Beyond Compliance: How New EU Rules Can Strengthen African Exporters’ Position

What if the new European regulations were not just a constraint for African exporters, but also an opportunity to strengthen their position vis-à-vis their buyers? This was the core message delivered by Steven Tebbe at the 4th edition of the African ESG Summit.

A former Director General of CDP Europe and former collaborator with EFRAG, Tebbe offered a distinct perspective on European regulation. For him, the issue is no longer simply about how African companies will comply with European requirements. Instead, it is crucial to understand what European buyers must now obtain from their suppliers to meet their own obligations.

“I am not here to tell you how your market works. You know it far better than I do. What I can offer you is a view from inside the room where the requirements affecting you are being formulated,” he stated.

An Insider’s Perspective

Steven Tebbe knows the subject from the inside. He explained that he spent 10 years developing the activities of CDP Europe, an organization specialized in collecting environmental data from companies and investors. He subsequently worked with EFRAG, playing a role in the European process that led to the development of the European Sustainability Reporting Standards (ESRS).

A Shift from Complexity to Simplification

His first observation is somewhat unusual for a speech dedicated to ESG. After several years of warnings about a massive tightening of European regulations, Brussels has ultimately initiated a movement toward simplification. The scope of the Corporate Sustainability Reporting Directive (CSRD) has been reduced, and the European framework for sustainability reporting has been revised.

“Many of you have probably spent three years hearing that a wall of European regulation was coming,” he noted.

According to Tebbe, this evolution should serve as a lesson. An African company should not build its commercial strategy solely on the assumption of continuous tightening of European regulations. In fact, “a rule that arrives before anyone actually wants the data it produces is a rule that can easily be abandoned when politics change,” he argues.

However, this does not mean that European demand for ESG data is disappearing. Some regulations are now sufficiently entrenched in trade to alter the relationship between buyers and suppliers.

• Carbon Border Adjustment Mechanism (CBAM): Entered its definitive regime on January 1, 2026, covering cement, iron and steel, aluminum, fertilizers, electricity, and hydrogen.
• Deforestation Regulation: Adds traceability requirements affecting sectors such as cocoa and timber.

For African companies present in these markets, these mechanisms are not merely matters of compliance. They directly impact the commercial relationship with the European buyer. This is precisely where Tebbe wants to shift the focus.

“None of these rules apply to you. Each applies to your buyer, and your buyer cannot meet their obligations without you,” he explained.

From Compliance Burden to Strategic Dependency

The nuance is significant. Legally, it is often the European company that bears the obligation. However, to fulfill this obligation, it must obtain information from its supplier: product origin, geolocation of plots, traceability, embedded emissions, production data, and more. These pieces of information can become indispensable for the continuation of the commercial relationship.

“This is not a compliance burden. It is a dependency,” Tebbe summarized.

This dependency could, according to him, alter the balance of power. A large buyer can always send a questionnaire to its supplier and request a new series of data. But behind every question lies a cost.

“There is a questionnaire, a portal, a request: ‘Please complete this by Friday.’ What is presented as a requirement effectively shifts the cost to the supplier,” he observed.

Data does not produce itself. Mapping plots, measuring embedded emissions, or ensuring traceability in a chain linking thousands of producers to a single container requires tools, personnel, and investment.

“Mapping costs money. Measuring embedded emissions costs money. Building traceability from a thousand producers to a single container costs money. And someone has to pay,” he emphasized.

Turning Data into an Asset

For the expert, this is precisely the terrain where African exporters can take the lead. Rather than waiting for the European buyer to request data, they should start by asking the buyer a question: What information do you need to meet your own obligations?

“The most successful exporters ask their buyer a question instead of waiting for the request. The question is simply: What do you have to declare, and what do you need from me to do so?”

The difference may seem minor, but it is not. It shifts the dynamic from a supplier passively accepting a new requirement to a partner providing information the buyer needs. In fact, when data is essential to a transaction, has legal consequences, and costs money to produce, it acquires economic value.

“Things that have these three properties have a price. And things that have a price can be financed,” he argued.

Therefore, traceability should no longer be viewed solely as an additional expense imposed by ESG. It can become an asset, provided it is structured, reliable, and available.

The same logic applies to the regulatory calendar. The postponement of certain European obligations should not be interpreted as a reason to wait.

“The shift of the due diligence directive to 2028 is not a reprieve. I think it is a window,” Tebbe said.

For him, a supplier who prepares their data before the buyer requests it is in a different position than one who has to gather it in a rush.

“The supplier whose documentation is ready before it is requested negotiates. The one who gathers it under a red line does not negotiate.”

Conclusion: Export What Europe Cannot Do Without

Steven Tebbe’s message boils down to a change in perspective. ESG is not just a story of European rules that African companies must comply with. It is also a question of value, data, and commercial leverage.

“I would say: export what Europe cannot do without, and clearly understand that what it cannot do without today is the proof that it can only obtain from you.”

The product remains at the heart of exportation. However, the ability to prove its origin, traceability, or environmental footprint could become equally strategic. According to Tebbe, European buyers may not necessarily lack suppliers. However, they may lack suppliers capable of documenting what they sell. And those suppliers will be the hardest to replace.