The EU’s Deforestation Regulation (EUDR) is shaking up how cocoa is grown, tracked, and traded. If your business touches cocoa in any way – whether you’re sourcing raw beans, processing chocolate, or handling export – you’re now part of a much stricter system.
This isn’t just another layer of bureaucracy. It’s a major shift in how companies must prove that their cocoa isn’t tied to illegal practices or deforestation. The EUDR demands traceability, documentation, and transparency at a level that most cocoa supply chains aren’t currently built for.
So what does that mean in practice? Let’s break it down clearly, with no fluff, no jargon, and no assumptions.
What the EUDR Actually Requires for Cocoa
At the core, EUDR compliance means showing that your cocoa:
- Did not come from deforested land after December 31, 2020
- Was legally produced in the country of origin
- Can be traced back to the exact plot where it was grown
- Comes with a due diligence statement before entering the EU market
This applies to both operators (those placing products on the EU market or exporting them) and traders (who buy and resell cocoa within the EU). Each role has its own responsibilities, but both are legally on the hook for ensuring deforestation-free cocoa with verified sourcing.
There’s no loophole here. Even smallholders, cooperatives, and processors must be connected through a documented chain. Size doesn’t matter. What matters is data.
The Timeline You’re Working With
The EUDR became law in June 2023, but enforcement hits in stages:
- 30. Dezember 2025: Large and medium operators and traders must be fully compliant
- 30. Juni 2026: Micro and small enterprises are brought under the same rules
That gives most cocoa businesses until December 2025 or June 2026, depending on size, to get ready. The clock is ticking, especially for large and medium operators sourcing during the 2025 main harvest.
Cocoa Has It Tougher Than Other Commodities
Unlike palm oil or soy, cocoa supply chains are especially fragmented. Here’s why that matters:
- Smallholder dominance: Most cocoa comes from small farms with informal land rights
- Weak mapping systems: National records often lack detailed farm boundaries
- Cross-border trade: Cocoa gets mixed or trafficked across countries, losing origin data
- Shade-grown confusion: Agroforestry cocoa can look like natural forest in satellite images
All of these issues make compliance harder. You can’t just tick a box and call it done. You need reliable data, tools that work in rural areas, and systems to keep it all updated.
What Counts as Cocoa Under EUDR?
It’s not just beans. The EUDR applies to a wide range of cocoa products, including:
- Raw or roasted beans
- Shells, husks, and other waste
- Cocoa paste (defatted or not)
- Cocoa butter and oil
- Cocoa powder (without added sugar)
- Chocolate and food products with cocoa
These are classified under HS codes 1801 to 1806. Every one of them needs to be covered by due diligence documentation before hitting the EU market.
Why Polygon Mapping Isn’t Optional
Geolocation is non-negotiable. For plots over 4 hectares, polygon maps are required. That means:
- Accurate boundary lines drawn via GPS
- Coordinates that show exactly where the cocoa came from
- Data that can be verified and rechecked later
Single-point coordinates (like a farm center) don’t cut it. And fuzzy satellite images aren’t enough either. Regulators want confidence that no tree cover was removed after the cut-off date.
If your suppliers can’t provide this level of detail, it’s time to start mapping now.
Building a Real Due Diligence System
EUDR compliance goes far beyond collecting basic data. What’s required is a complete, working due diligence system with clear steps and documented processes. Here’s how that typically breaks down:
1. Information Collection
Start by compiling all essential supply chain data:
- Supplier identities and contact details
- Geolocation data (polygon coordinates, not just single points)
- Product quantities, batch references, and shipment documentation
- Legal ownership documents, production records, and contracts
2. Risk Assessment
Once your data is collected, it needs to be verified and evaluated:
- Use satellite imagery to detect signs of recent deforestation
- Check legal compliance, especially around land tenure and labor laws
- Account for regional factors like corruption risk, forest proximity, or presence of Indigenous communities
3. Risk Mitigation
If your assessment shows more than negligible risk, you’re required to respond before moving forward. This could involve:
- Conducting field audits
- Training suppliers on compliance expectations
- Updating documentation
- In serious cases, changing suppliers or suspending sourcing until gaps are addressed
4. Submitting the Due Diligence Statement
Once risks are addressed, you’ll need to:
- Submit the full due diligence statement via the EU’s TRACES NT system
- Include supporting geolocation, legal, and sourcing documents
- Maintain all records securely for at least five years in case of audit or investigation
Practical Barriers Cocoa Companies Face
No regulation is easy to implement, but cocoa presents some tough real-world issues:
1. Inconsistent Farm Data
Many farms are mapped informally or not at all. Even when data exists, it might be incomplete, duplicated, or outdated.
2. Farmer Recall Errors
Smallholders often estimate plot sizes or forget exact boundaries. Without training or digital tools, accuracy drops fast.
3. Informal Land Ownership
In some regions, legal land titles are rare. That makes it harder to prove legality under EUDR terms, even if the farm has operated for years.
4. Agroforestry Complexity
Cocoa grown under shade trees can confuse satellite systems. It might look like forest cover or be misread as cleared land when it’s just pruned.
5. Cross-Border Cocoa
Beans moved informally across borders lose traceability. Once mixed, you can’t prove origin or deforestation status.
What You Can Do Right Now
Even if you’re just starting, there are clear steps you can take:
- Start mapping farms: Use mobile GPS tools to collect polygon boundaries
- Talk to suppliers: Find out who can provide documentation and who needs help
- Check deforestation risk: Run satellite imagery checks for red flags
- Build digital records: Use software to store and track data from farm to shipment
- Stay current on law: Member states may apply enforcement differently. Follow local interpretations closely.
What About Certification?
Certifications like Fairtrade or Rainforest Alliance can support your process but do not replace EUDR requirements. The EU is clear on this: operator-led due diligence is mandatory. You can’t outsource the responsibility.
That said, certified farms may already have traceability systems in place, which can save time and reduce risk.
Using the Right Tool Makes a Big Difference: EUDR Compliance
Manual checks aren’t enough anymore. For cocoa companies trying to meet EUDR requirements across large, fragmented supply chains, automation isn’t just helpful – it’s essential. That’s where we come in.
Unter EUDR-Einhaltung, we’ve built a platform designed to simplify the entire compliance process. Our tools are built for real-world supply chains, not ideal-case scenarios. Whether you’re dealing with dozens of smallholders or managing trade across borders, our system helps you move from uncertainty to verified, auditable compliance.
What our platform does:
- Generates precise polygon maps using verified geolocation data
- Integrates with satellite-based monitoring for ongoing deforestation checks
- Stores sourcing and legal documentation in one central, secure place
- Prepares due diligence statements in line with TRACES NT submission standards
- Tracks your compliance progress across different commodities and suppliers
We made the platform accessible and affordable, with flexible pricing for businesses of all sizes. The interface is clean and easy to use, even for teams without deep technical experience. Most importantly, every report and output is backed by data accuracy and traceability that stands up to EU scrutiny.
EUDR compliance isn’t just a technical challenge – it’s about building trust in your supply chain. We help you get there faster, with fewer gaps and much less stress.
Final Thoughts: The Real Point of EUDR
Yes, EUDR compliance can be frustrating. It’s a lot of work, especially if your supply chain spans multiple countries, languages, and tech levels. But the goal is real: stop deforestation tied to everyday products like chocolate.
That means the cocoa industry has a choice. Wait for the deadline and scramble, or use this moment to build systems that are cleaner, smarter, and future-proof.
If you’re working with cocoa, the time to act is now. And if you get this right, it won’t just be about checking a regulatory box. It’ll be about running a business that’s ready for the next 10 years, not the last 10.
Häufig gestellte Fragen
What exactly is the EU asking for with cocoa traceability?
In plain terms, the EU wants to know where your cocoa comes from, all the way down to the farm plot. And not just vaguely – we’re talking precise GPS coordinates, ideally in polygon format. They want proof that no deforestation happened there after December 2020 and that the farm follows all local laws. Without this, your cocoa can’t legally enter the EU market.
Does this apply to small farms and informal suppliers too?
Yes, absolutely. The EUDR doesn’t make exceptions for smallholders or less formal setups. Every link in the chain matters. Whether your cocoa comes from a large estate or a few hundred family farms, the responsibility is the same: full documentation, mapped land, and proof of legal and sustainable production.
Are third-party certifications like Rainforest Alliance enough to comply?
Not on their own. Certifications can support your documentation and help with traceability, but they’re not a substitute for the EU’s due diligence requirements. You still need to collect geolocation data, assess risks, and file the due diligence statement yourself. The EU puts the legal responsibility on you, not the certifier.
What happens if I’m not ready by the deadline?
If your cocoa products don’t meet the compliance standards by the time enforcement kicks in, they won’t get past customs. On top of that, you could face financial penalties or have your shipments flagged for further inspection. The deadlines are real, and regulators aren’t offering much wiggle room.
How do I handle mixed or cross-border cocoa?
That’s one of the trickiest parts. Cocoa that crosses borders informally or gets mixed with other batches becomes nearly impossible to trace properly. Once origin data is lost, you can’t prove deforestation-free status. That’s why segregation and clean data from the start are so important.
Can I still work with smallholders who don’t have legal land titles?
You can, but you’ll need to tread carefully. The EUDR requires proof that cocoa was grown legally, which includes land use rights. In places where land titles are informal or unclear, you’ll need to dig deeper – think local legal documentation, community agreements, or third-party verification. It’s not impossible, but it does take more effort.
