suppliers are being consolidated.

Origin and Export Documents

  • Confirm whether a Certificate of Origin is required for the entry.
  • Request the COO early where applicable.
  • Request the China export declaration or other acceptable export documentation.
  • Check exporter and importer information.
  • Check goods description.
  • Check quantity and value information.
  • Check tariff or HS classification information where shown.

Commercial Documents

  • Prepare the commercial invoice.
  • Prepare the packing list.
  • Confirm Incoterm.
  • Confirm cargo value and currency.
  • Check package count.
  • Check gross and net weight where applicable.

Kenya Compliance

  • Review HS classification.
  • Check whether KEBS or PVoC applies.
  • Obtain a CoC where required.
  • Check whether another Kenyan regulator requires a permit or approval.
  • For ocean freight, check other pre-arrival documentation applicable to the shipment.
  • For dangerous goods, check carrier and regulatory documentation.

Before Departure

  • Send draft documents to the Kenyan clearing agent.
  • Resolve exporter-name discrepancies.
  • Resolve product-description discrepancies.
  • Check documentation for every supplier in a consolidated shipment.
  • Do not assume DDP or door-to-door shipping removes Kenyan regulatory requirements.

Pro Tip: The best time to discover a missing COO, incorrect exporter, inconsistent cargo description or missing CoC is while the goods are still in China. Pre-shipment document review is normally much easier than trying to reconstruct the file after the vessel or aircraft has departed.

Does DDP Shipping Remove the Certificate of Origin Requirement?

No Incoterm should be treated as an exemption from government import requirements.

DDP determines contractual responsibilities between buyer and seller, but it does not automatically remove requirements imposed by KRA, KEBS or another Kenyan authority.

If a supplier or logistics company offers “DDP to Nairobi” or “all-inclusive door-to-door shipping”, ask:

  • Who is the importer?
  • Who handles the customs entry?
  • What documents will be used?
  • How will origin be supported?
  • Who retains the Section 23B export documentation?
  • Does the cargo require a CoC or other regulatory approval?

A low door-to-door price does not answer these questions.

For commercial imports, document transparency matters.

Importing From Multiple Suppliers? Control the Documents Before Consolidation

Multi-supplier consolidation is common for Kenyan importers buying from Guangzhou, Shenzhen, Foshan, Yiwu or several other Chinese manufacturing areas.

It can reduce shipping complexity, but it also creates more document relationships.

For example:

  • Supplier A produces furniture.
  • Supplier B supplies lighting.
  • Supplier C supplies electrical accessories.
  • A separate export company handles the China customs declaration.
  • All cargo is consolidated into one LCL or FCL shipment.

Before loading, create a simple control sheet:

SupplierCommercial invoiceActual exporterHS code checkedCOO statusExport documentCoC / compliance
Supplier A✓ConfirmConfirmConfirmConfirmCheck
Supplier B✓ConfirmConfirmConfirmConfirmCheck
Supplier C✓ConfirmConfirmConfirmConfirmCheck

This is much more reliable than collecting documents from several suppliers after the container has already sailed.

For consolidated shipments from China to Kenya, the freight plan and documentation plan should be built together.

FAQ

Is a Certificate of Origin mandatory for Kenya imports in 2026?

Kenya introduced a general Certificate of Origin requirement under Section 44A in 2025. Although the Finance Bill 2026 proposed repealing Section 44A, the proposed repeal was not retained in the final Finance Act 2026. KRA's current import guidance also continues to list a Certificate of Origin among import documents. Importers should therefore not assume the COO requirement has disappeared without confirming the treatment of the specific customs entry.

Did the Finance Act 2026 abolish Kenya’s Certificate of Origin requirement?

The Finance Bill proposed repealing Section 44A, but that proposed repeal was not retained in the final Act according to enacted-law comparisons. The Finance Act did delete the definition of "certificate of origin" from the Tax Procedures Act and introduced the new Section 23B export-document requirement, which has contributed to conflicting interpretations.

Can a Chinese customs export declaration replace the Certificate of Origin?

Do not assume that it automatically can. KRA's 2025 implementation notice allowed Customs, in exceptional cases and subject to verification and approval, to consider a customs export declaration when a COO was unavailable. Separately, Section 23B now requires importers to obtain and retain export documentation. Neither point guarantees that a China export declaration always replaces a COO.

Who should obtain the Certificate of Origin for goods exported from China?

The China-side exporter or supplier normally needs to coordinate the origin documentation with the appropriate competent issuing authority. The Kenyan importer should identify the requirement early and provide the correct importer and shipment information. A freight forwarder can coordinate document collection but is not the government or competent authority that issues an official origin certificate.

Is a Certificate of Origin the same as a KEBS Certificate of Conformity?

No. A Certificate of Origin relates to where goods originate. A KEBS Certificate of Conformity relates to whether applicable goods conform to Kenyan standards or technical requirements under the PVoC framework. A shipment may need to consider both documents.

Do samples or courier shipments from China need a Certificate of Origin?

KRA's September 2025 implementation notice identified samples of no commercial value and certain qualifying courier packages among categories that may be exempt from the mandatory COO requirement. Because Kenya's documentation framework changed again in 2026, confirm the current treatment before relying on an exemption.

What if the supplier name and Chinese exporter name are different?

This can occur when a factory uses a trading company or export agent to handle the formal export process. Identify the commercial seller, manufacturer, exporter and importer roles, then ask the Kenyan clearing agent to review whether the supporting documents correctly explain the transaction before departure.

Prepare the Documents Before the Cargo Leaves China

For Kenya imports, the Certificate of Origin should be treated as part of a wider document-control process rather than something to request after the shipping booking is finished.

Before supplier pickup or consolidation, confirm:

who is selling the goods → who is exporting them from China → who is importing them into Kenya → which origin and export documents apply → whether KEBS or another regulator applies → whether the Kenyan clearing agent has reviewed the file.

The 2026 Section 23B requirement makes China-side export records even more important, while the current legal and KRA information means importers should not casually assume the earlier COO requirement has disappeared.

For ocean shipments moving through Mombasa, inland cargo moving onward toward Nairobi, and air freight arriving in Nairobi, the same principle applies:

document problems are easier to solve before departure from China than after arrival in Kenya.

If you are still deciding between sea freight, air freight, LCL, FCL or door-to-door arrangements, see Shipping from China to Kenya for the wider route, cost, transit-time and customs planning process. You can also compare the main options in Best Shipping Methods from China to Kenya.

Regulatory Sources

Regulatory Disclaimer: Import documentation, customs interpretation and enforcement practices may change. Confirm shipment-specific requirements with KRA and the licensed Kenyan customs clearing agent before goods leave China.