Kampala — In mid-December 2025, under the chandeliers of a conference hall in Speke Resort Hotel-Munyonyo, in Kampala, a familiar tension surfaced in unfamiliar language.
Delegates from across Eastern and Southern Africa comprising; policy-makers, economists, civil society actors, farmer group advocates, and trade negotiators, had gathered for a high-level policy dialogue convened by the Southern and Eastern Africa Trade Information and Negotiations Institute (SEATINI), a Kampala-based non-profit that works on trade, fiscal and development-related issues to promote sustainable development and livelihoods across Africa.
The setting was calm, overlooking Lake Victoria but, the discussion which was themed, "Advancing Transformative and Equitable EU-Africa Agricultural Trade Relations," sometimes bordered on the pensive. At the centre of the debate was the European Union's "Green Deal," a sweeping set of climate change, environmental, and sustainability policies that are rapidly reshaping global trade.
To European policymakers in Brussels, the Green Deal represents leadership on climate action. To many African experts in the room, however, it is beginning to look like something else entirely: a new trade wall-built not with tariffs, but with rules, standards, and compliance costs. "Tariffs are no longer the problem," one participant observed quietly during a coffee break. "Compliance is."
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From tariffs to traceability
For decades, Africa-EU trade discussions have revolved around tariffs, quotas, and preferential market access. Today, the vocabulary has changed. The new language of trade is deforestation-free supply chains, carbon footprints, due diligence, geolocation data, traceability systems, and sustainability certification.
These requirements are embedded in EU instruments such as the EU Deforestation Regulation (EUDR), the Corporate Sustainability Due Diligence Directive (CSDDD), the Carbon Border Adjustment Mechanism (CBAM), and the Farm to Fork Strategy. Together, they form the trade-facing edge of the European Green Deal.
The delegates heard that these instruments, when taken together, they will significantly affect African exporters' cost structures and competitiveness over the next 12-24 months. Evidence presented at the two-day dialogue from multiple studies showed that compliance costs will be highly asymmetrical.
Smallholders may be required to spend up to 75% of their annual income on compliance, while larger exporters absorb a much smaller share of their revenue. Awareness levels are alarmingly low: surveys indicate that up to 85% of East African agribusinesses lack substantive knowledge of the new requirements.
Under the EUDR alone, compliance costs include geolocation and satellite verification (€200-500 per year), due diligence documentation (€1,000-5,000 per cycle), and digital traceability systems (€500-1,500). Cumulatively, this can amount to €740-2,000 per smallholder annually, compared to average incomes of €1,000-3,000. These requirements risk creating deep capital and digital asymmetries across African agriculture.
"This is not just an environmental policy," said Vahini Naidu, the Programme Coordinator for Trade for Development at the South Centre in Geneva. "It is a profound restructuring of how market access is governed."
The concern raised repeatedly in Munyonyo was not the principle of sustainability itself. Rather, it was the design, speed, and uneven impact of these measures on African economies that are still dominated by smallholder farmers and traders, informality, and limited fiscal space.
The EU Deforestation Regulation: Protection or exclusion?
No EU directive dominated the discussion more than the EU Deforestation Regulation, which will prohibit the sale of products linked to deforestation or forest degradation on the EU market. The EUDR applies to commodities central to African exports; coffee, cocoa, cattle, timber, palm oil, rubber, and soy-along with derivatives such as chocolate, leather, furniture, and paper. Companies trading in these products must now demonstrate that these products are deforestation-free, legally produced, and traceable to exact geographical coordinates.
Large companies must comply by 30 December 2026. On paper, the objective is hard to dispute. Forest loss is a global crisis. But as Naidu explained, the regulation's compliance architecture tells a more troubling story. "Smallholder farmers are expected to bear costs they simply cannot afford," she said. "Estimates show compliance could consume up to 75% of a smallholder's annual income."
The costs include GPS mapping, satellite verification, digital reporting systems, and legal documentation; requirements that may be manageable for multinational firms, but devastating for farmers earning a few dollars a day.
Farm to Fork: Standards that bite
Beyond deforestation, the EU's Farm to Fork Strategy aims to transform food systems by reducing pesticide use, fertilisers, and antimicrobials, while expanding organic farming. These changes will likely reduce EU agricultural output--creating opportunities for imports. But only for exporters who can meet increasingly stringent sanitary and phytosanitary (SPS) standards.
Testing costs for African exporters range from €200 to €2,000 per shipment. According to data from the United Nations Conference on Trade and Development (UNCTAD) cited during the policy dialogue, African exporters spend up to four times more on Sanitary and Phytosanitary (SPS) compliance than exporters from developed countries. "These measures are already reducing African exports," Naidu noted, citing cases from Nigeria and Cameroon.
CBAM and the carbon question
Perhaps the most contentious instrument is the Carbon Border Adjustment Mechanism (CBAM) which places a carbon price on imports of cement, steel, aluminium, fertilisers, electricity, and hydrogen. From January 2026, African exporters will face real financial charges at the EU border.
"Measurement, reporting and verification systems alone can cost millions," said Edgar Odari, the Executive Director of Eco News Africa, based in Nairobi. "And yet Africa contributes less than 4% of global emissions." Modelling discussed at the dialogue suggested potential export losses of up to 5.7%, with GDP losses reaching €31 billion in worst-case scenarios.
"Why are exemptions quietly extended to powerful economies while Africa is told to adjust?" Odari asked. "This is where climate policy begins to look like protectionism."
When buyers become regulators
Crucially, African farmers are not regulated directly by Brussels. Instead, regulation flows through European buyers, who now face heavy penalties if their supply chains fail to meet EU standards. For example, under the Corporate Sustainability Due Diligence Directive (CSDDD), EU companies can be fined up to 5% of global turnover for environmental or human rights violations anywhere in their supply chains.
"That risk will be pushed downwards," said Rangarirai Machemedze, the Project Coordinator for the Tripartite Simplified Trade Regime at the Southern Africa Development Community (SADC) Secretariat. Machemedze who delivered a paper titled, "Reflections/Perspectives on Promoting Mutually Beneficial, Equitable and Transformative EU-Africa Trade Relations," noted that: "African exporters and producers will be asked to prove compliance in systems that were never designed for our realities."
In many African countries, land tenure is customary rather than formally registered. Production is fragmented. Records are minimal. Expecting instant traceability, Machemedze argued, effectively redefines informality as illegality.
Uganda's coffee at risk
Uganda's experience illustrates the dilemma starkly. Roughly 60% of Uganda's coffee exports go to the EU, making Europe the country's most important market. Cleopas Ndorere, the Commissioner for External Trade at Uganda's Ministry of Trade, Industry and Cooperatives, described the scale of the challenge as enormous.
"Our value chains are long and fragmented," he said. "Traceability means knowing exactly where the coffee came from, who handled it, and whether any land-use rules were violated at any stage."
He said shortening value chains may help compliance but it also risks excluding small traders and consolidating the sector, with social consequences. "If your cow grazed on land classified as deforested," Ndorere added, "then the entire product is disqualified. That is how strict these rules are."
But not all examples discussed were negative. Ghana's cocoa sector in West Africa was frequently cited as a model of proactive adaptation. Through the Ghana Cocoa Traceability System, the government has GPS-mapped tens of thousands of farms, registered farmers digitally, and introduced QR-code tracking. By pooling costs across the public and private sectors, Ghana has dramatically reduced per-farmer compliance burdens.
"This shows what is possible when compliance is treated as a public investment," Naidu said. "But it also shows how much state capacity and financing are required." Most African countries, she warned, do not yet have that capacity.
Old trade patterns, new green rules
Several speakers placed the EU Green Deal in historical context. "Africa's trade relationship with Europe has always been extractive," Machemedze said. "We export raw materials. Europe exports value-added goods."
Speaking virtually from Germany, Francisco Marí, the Policy Advisor for Global Nutrition, Agricultural Trade and Maritime Policy at Bread for the World illustrated the imbalance: Germany exports chocolate worth US$6 billion annually, while importing cocoa beans worth just US$1 billion. "The Green Deal risks locking this structure in place," he warned, "unless Africa is supported to move up the value chain."
"Most of the value is created in European factories, through roasting, rimming, processing, branding and logistics, not in African communities. The same is true for coffee and many fruits and vegetables," he said. "The most profitable steps of the value chain, and thus most jobs and tax revenues, are still located in Europe, while African farmers remain stuck in low-income segments."
The new EU regulations, the Green Deal, the EU Deforestation Regulation and the Corporate Sustainability due Diligence Directive, are changing, however, the framework for agricultural trade with Africa remain the same.
Are these Non-Tariff Barriers?
By classical definition, non-tariff barriers are measures that restrict trade without imposing tariffs. By that definition, many participants argued, the Green Deal qualifies.
"Compliance is the new tariff," Machemedze said. "And geography now determines who can comply." The problem, speakers emphasised, is not standards themselves--but who pays for compliance, how fast rules are imposed, and whether Africa has policy space to adapt.
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The dialogue also highlighted concerns about hypocrisy. Pesticides banned in Europe continue to be exported to Africa. EU agricultural subsidies have been rebranded as "green" without reducing their market-distorting effects. "Green for whom?" Odari asked pointedly.
"We have seen some times where our fruits and vegetables and other products have reached the markets and we're told, you know, this kind of arachnid or herbicide was long banned in EU, so we cannot accept a product where you have used this kind of herbicide," Ndorere said.
"When we go back in our reports, we can barely find that kind of modification having come through so that we can send it down to the people who do the actual production to be aware that moving forward, that kind of maybe chemical is not allowed in the EU market."
"We feel strongly that there's much more we need to work together to make market access a little lighter, because the compliance burden has become even more and more heavier as time moves on."
"One thing I keep wondering in my head is when we talk of standards. I have seen many of our visitors (tourists) come and enjoy our foods and vegetables in a shelter or even on the roadside. And yet, when it comes to sending them to their countries, they say they are not good enough."
Across sessions, calls grew louder for regional coordination. Dr Hoseana Lunogelo of the Tanzanian non-profit, the Economic and Social Research Foundation (ESRF) urged EAC and SADC states to harmonise compliance systems and negotiate collectively. The East African Legislative Assembly (EALA) MPs; Gideon Gatpan and Francine Rutazana echoed the point. "We negotiate individually and lose collectively," Rutazana said. "Europe never negotiates that way."
Compliance as a public good
One of the dialogue's most compelling reframings came from Machemedze. "If compliance determines market access," he said, "then compliance must be treated as a public good." That means public traceability systems, shared databases, subsidized certification, and collective bargaining--especially for smallholders, Machemedze said.
SEATINI Executive Director, Jane Nalunga, offered a measured conclusion. "These are issues we should have addressed long ago," she said. "Sustainability is not the enemy," Nalunga said.
"But without fairness, financing, and flexibility, green rules risk becoming exclusionary. Sustainability must be environmental, social, and economic. Otherwise, it becomes another wall."
So, is the EU Green Deal a genuine partnership--or a new barrier? The answer emerging from Munyonyo was deliberately nuanced. The Green Deal can drive sustainability but only if Europe shares transition costs, respects Africa's development constraints, and avoids imposing one-size-fits-all timelines. Without that, Africa risks facing a familiar future: open rhetoric, closed markets.
