Successfully navigating compliance with the EU Deforestation Regulation (EUDR) for cocoa means systematically gathering geo-verified farm data, analysing historical land use, documenting legality, and maintaining robust traceability and due diligence systems across your entire supplier base, regardless of their size or access to technology.

Achieving this requires managing significant volumes of data, coordinating multiple stakeholders, and applying due diligence expertise. Once these elements are in place, EUDR compliance can become a smooth and largely automated process.

This guide provides an overview to help stakeholders understand the expectations of the EUDR, with cocoa-specific insights and practical steps to support compliance.

EUDR requirements for compliant cocoa

Cocoa must be sourced from land that has not undergone deforestation since 31 December 2020.

Under the EUDR, every shipment of cocoa must be fully traceable back to its exact cultivation site. This can be verified through geographic coordinates or detailed mapping, ensuring that no deforestation has occurred after the official cut-off date. Importantly, this requirement applies to all producers and suppliers, regardless of business size.

The regulation also distinguishes between two categories of companies: operators and traders.

• An operator is the business that first places cocoa products on the EU market, either as an importer or as the initial seller within the EU.
• A trader refers to any company that purchases or resells these products after their initial entry into the market.

Both categories are legally obliged to conduct due diligence and to submit a due diligence statement through the EU’s centralised information system before proceeding with their activities.

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Which cocoa products and derivatives (HS codes) are subject to EUDR

The European Union’s Deforestation Regulation (EUDR) applies to a wide range of cocoa products, from raw beans to finished chocolate, ensuring that all cocoa placed on the EU market meets strict criteria for deforestation-free and legally produced goods. This includes cocoa beans (raw or roasted), shells and husks, cocoa paste, butter, powder without added sugar, and chocolate or other food preparations containing cocoa. Operators and traders must demonstrate full traceability and compliance for these specified product categories in order to meet the regulation’s requirements.

The following HS codes apply:

• 1801 – Cocoa beans, whole or broken, raw or roasted
• 1802 – Cocoa shells, husks, skins and other cocoa waste
• 1803 – Cocoa paste, whether or not defatted
• 1804 – Cocoa butter, fat and oil
• 1805 – Cocoa powder, not containing added sugar or other sweetening matter
• 1806 – Chocolate and other food preparations containing cocoa

Key challenges in EUDR cocoa compliance

Cocoa’s traceability

Cocoa’s traceability faces unique obstacles because most cocoa is cultivated on unregistered plots by smallholders who depend on informal land tenure, while national mapping systems lack coverage, making farm-level traceability much more fragmented and less reliable than for commodities like palm oil or soy.

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National definitions

National definitions of ‘deforestation’ in top cocoa-producing countries often conflict with EUDR standards or lag behind EU progress, which leaves farmers and exporters frequently dealing with inconsistent legal frameworks and uncertain compliance risks.

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Reliability of farm plot level data

Another obstacle is the reliability of farm plot-level data. Farm mapping datasets are often inconsistent and incomplete, limiting its usability for robust compliance processes like those required under the EUDR. In the Cavally region of Côte d’Ivoire, for example, Meridia, with support from Rabo Foundation, conducted a study that revealed that approximately 30% of farm plot data collected on the ground was insufficiently reliable to meet EUDR standards. This highlights a systemic challenge: while ground-truthing is indispensable, the data collection process is often hampered by inaccurate farmer recall, inconsistent measurement practices, and difficulties in defining exact boundaries.

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Cocoa trafficking

Cocoa trafficking between countries undermines traceability and EUDR compliance, as beans moved informally across borders become mixed, losing any origin data and often falling out of scope for regulatory control or mapping, thereby making legal verification and deforestation risk assessment virtually impossible.

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Correct detection of agroforestry or shade-grown cocoa

Agroforestry is a well-established practice in cocoa farming, helping to protect young cocoa trees from excessive sunlight while also enhancing carbon sequestration on farms. However, detecting shade-grown cocoa or agroforestry systems through remote sensing remains a significant challenge. From a satellite perspective, these mixed tree systems often resemble natural forest cover, making it difficult to distinguish managed cocoa plots from intact forest. Similarly, when canopy cover is reduced through farm maintenance or tree thinning, it can be misinterpreted as deforestation.

Step-by-step approach to EUDR-compliant cocoa supply chains

Step 1: Map your cocoa supply chain

Identify every actor in your cocoa network, from cooperatives and buying stations to individual smallholders and larger estates. Collect precise geolocation data, always using polygon boundaries instead of point coordinates. This ensures you can pinpoint the exact origin of your cocoa and link it back to the land where it was produced.

Step 2: Establish a due diligence system

Gather key documentation such as farm boundaries, satellite-based deforestation checks, and proof of compliance with local land and labour laws. While voluntary certifications like Fairtrade or Rainforest Alliance may support your efforts, they cannot substitute for the mandatory verification requirements under the EUDR.

Step 3: Conduct a comprehensive risk assessment

Verify and analyse all collected data, paying attention to risk factors such as the deforestation history of the sourcing region, proximity to forest frontiers, the presence of Indigenous communities, land tenure clarity, and supply chain complexity. Because the burden of proof lies with operators, you need accurate and well-documented evidence to demonstrate compliance.

Step 4: Mitigate identified risks

If the assessment flags cocoa linked to deforestation after the 2020 cut-off date, unclear land ownership, or other compliance gaps, engage directly with suppliers to resolve them. This can involve updating maps, carrying out independent verification, supporting farmer training, or investing in cooperative-level data systems. By enabling smallholders to improve, you reduce risk while keeping them integrated in the supply chain.

Step 5: Submit due diligence statements

Once risks are reduced to a negligible level, prepare and submit your due diligence statement. This includes cocoa plot data, supply chain details, and a formal declaration of compliance, all uploaded to the EU’s centralised system. You will receive a unique reference number required for customs clearance.

Step 6: Maintain continuous monitoring

EUDR compliance is an ongoing process. Set up systems for satellite monitoring, spot checks, and regular supplier updates. Encourage farmers to adopt practices like accurate boundary mapping, agroforestry, and digital record-keeping to strengthen traceability and ensure sustained compliance over time.

Cocoa-specific strategies and best practices

Traceability in cocoa supply chains is complex due to the many smallholders, fragmented markets, and informal land tenure systems. These factors create significant challenges for mapping origin and ensuring legal and environmental compliance. Addressing these challenges requires tailored strategies to improve farm-level data, harmonise regulatory definitions, and prevent cocoa trafficking across borders. 

• Develop platforms and mobile tools that enable reliable mapping of smallholder cocoa plots, using GPS data and digital documentation to overcome the challenges posed by unregistered land and fragmented farm records.

• Create collaborative protocols and risk assessment frameworks that integrate national and EU deforestation definitions, regularly monitor mapped farms, and support farmers through transparent compliance guidance.

• Implement robust batch segregation and verification procedures, including audits and community engagement, to block cross-border cocoa trafficking and mixing, helping preserve origin data and meet EUDR traceability standards.

How Meridia Verify can support your cocoa EUDR compliance

Meeting the EUDR requirements in cocoa is complex, but Meridia is uniquely positioned to close the gap between regulation and practice. Through Meridia Verify, we provide a purpose-built solution for collecting, validating, and maintaining farm-level data that meets the EU’s strict due diligence standards.

Here’s what Meridia can do:

• Farm mapping and geo-verification

We work directly with smallholder farmers, cooperatives, and supply chain actors to generate reliable polygon-based maps and GPS data. By combining on-the-ground expertise with digital tools, we address gaps in fragmented datasets and ensure your sourcing areas are accurately represented.

• Deforestation and legality checks

Meridia Verify integrates satellite imagery, historical land use analysis, and legal documentation to confirm that cocoa has not been linked to deforestation since the December 2020 cut-off. Our methodology also verifies compliance with land tenure and local regulations, helping operators and traders demonstrate legality.

• Data validation and quality assurance

In cocoa, as much as 30% of farm data can be unreliable. Meridia applies robust validation protocols, harmonising records, correcting inconsistencies, and standardizing farm information so that it is EUDR-ready.

• Seamless integration with ICE CoT

ICE Benchmark Administration (IBA) provides the ICE Commodity Traceability Service (ICE CoT), a platform supporting EU Deforestation Regulation (EUDR) compliance for cocoa and coffee. In partnership with Meridia, ICE CoT uses tested methodologies and software (Meridia Verify) to collect and validate supply chain data: checking for quality, legal compliance, and deforestation risks. This is especially critical for cocoa, which faces greater data gaps than other commodities due to fragmented sourcing, weak mapping, and frequent blending. ICE CoT addresses this by offering a Green Lane pre-assessment to standardise and verify cocoa farm data (GPS, boundaries, documentation), seamless integration with the EU due diligence system, and a harmonised traceability approach that works even when beans come from thousands of smallholder farms.

• Risk assessment and mitigation

Meridia helps you identify deforestation risk hotspots, land tenure issues, or traceability gaps across your supply base, and then works with suppliers and farmers to address them. This ensures you can move from risk detection to practical risk reduction.

• Continuous monitoring and supplier engagement

Compliance is not a one-off exercise. We set up systems for ongoing satellite monitoring, field verification, and farmer training. By equipping smallholders with digital record-keeping tools and compliance support, we help secure long-term supply chain resilience.

With Meridia, operators and traders gain a trusted partner to transform EUDR obligations into a streamlined, auditable process. Our expertise bridges the realities of cocoa farming with the demands of EU regulation; making compliance not just possible, but sustainable.

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