Your shampoo compliance map will include:

• Applicable quality requirements
• Required certifications
• Testing requirements
• Labeling rules
• Estimated costs & worked example

How to Use This Report

This report is built to be read in the order the actual export process happens. Section 2 shows you the sequence end to end. Section 3 tells you, for each requirement, whether it’s something you arrange as the exporter or something your Kenyan importer arranges. Sections 4 onward go into the technical detail: standards, testing, labeling, costs, and the mistakes that most commonly cause delays or rejections.

 Start to Finish

Nine phases, in order. The single most consequential decision in this whole sequence happens at Phase 2, n: whether your label copy keeps this product as a general cosmetic (fast KEBS notification) or pushes it into Pharmacy and Poisons Board territory (slow, dossier-based registration)

3.  Responsibility Matrix

Same three tags as Section 2, applied to every individual requirement. Use this to divide the work with your importer before shipment — and to confirm, in writing, who owns the pathway-classification decision.

4.  Match Summary

5.  Why This Category Gets Flagged

The four most common triggers for a compliance hold on hair shampoo shipments:

• Crossing into medicinal-product territory – any therapeutic wording on the label (“treats dandruff,” “prevents hair loss,” “anti-fungal treatment”) pulls the product out of KEBS’s fast notification route and into PPB’s full, dossier-based registration process. This is the single biggest cost and timeline risk in this category, and it’s created entirely by label copy, not by anything that happens at the border.
• Wrong sub-type classification -Baby, Neutralising, Treatment/conditioning, and General purpose each have different pH ranges and minimum fatty matter content. Declaring the wrong sub-type means testing against the wrong row in Table 1.
• Non-compliant or incomplete labelling -(12)twelve mandatory items, several with their own sub-conditions (shelf-life-dependent date rules)
• Failing a pass/fail test rather than a numeric limit -the antimicrobial activity requirement (Section 7) is a straightforward pass or fail, and it’s easy to overlook precisely because it isn’t a number to hit.

Regulatory Agencies Involved

6.  Glossary

7.  Test Parameters

Soap-based hair shampoo must be tested against the following parameters to demonstrate compliance with KS EAS 842-2:2022. Requirements vary by declared sub-type — confirm which of the four columns applies to your product before testing.

Table 1 — Physicochemical & Performance Requirements

Table 2 — Heavy Metal Contaminants (tested per EAS 847-16)

☐  Lead: maximum 20 mg/kg

☐  Arsenic: maximum 2 mg/kg

☐  Mercury: maximum 2 mg/kg

Table 3 — Microbiological Limits

☐  Total viable count: maximum 100 cfu in 0.5 g — for products specifically intended for children under 3, the eye area, or mucous membranes (tested per ISO 6887-1)

☐  Total viable count: maximum 100 cfu in 0.1 g — for all other products (tested per ISO 6887-1)

☐  Pseudomonas aeruginosa: not detectable (tested per ISO 22717)

☐  Staphylococcus aureus: not detectable (tested per ISO 22718)

☐  Candida albicans: not detectable (tested per ISO 18416)

For Pseudomonas aeruginosa, Staphylococcus aureus, and Candida albicans, “not detectable” means not detectable in 0.5 g for products intended for children under 3, the eye area, or mucous membranes, and in 0.1 g for all other products.

8.  Labeling Requirements

☐  Name of the cosmetic product

☐  Type of the cosmetic product

☐  Intended use of the cosmetic product

☐  Instructions of use, where applicable

☐  Net content, given by weight or volume, in the metric system

☐  Name and address of the manufacturer, importer, and/or distributor

☐  Country of origin

☐  Batch number, in code or otherwise

☐  Precautions and warnings, where applicable

☐  Storage condition, where applicable

☐  Date of manufacture, in the form “mm/yyyy”

Expiry / best-before date — shelf-life-dependent rule

☐  Products with a shelf life of 30 months or less: must be marked with an expiry date, and the manufacturer, agent, or importer must ensure the information outlined in Annex A is accessible to the competent authority

☐  Products with a shelf life greater than 30 months: must be marked with a best-before date, with an additional provision from the manufacturer/agent/importer

9.  What Goes Wrong — Common Failure Modes

These are the specific, recurring reasons hair shampoo shipments get held, penalized, or rejected at the Kenyan border. Cross-check each one against your own shipment before you finalize documentation.

10.  Cost Estimate

Worked Example

Below is an illustrative worked calculation for a 20ft container of shampoo with an FOB value of USD 30,000, assuming the general-cosmetic KEBS pathway applies. If your product instead requires PPB registration, treat this total as a floor, not a ceiling — add the PPB fee and expect a materially longer timeline. These figures are estimates for planning purposes only — confirm actual duty and levy rates with a licensed customs agent before finalizing your landed-cost model.

11.  Recommended Next Steps

• Confirm your regulatory pathway before you finalize packaging artwork — a single word on the label can move you from KEBS notification to PPB registration.
• Confirm your importer of record in Kenya — several steps in Section 3 cannot proceed without one.
• Schedule accredited lab testing against the correct Table 1 column for your declared sub-type (Baby / Neutralising / Treatment-conditioning / General purpose).
• Don’t treat the antimicrobial activity test as secondary — it’s pass/fail, and it’s tested and enforced the same as every numeric limit in the standard.
• Review your label copy against Section 8 before your packaging print run, paying particular attention to the mm/yyyy date format and the shelf-life-dependent expiry rule.
• If there’s any doubt about your regulatory pathway, get it confirmed in writing before shipping — reprinting a label is cheap, restarting a registration process mid-shipment is not.

Packaging & Documentation

A Certificate of Conformity is issued following KEBS conformity assessment, with the applied route — document review, document review plus sampling, or full physical inspection — set by a risk assessment carried out on receipt of the request. A shipment with an unsubstantiated hair-loss or regrowth claim, or one arriving without a batch-specific Certificate of Analysis, is routed toward the more intensive end of that scale, since the contractor has no basis for confirming the claim or the batch’s authenticity from documentation alone.