Why Chocolate Is Covered by EUDR

Cocoa is one of the seven regulated commodities under the EU Deforestation Regulation (EUDR). This isn't random—global cocoa production is directly linked to significant deforestation, particularly in West Africa.

If you make chocolate bars, truffles, drinking chocolate, or any product containing cocoa—EUDR applies to you. It doesn't matter if you're a micro-business or if your cocoa is certified Fair Trade. The regulation treats all cocoa importers equally.

Understanding Your Role: Operator vs Trader

The first step is identifying your EUDR role. Chocolate makers typically fall into one of two categories:

Operators (Higher Obligations)

You're an Operator if you:

• Import cocoa beans directly from origin countries
• Are the first to place cocoa products on the EU market
• Transform raw cocoa into chocolate products

Operator obligations:

• ✅ Collect farm-level GPS coordinates from cooperatives
• ✅ Conduct full risk assessment for each cocoa batch
• ✅ Generate and submit DDS for every shipment
• ✅ Maintain 5-year traceability records
• ✅ Implement mitigation measures for high-risk sources

Traders (Simplified Obligations)

You're a Trader if you:

• Buy cocoa mass, cocoa butter, or chocolate from EU suppliers
• Resell chocolate products within the EU supply chain
• Don't import directly from origin countries

Trader obligations:

• ✅ Collect DDS reference numbers from your suppliers
• ✅ Verify upstream DDS validity
• ✅ Maintain records for 5 years
• ❌ Don't need to collect GPS coordinates yourself
• ❌ Don't need to conduct risk assessments

What Information You Must Collect

As a chocolate maker Operator, you must collect and maintain the following data for every cocoa shipment:

1. Geographic Coordinates (GPS)

This is the most challenging requirement. You need:

• Latitude and longitude for every production plot
• 6+ decimal places of precision (e.g., 6.5244, -1.6768)
• Farm-level data (not just cooperative headquarters)

2. Product Information

• Commodity type: Cocoa (Theobroma cacao)
• Quantity in kilograms
• HS code: Usually 1801.00 (cocoa beans) or 1803 (cocoa paste)
• Product description (e.g., "Fermented cocoa beans, Forastero variety")

3. Supplier Details

• Name and address of cooperative or exporter
• Country of origin (e.g., Ghana, Ivory Coast, Ecuador)
• Contact information
• Certification details (if applicable)

4. Harvest and Production Dates

• Harvest period (e.g., "October 2025 - January 2026")
• Fermentation and drying dates
• Export date from origin country
• Import date to EU

5. Traceability Documents

• Purchase contracts or invoices
• Phytosanitary certificates
• Bills of lading or shipping documents
• Certification documents (Fair Trade, Organic, etc.)

Working with West African Cooperatives

The majority of artisan chocolate makers source from Ghana or Ivory Coast cooperatives. Here's how to get the GPS data you need:

Step 1: Notify Your Cooperative Early

Send a formal notification at least 6 months before June 2026. Many cooperatives are overwhelmed with EUDR requests and need time to organize GPS collection.

Step 2: Provide GPS Collection Support

Many smallholder farmers don't have smartphones or technical knowledge. Offer practical support:

• GPS apps: Share free smartphone apps like GPS Fields Area Measure or What3Words
• Training sessions: Fund a cooperative training day on EUDR requirements
• Supplier portal: Provide a simple web form where cooperative staff can upload data
• Third-party verification: Hire local NGOs or certification bodies to collect GPS on your behalf

Step 3: Verify GPS Accuracy

Once you receive GPS coordinates, verify them using free tools:

• Google Maps: Paste coordinates to check they're actually in Ghana/Ivory Coast farming regions
• Global Forest Watch: Check for deforestation alerts near farm locations
• Precision check: Ensure coordinates have 6+ decimal places (e.g., 6.524431, -1.676802)

Certification vs EUDR: Critical Differences

This is the #1 source of confusion among chocolate makers. Let's be absolutely clear:

What Certifications Cover

Certification	What It Guarantees	EUDR Gaps
Fair Trade	Fair prices, social standards	❌ No GPS ❌ No DDS ❌ No deforestation proof
Rainforest Alliance	Environmental standards, some mapping	⚠️ GPS may exist but not shared ❌ No DDS ⚠️ Partial deforestation data
UTZ	Farm management practices	❌ No GPS ❌ No DDS ❌ No deforestation tracking
Organic	Chemical-free farming	❌ No GPS ❌ No DDS ❌ No deforestation standards

Certification Gap Analysis Strategy

If your cocoa is already certified, you can leverage that data to reduce EUDR compliance work:

1. Request GPS from certifier: Rainforest Alliance often has farm polygons—ask for them in EUDR-compatible format
2. Use audit reports: Certification audits may contain harvest dates, farm sizes, or satellite imagery you can reference
3. Document certification status: While not sufficient alone, certifications are supporting evidence in risk assessments
4. Combine data sources: Merge certification data with additional GPS collection to fill gaps

Risk Assessment for Cocoa

All cocoa imports require a risk assessment to determine likelihood of deforestation. Cocoa is automatically classified as higher risk due to:

• 🌍 Country risk: Ghana and Ivory Coast are in high-deforestation regions
• 📊 Commodity risk: Cocoa scores 9/20 on EU risk scale
• 🌳 Prevalence of violations: Documented cocoa-driven forest loss in West Africa

What Your Risk Assessment Must Cover

1. Geographic verification: Cross-reference GPS coordinates with Global Forest Watch to check for deforestation alerts after Dec 31, 2020
2. Supplier reliability: How long have you worked with this cooperative? Any red flags?
3. Certification status: Does the farm have any credible third-party certifications?
4. Complexity of supply chain: Direct from one cooperative (lower risk) vs aggregated from multiple sources (higher risk)
5. Evidence of legal compliance: Do you have export permits, phytosanitary certificates, etc.?

Generating Your Due Diligence Statement (DDS)

Once you've collected all data and completed risk assessment, you must generate a Due Diligence Statement (DDS) for each cocoa shipment.

DDS Contents for Chocolate Makers

Your DDS must include:

1. Your company details (operator name, address, EU registration)
2. Commodity description: "Cocoa beans (Theobroma cacao)"
3. Quantity and HS code
4. Country(ies) of production: e.g., "Ghana"
5. GPS coordinates of all production plots
6. Harvest date range
7. Risk assessment conclusion: "Negligible risk" or "Enhanced due diligence completed"
8. Supporting documents: Links to contracts, certificates, satellite verification

Where to Submit Your DDS

DDS must be submitted to the EU Information System before placing cocoa on the market. As of November 2025, the system is still being finalized, but key facts:

• ✅ Submission required before chocolate products are sold/distributed
• ✅ You'll receive a DDS reference number to keep for 5 years
• ✅ Customs may request DDS number at import
• ❌ No DDS = shipment refused or fines up to 4% of turnover

Special Considerations for Artisan Chocolate Makers

Single-Origin Chocolate Bars

If you produce limited-edition single-origin bars (e.g., "Madagascar 70%"), treat each origin as a separate batch for EUDR purposes:

• 🏷️ Batch tracking: Link each bar SKU to the specific cocoa shipment GPS data
• 📦 Lot codes: Use lot codes on packaging that reference DDS numbers
• 📝 Customer transparency: Some chocolatiers include DDS reference on product labels as a trust signal

Multi-Origin Blends

For chocolate blends using cocoa from multiple countries (e.g., "House Blend: 60% Ghana, 40% Ecuador"):

• ✅ You need GPS for all origins in the blend
• ✅ Conduct risk assessment for each origin separately
• ✅ One DDS can cover multiple origins if clearly documented
• ⚠️ If one origin is high-risk, the entire blend requires enhanced due diligence

Micro-Batch Production

If you make chocolate in 50kg batches or smaller:

• 📊 No exemption: EUDR applies to all chocolate makers regardless of size
• ⏰ SME deadline: June 30, 2026 (larger companies must comply by Dec 30, 2024)
• 💰 Simplified DD option: Micro-enterprises (≤10 employees) may use simplified procedures (TBD by member states)

Record Retention Requirements

You must keep all EUDR documentation for 5 years from the date of placing products on the market. This includes:

• ✅ GPS coordinate records
• ✅ Supplier contracts and invoices
• ✅ Risk assessment reports
• ✅ DDS submissions and reference numbers
• ✅ Satellite imagery or deforestation verification
• ✅ All communication with cooperatives about EUDR

What Happens If You're Non-Compliant

EUDR enforcement is serious. Non-compliance can result in:

• 💰 Administrative fines: Up to 4% of annual EU turnover
• 📦 Product confiscation: Customs can seize non-compliant cocoa shipments
• 🚫 Market bans: Temporary or permanent prohibition from selling chocolate in the EU
• ⚖️ Criminal penalties: In extreme cases of intentional violations
• 🏢 Reputational damage: Public disclosure of violations

Step-by-Step Compliance Roadmap

Here's your practical timeline to get EUDR-ready before June 30, 2026:

Now - March 2026 (6 Months Before Deadline)

1. Identify your EUDR role (Operator or Trader)
2. Audit all cocoa suppliers and list countries of origin
3. Contact cooperatives with EUDR notification letters
4. Request existing certifications and GPS data
5. Set up a supplier data collection system

April - May 2026 (3-4 Months Before Deadline)

6. Collect GPS coordinates from all cooperatives
7. Verify GPS accuracy using satellite tools
8. Conduct risk assessments for each origin
9. Gather supporting documents (contracts, certificates)
10. Set up 5-year record retention system

June 2026 (Final Month)

11. Generate DDS for all current cocoa inventory
12. Submit DDS to EU Information System
13. Train staff on ongoing EUDR procedures
14. Establish process for new cocoa shipments
15. Conduct internal compliance audit

Frequently Asked Questions

Do I need EUDR compliance if I only sell locally?

Yes. EUDR applies to placing products on the EU market, regardless of where you sell. Even if you're a small chocolatier selling only at farmers markets in France, if you import cocoa, you must comply.

What if my cooperative refuses to provide GPS data?

You have three options:

1. Offer financial support: Pay for GPS collection equipment or training
2. Switch suppliers: Find EUDR-ready cooperatives (growing number advertising compliance)
3. Third-party collection: Hire a local NGO or consultant to collect GPS on your behalf

Not an option: Importing without GPS after June 30, 2026. Enforcement authorities will not accept "supplier non-cooperation" as justification.

Can I use one DDS for a whole year of cocoa imports?

No. Each shipment requires a separate DDS. If you import cocoa four times per year from the same cooperative, you need four different DDS submissions (though the GPS data may be the same if from the same farms).

Does EUDR apply to cocoa butter and cocoa powder?

Yes. EUDR covers all cocoa-derived products, including:

• Cocoa beans
• Cocoa mass/paste/liquor
• Cocoa powder
• Cocoa butter
• Chocolate (all percentages)

What if I import cocoa from low-risk countries like Switzerland?

EUDR follows the country of production, not the country of export. If Swiss traders sell you cocoa originally from Ivory Coast, it's still high-risk Ivory Coast cocoa for EUDR purposes. You need the original farm GPS, not just Swiss trader documents.

Tools and Resources

Conclusion: Get Started Now

EUDR compliance for chocolate makers is achievable, but it requires early action. The biggest challenge—GPS coordinate collection from West African cooperatives—can take 6+ months due to communication delays and technical barriers.

Don't wait until June 2026. Start your EUDR journey now:

1. Notify all cocoa suppliers this month
2. Download our free cocoa supplier data template (Excel)
3. Request GPS from cooperatives with a 3-month deadline
4. Set up a systematic record-keeping system
5. Consider automated compliance tools to reduce admin burden

Questions about chocolate-specific compliance? Contact our team for personalized guidance.

The EU is serious about enforcement. Chocolate makers who wait until the last minute risk supply chain disruptions, emergency costs for rushed GPS collection, or worse—being locked out of the EU market entirely.