EUDR and cocoa: what importers must collect
Cocoa beans and everything downstream, paste, butter, powder, and chocolate, are covered.
EUDR · Regulation (EU) 2023/1115
Cocoa is one of the seven commodities covered by the EU Deforestation Regulation. Placing cocoa on the EU market needs a Due Diligence Statement filed before customs clearance.
Cocoa is one of the seven commodities covered by the EU Deforestation Regulation, so cocoa and the products derived from it cannot enter the EU market unless it is deforestation-free after 31 December 2020, legally produced in its country of origin, and covered by a Due Diligence Statement. Annex I lists it under 1801, 1802, 1803, 1804, 1805, 1806.
Is cocoa covered by the EUDR?
Yes. Cocoa is on the list of seven commodities, alongside cattle, cocoa, coffee, oil palm, rubber, soya and wood. Scope extends to the derived products in Annex I, so a finished good containing cocoa can be in scope too. The exact boundary is the CN code: for cocoa the relevant headings are 1801, 1802, 1803, 1804, 1805, 1806. Several Annex I rows carry an ex prefix, meaning only the described subset of that heading is caught, and the Annex itself is versioned. Article 34 lets the Commission update the codes by delegated act, so check the current text rather than a cached list.
What cocoa importers have to collect
The same three things every covered commodity needs: plot geolocation for the ground it came from, evidence that it was produced legally and is deforestation-free, and a Due Diligence Statement filed before customs. There is no de minimis: the obligation applies whatever the quantity, including where cocoa is a minor ingredient inside a processed product.
Most cocoa originates with West African smallholders. Chocolate makers are usually downstream operators and can often rely on a Due Diligence Statement filed upstream. Confirm the reference number travels with the goods.
What is not in scope for cocoa
Cocoa is the cleanest of the seven: Annex I runs the whole chain from beans (1801) to finished chocolate (1806) with no partial-scope carve-outs, so there is no boundary to argue about.
When does this apply, and what next?
From 30 December 2026 for large and medium operators and 30 June 2027 for natural persons and micro and small undertakings established by 31 December 2024. The deadlines page sets out the four separate dates the Regulation keeps and why they are not interchangeable. Start by confirming which cocoa products you handle are in scope, then ask suppliers for geolocation and statement reference numbers now. EUDR for SMEs covers the reliefs for smaller importers, and the EUDR overview walks the full flow.
Sources
Collect the plots once. File every shipment after.
Bindu holds the geolocation, the legality evidence, and the audit trail in one record, and assembles the statement from it when a shipment moves.