Compliance
Compliance regimes for African commodity exports.
A catalog of the regulations and schemes that govern commodities placed on international markets — what each one requires, where it applies, and who has to comply. Tracked and operationalised in the Commodity Plus compliance package.
Tier 1
- EU Deforestation Regulation
Bans placing on / exporting from the EU market commodities (cattle, cocoa, coffee, oil palm, rubber, soya, wood) and derived products unless they are deforestation-free (no deforestation after 31 Dec 2020), legally produced, and covered by a Due Diligence Statement. Plot-level geolocation is the core evidence.
- OECD Due Diligence Guidance for Responsible Mineral Supply Chains
The global meta-framework for responsible sourcing of minerals from conflict-affected and high-risk areas. Applies the five-step risk-based due-diligence framework to 3TG (tin, tantalum, tungsten, gold) and is referenced by the EU Conflict Minerals Regulation and US Dodd-Frank Section 1502.
- US Dodd-Frank Act Section 1502
Requires SEC-registered companies to perform OECD-aligned due diligence and file an annual conflict-minerals report on 3TG (tin, tantalum, tungsten, gold) originating from the DRC and adjoining countries.
- EU Critical Raw Materials Act
Establishes a framework for secure and sustainable supply of 34 critical raw materials (17 strategic), incl. cobalt, lithium, copper, and graphite with strong African overlap. Buyer-side responsible-sourcing work is already underway.
- US Inflation Reduction Act — Critical Minerals
EV tax-credit provisions requiring battery critical minerals to be extracted/processed in the US or an FTA partner, with Foreign Entity of Concern exclusions — driving demand for documented non-Chinese provenance.
- LBMA Responsible Gold Guidance
The de facto global standard for refined gold: every refinery selling into the LBMA market must run OECD-aligned due diligence and pass independent assurance. High-margin niche for refineries and major gold transit points.
- DMCC Dubai Good Delivery
The Dubai-market equivalent of the LBMA standard for the large Dubai-bound gold flow from East Africa — same responsible-sourcing architecture.
- Kimberley Process Certification Scheme
Mandatory certification preventing conflict ("blood") diamonds from entering the rough-diamond trade: each shipment of rough diamonds must be accompanied by a government-issued Kimberley Process Certificate.
- LBMA Responsible Silver Guidance
The LBMA responsible-sourcing standard for refined silver — the same OECD-aligned due-diligence and independent-assurance architecture as the gold guidance, for refineries on the Silver Good Delivery List.
- LBMA Responsible Platinum & Palladium Guidance
The LBMA responsible-sourcing standard for refined platinum-group metals — the same OECD-aligned due-diligence and independent-assurance architecture, for refineries on the Platinum/Palladium Good Delivery List.
Tier 2
- Rainforest Alliance / UTZ
Sustainable agriculture certification dominant in coffee, tea, and cocoa; merged with the former UTZ programme.
- Fairtrade International (FLO-CERT)
Producer-focused fair-trade certification covering coffee, cocoa, tea, sugar, and bananas, audited by FLO-CERT.
- EU Organic
EU organic certification issued by accredited control bodies for produce sold as organic in the EU market.
- USDA National Organic Program
US Department of Agriculture organic certification for produce marketed as organic in the United States.
- Japan Organic (JAS)
Japanese Agricultural Standard organic certification, required to label produce organic in Japan.
- GLOBALG.A.P.
The dominant good-agricultural-practice standard for fresh-produce exports to the EU — the major wedge for horticulture (cut flowers, fruit, vegetables).
- Fairmined / Fairtrade Gold
Certification for responsible artisanal and small-scale gold mining, carrying a strong price premium for verified ASM gold.
- Q Coffee (CQI) / SCA Cupping
Specialty-coffee quality verification: a licensed Q grade / SCA cupping score certifying the green coffee meets specialty thresholds.
- Starbucks C.A.F.E. Practices
Starbucks' proprietary ethical-sourcing programme for coffee — narrow ownership but very high purchase volume.
- Smithsonian Bird Friendly
Niche shade-grown, organic coffee certification commanding a premium for biodiversity-friendly production.
- Cocoa Life (Mondelēz)
Mondelēz's proprietary cocoa sustainability programme covering sourced cocoa volumes.
- Cocoa Horizons (Barry Callebaut)
Barry Callebaut's proprietary cocoa sustainability and traceability programme.
Tier 3
- EU Corporate Sustainability Due Diligence DirectiveOn the horizon
Obliges very large EU companies to conduct human-rights and environmental due diligence across their full supply chain. Phased application 2027–2029 — cascades supplier-documentation demand downstream.
- EU Forced Labour RegulationOn the horizon
Prohibits products made with forced labour from the EU market. Drives demand for labour-conditions verification, especially in tea, coffee, cocoa, and fishing.
- EU Corporate Sustainability Reporting Directive / ESRS
Requires large EU companies to report sustainability data (FY2024 onward); their disclosure obligations create downstream demand for verified supplier data.
- Germany Lieferkettensorgfaltspflichtengesetz
German Supply Chain Due Diligence Act, in force since 2023 for companies with 1,000+ employees. German buyers of East-African coffee, cocoa, cotton, and gold already request this documentation.
- Norway Transparency Act
In force since July 2022. Norwegian buyers request supply-chain due-diligence disclosure on human rights and decent working conditions.
- France Devoir de Vigilance
In force since 2017. French parent companies must publish a vigilance plan covering human-rights and environmental risks across their supply chain.
- UK Modern Slavery Act
Requires a published modern-slavery statement covering steps taken to ensure no slavery or human trafficking in operations or supply chains.
- UK Environment Act — forest-risk due diligenceOn the horizon
Watch item: forest-risk-commodity due-diligence regime under the Environment Act. Secondary legislation pending — surfaced as a readiness item.