EUDR for cocoa: scope, obligations, and how cocoa plots are screened

Cocoa is one of the seven commodities of Regulation (EU) 2023/1115 (Art. 2(1)). Annex I lists the whole of Chapter 18: beans, shells, paste, butter, powder, and chocolate and other food preparations containing cocoa. A chocolate maker placing bars on the EU market is in scope through heading 1806.

In scope: Annex I codes for cocoa

What the regulation asks of a cocoa importer

The obligations apply from 30 December 2026. An operator that is a micro or small undertaking, established as such by 31 December 2024, has until 30 June 2027, except for products that were already covered by the EU Timber Regulation. The amendment is Regulation (EU) 2025/2650.

For every consignment the operator must hold, and the statement must rest on:

• The geolocation of every plot of production, as a polygon where the plot is above four hectares, with the production period (Art. 9(1)(d)).
• Evidence that the products are deforestation-free against the 31 December 2020 cutoff (Art. 9(1)(g)) and were produced in accordance with the country's laws in the eight areas of Art. 2(40) (Art. 9(1)(h)).
• The product description with its HS code, the quantity, the country of production, and who supplied and who bought (Art. 9(1)(a) to (f)).
• A risk assessment on that information (Art. 10), and before placing, a due-diligence statement filed in the Information System, whose reference number goes into the customs declaration (Arts. 4, 26 and 33). Everything is kept for five years (Art. 12).

What is specific about cocoa

Cocoa shares coffee's two difficulties. The supply stands on very many small farms, often below four hectares, so a consignment carries hundreds of plots, many given as points. And cocoa is grown under shade: the farm reads as tree cover in every global dataset, while the regulation excludes agricultural plantations of commodities other than wood from its definition of forest (Art. 2(6)); the Commission's FAQ lists cocoa among them. The chain is also long: a bar placed on the market in Germany rests on beans that were placed on the market once already at import, so the question of who is the operator and who is a trader has to be settled per product and per step (Arts. 2(15), 2(17) and 5).

How Konstata screens cocoa plots

Every plot is screened in more than one pass. The first runs the plot through WHISP, the open analysis developed under FAO's Open Foris, against the EU's own 2020 forest map, the global loss datasets and the alert layers, joined by national records where a country publishes them. Where that finds loss after the cutoff, a second pass locates it on the ground against the forest map, so a reading on land that was not forest in 2020 is not mistaken for the conversion of forest. Where the plot is still unclear, a third pass reads ten years of monthly satellite greenness for the pattern of an established crop. Each plot ends with a verdict and a written reason, never milder than WHISP's own headline, and a plot the data cannot settle is held for a person, with what to check written next to it.

Cocoa's canopy is evergreen, so the greenness pass applies as it does for coffee: an established farm holds its reading across the cutoff, and a cleared one does not. For a downstream product the case links the consignment to the statements it rests on, so a chocolate maker working from beans that already carry a statement records its reference instead of screening the plots again, under the downstream rules of Arts. 4 and 5 as amended by Regulation (EU) 2025/2650.

Where to start

• Check your own product codes in the HS code lookup and the Annex I browser under /eudr/tools.
• Settle which date binds you with the company size test, and read the benchmark for each country of production in the country risk tool.
• Open a free Konstata workspace with room for three plots, import them, and read the screening on your own data. No card and no sales call.