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Compliance Gap Threatens Market Access for 85% of East African Exporters Eyeing the €2.75B EU Market

Editor’s Note 

This article explores the main barriers to achieving traceability in East Africa and highlights practical recommendations from Koltiva experts to move from risk to readiness. 


Executive Summary 

  • Agriculture remains the backbone of East Africa’s economy, contributing over 32% of regional GDP and employing more than 80% of the population (East African Community, n.d). The European Union absorbs over 60% of East African Community (EAC) coffee exports (SEI, 2024). Yet, with the EU Deforestation Regulation (EUDR) and Corporate Sustainability Due Diligence Directive (CSDDD) coming into effect, more than €2.75 billion in trade value is at risk if compliance gaps persist (Danish Industry Report, 2024).

  • Only 15% of agribusinesses in East Africa are aware of the new EU regulations, with most lacking digital infrastructure and clear guidance for implementation (Danish Industry Report, 2024). Limited internet connectivity, high costs of farm mapping, and fragmented data systems continue to slow progress. Many actors still view traceability as a compliance checkbox, rather than a driver of competitiveness, efficiency, and market trust. 

  • Sustainable compliance requires more than technology—it demands awareness, institutional leadership, and shared responsibility. By adopting digital traceability systems like KoltiTrace MIS, investing in capacity building, and fostering public-private collaboration, East Africa can transform regulatory pressure into economic opportunity. The region stands poised to become a trusted supplier of deforestation-free, transparent, and resilient agricultural commodities. 


East Africa’s economy runs on agriculture. Coffee, cocoa, tea, timber, and other commodities form the backbone of exports, with the European Union as the region’s largest trading partner. In 2021, the EU accounted for over 60% of East Africa Community (EAC) coffee exports, led by Uganda and Ethiopia, followed by Tanzania, Kenya, Rwanda, and Burundi (SEI, 2024). 


Yet, as the EU tightens sustainability and deforestation-free trade rules, most producers remain underprepared. Only a 15% of East African agribusinesses are aware of these evolving regulations, putting €2.75 billions in export value and millions of smallholder livelihoods at risk (Danish Industry Report, 2024). 


Table of Content:


Across the European coffee market, sustainability has become non-negotiable. Consumers, importers, and roasters increasingly demand proof of ethical and deforestation-free sourcing (CBI, 2021), a standard now expanding beyond coffee to cocoa, rubber, palm oil, and timber, under EU Deforestation-free Regulation (EUDR). This shift is reshaping how agricultural products must be verified before reaching EU shelves. 


For East Africa, this creates both urgency and opportunity. Coffee, a major contributor to national GDPs, while in Kenya, it was associated with 50 hectares of annual deforestation from 2015–2018, entirely driven by exports (Dummett & Tenorio, 2023). 


African coffee farmer harvesting cherries on the farm — Koltiva.com

To secure continued access to the EU market, EAC exporters must align with a series of new policies (SEI, 2024): 

  1. The EU Deforestation Regulation (EUDR) — requiring that commodities like cattle, cocoa, coffee, oil palm, rubber, soya and wood are does not contribute to deforestation or forest degradation (Regulation (EU) 2023/1115, 2023). 

  2. The Corporate Sustainability Due Diligence Directive (CSDDD) — obligating large EU-operating firms to identify, prevent, and mitigate human rights and environmental impacts in their supply chains (Procedure 2022/0051/COD, 2022). 

  3. The EU-Kenya Economic Partnership Agreement (2023) — a new generation of EU free trade agreements with trade and sustainability chapters that include specific requirements on climate change and agriculture, as well as the elimination of forced and child labour. 


Coffee market access requirements into the EU - Koltiva.com
Table: Coffee market access requirements into the EU

These regulations redefine the terms of trade. Compliance now demands end-to-end traceability, full transparency on where and how agricultural products are produced. However, despite these growing requirements, awareness and readiness remain critically low. Only a small portion of East African producers and exporters truly understand what traceability entails or how global sustainability laws affect their market access.  


However, lack of awareness is only part of the challenge. The path toward full traceability is hindered by a combination of technical, financial, and systemic constraints, including inadequate digital infrastructure, unclear cost distribution across supply-chain actors, and limited regulatory direction to guide implementation. 


Below, we unpack the key barriers holding back traceability implementation across East Africa’s agricultural sector. 


Key Barriers to Achieving Traceability in Eastern Africa Region 

  1. Low Awareness of Global Regulations and High Risk of Market Exclusion 

    Many agribusinesses and cooperatives across Eastern Africa still lack clarity on what international regulations actually require. Recent surveys indicate that 40% of East African companies report limited or no experience in addressing sustainability and compliance expectations  (Danish Industry Report, 2024). The findings also reveal that:  

    1. 65% of companies need a better understanding of global sustainability rules. 

    2. 57% seek practical support for internal initiatives. 

    3. 52% need access to digital tools and traceability platforms. 

"While some sectors, like coffee and cocoa, have begun adopting traceability measures, most producers are still at the early stage — needing education, guidance, and a clearer understanding of the risks of inaction (including market exclusion and financial penalties),” said Tarsis Katimbo, Business Development Officer for Europe, Middle East & Africa (EMEA) at KOLTIVA 

This lack of awareness has already led to slower export orders and heightened exclusion risks. For instance, the Guardian reported that some Ethiopian coffee exporters are experiencing reduced demand from EU buyers, who risk fines of up to 4% of their turnover for importing non-compliant products. Buyers are becoming increasingly hesitant to place orders due to uncertainty over farmers’ ability to demonstrate compliance (The Guardian, 2024). 


The risk of exclusion is particularly severe for fragmented producer in lower-income countries. Without technical and financial support, east-African smallholders' risk being excluded from EU market, losing access to premium buyers and certification-linked income, if they can't provide verifiable, geo-tagged evidence of deforestation-free origin (Nilepost, 2025).


  1. Smallholders Dominance and Structural Constraints Limiting Traceability Adoption 

    More than 75% of agricultural output in Ethiopia, Kenya, Tanzania, and Uganda is produced by smallholder farmers cultivating an average of just 2.5 hectares (African Development Bank, 2010). While smallholders are the backbone of the region’s economy, this landscape presents significant obstacles for implementing robust traceability. 


    Farms are typically intercropped, geographically dispersed, and governed by informal or undocumented land tenure systems, making boundary verification, geo-mapping, and land-use assessments extremely difficult.  


  2. Highly Fragmented Supply Chains Undermining Data Visibility and Verification 

    A major barrier to traceability in East Africa is the fragmented nature of agricultural supply chains. The movement of goods often involves multiple layers of intermediaries—village collectors, aggregators, traders, processors, and exporters—resulting in weak visibility and inconsistent documentation at the source. 


    Because many agribusinesses source from thousands of smallholders through intermediaries, companies have limited direct engagement with producers. This reduces the ability to collect accurate farm-level data, verify sourcing practices, or ensure compliance with emerging regulations. 


    Research shows that data quality is often determined by the strength of relationships with farmers and whether intermediaries are involved. In Kenya, for example, long chains of traders disrupt direct communication between producers and buyers, making it challenging to implement quality improvements, monitor sustainability practices, or maintain reliable traceability records (Investment in Development Studies, 2018). 


  3. Digital Connectivity Gaps 

    Connectivity black spots remain a major challenge in rural East Africa. Unreliable networks and lack of offline data systems often lead to data loss and gaps in farm monitoring. Many farmers operate in areas without consistent internet access, limiting real-time data collection. Internet penetration in East Africa is hovering around 28,5%, considerably lower than the global average of 67.9% (Statista, 2025).   


    To overcome this, digital platforms need offline-first functionality, allowing data capture in the field that syncs automatically once connectivity is available. This is crucial for scaling traceability across remote agricultural regions. 

“Our KoltiTrace system is built to work in remote, low-connectivity environments through full offline functionality. Field teams can carry out polygon mapping, plot-level risk assessments, supplier screening, and DDS submissions directly on-site. Once a network connection is available, the system syncs with a single user action—uploading, validating, and integrating field data into the central platform. This process helps reduce data-loss risks, minimises duplicate records, and supports both field teams and headquarters in staying updated, even in difficult conditions.,” said Michael Saputra, Head of Data Collection and Climate. 

  1. The Cost Burden 

    Implementing traceability comes with costs. From farmer registration and GPS mapping to platform integration. Although these costs may eventually be reflected in commodity prices, in the short term, they impose a significant financial burden on smallholders, around 80% of whom live below the poverty line  (Regeneration & Co, 2025).


    The key question remains: “Who should bear the cost — and how can it be shared fairly across buyers, producers, and consumers?” 


    In practice, costs are typically distributed across the supply chain: 

    1. Exporters and buyers invest in systems to ensure compliant sourcing. 

    2. Cooperatives and suppliers contribute data and maintenance support. 

    3. Development agencies co-fund baseline mapping and capacity building. 

“The return on this investment comes in the form of risk reduction, compliance assurance, and access to regulated markets. A collaborative funding model, where buyers subsidize onboarding and suppliers maintain data, is the most sustainable approach for long-term traceability implementation,” said Fanny Butler, Sr Head of Markets – EMEA, KOLTIVA. 

One of the EAC region, Kenya, offers a promising example. The government is covering the cost of coffee farm mapping to align with deforestation-free market standards, ensuring continued access to EU buyers that absorb over 60% of its exports (TradeMark Africa, 2025). 


Koltiva’s Recommendations: For East African Companies Who Started The Traceability Journey 

Based on our experience supporting traceability implementation across global supply chains, the path to readiness in East Africa involves three key phases: 


Phase 1 — Build Awareness Across The Entire Supply Chain  

Traceability begins with understanding. Many smallholders, processors, and exporters remain uncertain about what compliance actually means in practice. Companies must invest in education and awareness, ensuring that every actor in their supply chain, from farmers to field officers, understands the regulations, the risks of non-compliance, and the benefits of transparent operations. 


Workshops, digital training, and local-language communication materials are critical first steps in building this foundation. 


Understand what global regulations require, not just the EUDR, but the broader sustainability landscape. Join webinars like KOLTIVA's Beyond Traceability Talks Vol. 4 “Building Supply Chain Traceability and Market Access for East African Exporters" where representative from government and private sectors share practical insights. 


BeyondTraceability Talks webinar “Building Supply Chain Traceability and Market Access for East African Exporters" - Koltiva.com

Gain a clear understanding of what traceability truly means, how to leverage it to strengthen market access, and access a practical checklist to kick-start or enhance your traceability system, featuring insights from leading experts including: 

  • Susan Atyang — Regional Program Manager, Agricultural Business Initiative 

  • Gerald Kyalo — Director Development Services, Uganda Coffee Development Authority (UCDA) 

  • Eliud Kiptoo — Agribusiness Manager, DIAGEO 

  • Waithera Muriithi - Strategy & Innovation Lead, Cafe Africa Uganda 

  • Fanny Butler — Senior Head of Markets EMEA, Koltiva 

  • and will be moderated by Tarsis Katimbo our Business Development Officer. 



Phase 2 — Source-Level Data Assessment

Start with assessing what’s already available. Conduct a quick audit of existing supplier data, farm coordinates, land legality, and yield records. Identify what’s missing and use that to guide your traceability roadmap. 

 

  • Do you have an up-to-date supplier registry with verified farm locations? 

  • Are the supplier and sourcing relationships clearly mapped? 

  • Have you screened your sourcing areas for deforestation risk? 

  • Do your suppliers understand the implications of EUDR? 

  • How is data verified and maintained to ensure accuracy and consistency across the supply chain? 

  • What due diligence system is currently in place to assess and mitigate EUDR risks? 


Phase 3 — Adopt Digital Tools for End-to-End Visibility That Fit Local Conditions 

Choose traceability solutions designed for real-world conditions. Platforms like KoltiTrace MIS are built to capture, store, and sync data even in areas with limited connectivity, ensuring no data is lost between the farm and the buyer. 

“The success of traceability adoption depends on how well digital tools adapt to field realities. In regions where connectivity is still limited, platforms must work offline, be intuitive, and deliver visible value to farmers. That’s when adoption moves from obligation to empowerment,” said Fanny Butler, Sr Head of Markets – EMEA, KOLTIVA. 

 

Fragmented systems often create blind spots. Koltiva recommends adopting integrated digital platforms that connect farmers, suppliers, processors, and exporters within one ecosystem. By centralizing data collection, monitoring, and reporting, businesses can trace every product’s journey, from seed to table, while maintaining interoperability with buyers and regulators. 


Building a Resilient Future for East Africa’s Agriculture

For East Africa, the road to compliance extends beyond technology. True progress depends on building regulatory awareness, strengthening institutional capacity, and ensuring every actor in the supply chain, from smallholder to exporter, plays their part. By investing in traceability and data-driven systems today, the region can secure sustainable market access, safeguard livelihoods, and position itself as a trusted supplier in the global trade of deforestation-free commodities. 


Author: Gusi Ayu Putri Chandrika Sari, Social Media Practitioner at KOLTIVA

Subject Matter Experts: Tarsis Katimbo, Business Development Officer for Europe, Middle East, and Africa (EMEA), Fanny Butler, Sr Head of Markets - EMEA, Michael Saputra, Head of Data Collection and Climate at KOLTIVA


Gusi Ayu Putri Chandrika Sari combines her expertise in digital marketing and social media with a deep commitment to sustainability, supported by over eight years of experience in communications. Her work focuses on crafting impactful narratives that connect technology, agriculture, and environmental responsibility. She is driven by a passion for promoting sustainable practices through compelling, audience-focused content across a variety of digital platforms.


Tarsis Katimbo is a Business Development Officer at Koltiva, where he spearheads growth and engagement across the EMEA region, including Uganda. He brings strategic leadership to Koltiva’s mission of building transparent, sustainable, and inclusive agricultural supply chains.


Fanny Butler is leading the business development and projects in Europe, Middle East and Africa. With 14 years of experience in sustainability for various tropical crops, she oversees project activities, and ensure a pro-active and pragmative approach to implement solutions in the field.


Michael Saputra is the Head of Data Collection and Climate at KOLTIVA, leading initiatives that integrate climate intelligence with robust field data systems across global agricultural supply chains. With expertise in geospatial analysis, environmental monitoring, and digital traceability, Michael ensures that data collected from the ground up—down to the farm plot—supports compliance with sustainability frameworks like the EU Deforestation Regulation (EUDR). His work bridges technology and climate action to empower businesses and smallholders in building resilient, transparent, and deforestation-free supply chains. 


Resources:

  • East African Community. (n.d.). Climate-Smart Agriculture. Retrieved September 31, 2025, from https://www.eac.int/about-eac/63-sector/agriculture-food-security/136-158-159-climate-smart-agriculture

  • Sunguti, E. M., Sitati, C., Kehbila, A., Lutta, A., Suljada, T., & Osano, P. (2024). Climate-smart coffee production in the East African Community and export opportunities to the EU (SEI Report No. 2024.031). Stockholm Environment Institute. https://doi.org/10.51414/sei2024.031

  • Danish Industry & Global Compact Network Kenya. (2024). ESG Study: The effects of EU sustainability regulations in Eastern Africa. Global Compact Network Kenya. https://www.globalcompactkenya.org/sites/default/files/downloads/ESG%20Study_The%20Effects%20of%20EU%20Sustainability%20Regulations%20in%20Eastern%20Africa.pdf

  • Centre for the Promotion of Imports from Developing Countries (CBI). (2024, July 17). What requirements must coffee meet to be allowed on the European market? Retrieved September 31, 2025, from https://www.cbi.eu/market-information/coffee/what-requirements-should-your-product-comply

  • Hatcher, J., & Pendrill, F. (2022). Illegal deforestation for forest-risk agricultural commodities: Dashboard – Kenya. Forest Trends. https://www.forest-trends.org/wp-content/uploads/2022/01/Kenya-FRAC-Dashboard_Final.pdf

  • Mumbere, P. (2025, August 14). EU deforestation regulation compliance deadline sparks fears of market exclusion for African small-scale farmers. Nile Post. https://nilepost.co.ug/business/280409/eu-deforestation-regulation-compliance-deadline-sparks-fears-of-market-exclusion-for-african-small-scale-farmers

  • Regeneration & Co. (2025, July 7). The impact of EUDR on smallholders: Ensuring compliance and inclusion. Regeneration IO. https://www.regeneration.io/mrta-resources/eudr-smallholder-inclusion

  • African Development Bank Group. (2010). Working paper (No. 105). https://www.afdb.org/sites/default/files/documents/publications/working_105_pdf_d.pdf

  • International Development Studies. (n.d.). Small-holder data collection: New evidence on the challenges for agribusinesses in Africa. Institute of Development Studies. https://www.ids.ac.uk/opinions/smallholder-data-collection-new-evidence-on-the-challenges-for-agribusinesses-in-africa/

  • Trademark Africa. (2025). Kenya strengthens traceability to meet deforestation‐free market standards. https://trademarkafrica.com/kenya-strengthens-traceability-to-meet-deforestation-free-market-standards/

  • Statista. (2024). Internet penetration rate in Africa by region (statistic No. 1176668). https://www.statista.com/statistics/1176668/internet-penetration-rate-in-africa-by-region/

  • Harter, F. (2024, April 9). ‘We would not survive without coffee’: How rules made in Europe put Ethiopian farmers at risk. The Guardian. https://www.theguardian.com/global-development/2024/apr/09/coffee-how-rules-made-in-europe-put-ethiopian-farmers-at-risk

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