Africa's Silence on EU's Anti-Deforestation Law: Can We Afford to Stay Quiet While Malaysia Demands a Megaphone? (Series 1)

Picture this: The EU's shiny new anti-deforestation regulation is about to take center stage, dramatically altering the rules of the global commodity game. Malaysia, with its palm oil warriors, is at the front row, screaming for clarity, demanding exemptions, and perhaps even requesting a bit of applause. Meanwhile, Africa, home to millions of smallholder farmers cultivating coffee, cocoa, and tea, remains eerily silent. Is this a tactical meditation or a dangerous oversight? As the curtain begins to rise on the enforcement date, we can't help but wonder: is Africa about to miss the script entirely in this high-stakes play?

Introduction to the Series

Welcome to a two-part exploration of one of the most significant regulatory shifts affecting Africa's agricultural landscape: the EU Deforestation Regulation (EUDR). The EUDR is poised to become a major determinant of whether African agricultural exports can continue reaching European markets. While the EU has postponed the implementation date to December 2025, there remain numerous unanswered questions about exemptions for smallholder farmers—a concern that resonates deeply with Africa, where agricultural production is largely driven by smallholders.

In this series, we will delve into the details of the EUDR, contrasting Malaysia's proactive approach in negotiating the regulation's terms with Africa's concerning silence. We will examine the implications of this silence for millions of African farmers and explore how Africa can better position itself to ensure that its farmers are not disproportionately affected by these new regulations.

The first article lays the groundwork by exploring the intricacies of the EUDR, examining Malaysia's active lobbying efforts, and highlighting what Africa stands to lose if it continues to remain silent. The second part will then provide actionable recommendations for Africa—a path forward that moves from passivity to proactive advocacy, inspired by Malaysia's example.

Understanding the EU Deforestation Regulation (EUDR)

The EU Deforestation Regulation (EUDR) represents a bold move aimed at cleaning up the supply chain of commodities like coffee, cocoa, soy, palm oil, and rubber. It is part of a broader commitment outlined in the EU's Green Deal and Biodiversity Strategy for 2030, designed to reduce the EU’s environmental footprint. In short, it’s a regulatory whip meant to ensure that only “deforestation-free” products make it onto the shelves of European supermarkets.

But here's where things get interesting—"deforestation-free" sounds simple enough, but the requirements for proving this are anything but straightforward. Under the EUDR, all operators and traders—whether European or non-EU exporters—must prove that their products do not originate from recently deforested land. This involves tracing the entire supply chain, geolocation data, and ensuring compliance with legality requirements. The regulation covers a wide range of commodities, from timber and rubber to cocoa and beef.

Compliance is not just about producing paperwork—it's about transforming how agricultural production is tracked and managed. Companies have to conduct thorough due diligence to prove "negligible risk," a pre-condition for placing products on the EU market. This isn’t just an accounting exercise; it involves geolocation mapping, working through multiple certifications, and maintaining meticulous records—a tall order for any farmer, let alone a smallholder with limited resources and often limited literacy.

Even more challenging is the timeline: large and medium companies have until December 2025 to comply, while small and micro enterprises get an extra six months, until June 2026. The EU Commission acknowledges that stakeholders across Europe and globally are at varying stages of preparedness, which is precisely why it extended the original deadline by a year. Yet, this extension, while beneficial, still puts pressure on smallholder farmers, especially those in Africa, where most commodity production is not streamlined like the industrial-scale operations seen in some Asian countries.

To make it more tangible, let’s imagine a smallholder farmer named Kamau, tending his coffee farm in Kenya. Kamau doesn't have GPS mapping of his land, let alone a direct supply chain link to the EU. Under the new EUDR, Kamau would need to prove, possibly via a series of intermediaries, that his coffee is deforestation-free. In reality, Kamau's coffee may be perfectly sustainable, but without support, the paperwork needed to prove it may never reach the EU’s compliance threshold, effectively barring his product from European markets.

Malaysia's Active Response: A Model for Africa?

Malaysia has not been shy in stepping into the limelight to discuss its concerns about the EUDR. The country’s palm oil sector—a frequent target of sustainability debates—has been actively lobbying for adjustments, including exemptions for smallholder farmers and extended compliance timelines to avoid turning the regulation into a blunt trade barrier. Malaysia's strategy has been deliberate: rather than waiting until the regulations are fully implemented, it is already demanding clarifications, lobbying at international forums, and presenting its case during major events like the United Nations General Assembly.

Malaysia has taken a two-pronged approach: first, seeking clarity on the implementation of EUDR, especially the traceability requirements that place a heavy burden on smallholders; second, pushing for country-specific considerations that would recognize Malaysia's national efforts to tackle deforestation. For example, they have argued that their smallholder farmers should be offered specific exemptions or alternative compliance measures because of their socio-economic vulnerabilities and contributions to sustainable land management.

Contrast this with Africa, where the agricultural landscape is dominated by smallholder farmers growing key commodities like cocoa, coffee, fruits, flowers, spices, and tea. Despite the shared challenges, Africa's response has been notably subdued. There have been no major diplomatic efforts to negotiate more favorable terms, no concerted lobbying to secure exemptions for African smallholders, and no consistent push to articulate the unique complexities of African agriculture.

It’s as if Malaysia is at the microphone, belting out demands with a clear voice, while Africa is standing in line for karaoke, still debating which song to sing. And this isn’t just about national pride or publicity—it's about economic survival for millions of farmers. Malaysia's demands focus on avoiding unintended consequences that could cripple its smallholder farmers, emphasizing the importance of protecting their livelihoods while meeting environmental targets. Africa, on the other hand, risks having its agricultural exports marginalized in the lucrative European market due to its lack of proactive engagement.

If we consider the broader agricultural value chain, the irony is that Africa’s silence could lead to an outcome where, while the rest of the world adapts and demands accommodations, African farmers face the full brunt of the regulations without any concessions. This regulatory "one-size-fits-all" approach, if left unchallenged, risks excluding African smallholders from global trade—yet another missed opportunity in a continent full of them.

The African Context: Silence and Its Consequences

Africa's current response to the EUDR could best be described as muted, and the stakes are incredibly high. The continent's agricultural production is primarily driven by smallholders—millions of farmers who grow coffee, cocoa, tea, flowers, fruits, vegetables and other commodities that are covered by the new EU regulation. These commodities are the backbone of many African economies and critical to livelihoods. Despite this, there has been no coordinated diplomatic effort from African governments or major agricultural organizations to negotiate exemptions or influence the EUDR’s implementation.

The EUDR requires compliance with strict traceability and sustainability standards, and smallholder farmers across Africa are among those most vulnerable to these regulations. For instance, operators must provide geolocation information to prove that the commodities they export to the EU are not linked to deforestation. But for smallholders who farm just a few acres, often without digital tools or direct market access, providing such information is a daunting challenge.

Imagine another scenario: an Ivorian cocoa farmer named Amina who has been growing cocoa for over a decade. Her farm is part of a cooperative that sells to exporters who ship to Europe. Under the new regulations, every step of Amina’s supply chain must prove deforestation compliance. Without government support or organized advocacy, it is unlikely that Amina and her peers will be able to meet these requirements, potentially shutting them out of the EU market.

The lack of advocacy on Africa’s behalf contrasts starkly with the more aggressive approach taken by Malaysia. Malaysia has highlighted the specific socio-economic vulnerabilities of its smallholder farmers, arguing that a failure to consider these realities would create unintended trade barriers and undermine rural development. African smallholders face similar, if not greater, challenges—yet their plight has not been articulated at international forums or in negotiations with the EU.

Without proactive measures, Africa may become the biggest loser once these regulations are implemented. Inaction could lead to a scenario where African smallholders, who are often environmentally conscious out of necessity rather than policy, are effectively cut off from one of the world’s largest consumer markets due to a lack of institutional support. This would have significant ripple effects: reducing export revenues, threatening rural livelihoods, and undermining decades of development gains.

World Food Day Reflection: A Missed Opportunity for Advocacy?

It’s difficult to ignore the irony of celebrating World Food Day while new regulations like the EUDR threaten food security and economic stability for some of the world's most vulnerable populations. As we gather to applaud efforts to improve food security, millions of African smallholders may be left in an increasingly precarious position, unable to access their most lucrative export market due to complex bureaucratic requirements that they are ill-equipped to meet.

World Food Day, held annually in October, aims to raise awareness and mobilize action around issues of global hunger and food security. But this year, while Malaysia took the opportunity to vocalize its concerns at international forums, Africa largely missed its moment to step up to the microphone. If there was ever a stage set for Africa to raise its voice, it was this. Instead, it has remained a silent observer, letting opportunities for advocacy slip by.

The EUDR is not just a technical regulation; it is a new gatekeeper to the European market. With requirements that are challenging even for well-resourced agribusinesses, expecting smallholders—who may lack digital literacy, access to technology, or any organized support structure—to comply is unrealistic without additional assistance. The postponement of the EUDR’s implementation to December 2025 offers a small window for African stakeholders to mobilize, advocate for exemptions, and push for specific support for smallholder farmers.

The missed advocacy opportunities go beyond trade. World Food Day could have served as a platform for African governments to challenge the “one-size-fits-all” approach of the EUDR and to demand a just transition. Instead of merely accepting the regulations as they are, African countries could have highlighted their local efforts to combat deforestation and preserve ecosystems, asking for more nuanced compliance requirements that take into account their socio-economic realities.

While Malaysia actively champions its case, seeking adjustments that consider its local conditions, Africa’s silence risks a sweeping regulatory application that could effectively shut out many of its agricultural exporters. As we celebrate World Food Day, we should remember that securing food and livelihoods requires not only good agricultural practices but also proactive advocacy to ensure that international regulations do not inadvertently do more harm than good.