Insights / Regulatory & Compliance

Where to Build: A Legal Guide to Kenya’s Pharmaceutical SEZ Sites

By Clay & Associates Advocates · 5 min read ·

Two African construction workers in blue coveralls standing at a special economic zone development site in Kenya

Kenya markets several pharmaceutical SEZ sites as ready for manufacturing investment, but the sites carry very different legal status and very different evidence of actual pharma tenancy. An investor comparing them needs to separate a gazetted special economic zone with licensed operators from an announcement with no zone status yet, and needs to separate a confirmed pharmaceutical tenant from a single unverified headline claim.

Naivasha: A Confirmed Zone With an Unconfirmed Pharma Claim

The Naivasha Special Economic Zone, developed under the Special Economic Zones Act 2015 and administered by the Special Economic Zones Authority, is an operational, gazetted zone in Mai Mahiu covering a site reported at between 1,000 and 6,000 acres depending on the phase referenced, with 14 to 19 or more licensed investors already operating there. Its zone status is not in question. What is worth flagging directly is a specific pharmaceutical tenancy claim: an August 2026 report referencing a “Biopharma” operation at Naivasha appeared in a single source, as a headline-level mention without independent corroboration in SEZA’s own published tenant lists or a second news outlet. An investor should treat that specific pharma-tenant claim as unconfirmed and verify it directly with SEZA before relying on it as evidence that pharmaceutical manufacturing is already established at the site, while treating the zone’s own legal status and general investor base as solid.

Dongo Kundu: A Confirmed Zone, No Pharma Tenant Identified

The Dongo Kundu Special Economic Zone in Likoni, Mombasa County, developed by the Kenya Ports Authority, is a confirmed zone under construction with a genuine legal and infrastructure basis, positioned to take advantage of port access for an export-oriented manufacturer. No pharmaceutical tenant or pharmaceutical-sector announcement has been identified for this site in available reporting. An investor should not treat Dongo Kundu as a pharmaceutical manufacturing location on the strength of its SEZ status alone; its zone status is real, but its relevance to a life sciences investment specifically has not been established.

Tatu City: Kenya’s First Operational SEZ, With Pharma-Adjacent Tenants Only

Tatu City in Kiambu County was licensed under the 2015 Act as Kenya’s first operational special economic zone and hosts roughly 88 companies, of which around 40 are licensed under the SEZ regime specifically. Its life sciences relevance is real but narrower than a general “pharmaceutical manufacturing hub” label would suggest: the tenants identified are FullCare Medical, a personal protective equipment manufacturer, and Hewa Tele, a medical oxygen producer. Both sit within the health products and technologies space, but neither is classic small-molecule or biologic drug manufacturing. This is also the site originally earmarked for Moderna’s paused mRNA vaccine facility, a plan that has not proceeded since Moderna’s own April 2024 pause statement. An investor evaluating Tatu City for a conventional pharmaceutical manufacturing investment should treat its current life sciences tenancy as adjacent to, rather than squarely within, drug manufacturing, and should not assume the paused Moderna plan signals renewed pharma-specific momentum at the site.

Murang’a: An Announcement, Not Yet a Zone

A December 2025 presidential announcement referenced a prospective pharmaceutical manufacturing project associated with Murang’a County, reportedly connected to Chinese investment. As of this writing, no gazetted SEZ status for a Murang’a site has been identified, and the reported China link has not been independently confirmed beyond the initial announcement. This distinction matters for an investor’s diligence: an announcement is a policy signal, not a legal or operational fact, and Murang’a should be tracked as a site to watch rather than treated as an available, licensed manufacturing location today.

What This Comparison Means for Site Selection

Naivasha and Dongo Kundu offer confirmed SEZ legal status with, respectively, an unconfirmed pharma claim and no pharma tenant at all. Tatu City offers confirmed SEZ status and genuine health-products tenancy, but of a kind adjacent to rather than identical with pharmaceutical drug manufacturing. Murang’a offers neither confirmed zone status nor a corroborated investment commitment. An investor should request current tenant lists and zone-status confirmation directly from SEZA and, where relevant, Tatu City’s own zone operator, rather than relying on secondary reporting or a single announcement to select a site, and should independently verify any specific pharma-tenant claim before it enters an investment thesis.

Legal status also carries different practical consequences at each stage. A gazetted zone under the 2015 Act gives an investor access to the tax and customs incentives that come with SEZ status once a licence is issued, along with a defined regulator to hold accountable for infrastructure and licensing commitments. A site at the announcement stage, by contrast, offers none of that until gazettement actually happens, and an investor negotiating land or incentive terms before gazettement is negotiating against a legal framework that does not yet exist for that site.

How We Can Help

Clay & Associates Advocates advises pharmaceutical and life sciences investors on comparing Kenya’s special economic zone sites against their actual legal status and tenant base before committing to a location. Our guide to choosing between SEZ and EPZ regimes for pharmaceutical manufacturing is a useful companion for the regime-level analysis behind this site comparison. Contact our Life Sciences & Healthcare practice to verify current site status and tenancy before selecting a manufacturing location.

Sources: Special Economic Zones Act 2015; Special Economic Zones Authority (seza.go.ke); Tatu City Special Economic Zone investor materials; Moderna, Statement on Kenya Manufacturing Facility (11 April 2024); press reporting on the Naivasha SEZ “Biopharma” reference (August 2026, single source, unconfirmed); press reporting on the Murang’a pharmaceutical manufacturing announcement (December 2025).

Frequently asked questions

Which Kenyan SEZ site has a confirmed pharmaceutical manufacturing tenant?
None of the sites reviewed has a corroborated classic drug-manufacturing tenant confirmed from more than one source. Tatu City hosts PPE and medical oxygen producers, which sit in the broader health products space but are not conventional pharmaceutical manufacturing.

Is the Naivasha “Biopharma” report reliable enough to act on?
Not on its own. It appeared in a single source without corroboration in SEZA’s own tenant materials or independent news coverage, and should be verified directly with SEZA before being treated as fact.

Is Murang’a available for pharmaceutical investment now?
No gazetted SEZ status has been identified for the Murang’a site as of this writing. It remains at the announcement stage and should not be treated as a licensed, operational zone.

Is Tatu City still the site for Moderna’s mRNA facility?
Moderna’s own April 2024 statement describes that project as paused, and available reporting indicates Moderna never completed acquisition of the parcel. Tatu City’s current life sciences tenants are unrelated to that paused plan.

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Clay & Associates Advocates
This article is general information, not legal advice. For advice on your matter, speak to counsel.

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