22 April 2026 · 6 min read
The EU Deforestation Regulation has been through enough delays that a certain fatigue has set in. That is a mistake worth avoiding. The current position is clear: large and medium operators must comply by 30 December 2026, and small operators by 30 June 2027. For anyone placing cocoa on the EU market, the work has to start well before those dates, because the data has to come from origin and origin cannot produce it overnight.
Cocoa is one of the seven commodities in scope. If you are the operator first placing it on the EU market, you must file a due-diligence statement and hold three things behind it: high-precision geolocation data linking the product to the specific plots of land where it was produced; evidence the production was legal under the laws of the producing country; and a documented risk assessment with mitigation where risk is not negligible.
The December 2025 simplification amendments changed who files, not what is required. Only the business first placing the product on the EU market submits the statement — downstream traders no longer resubmit. That reduces duplication and concentrates accountability. If you are the importer, it concentrates on you.
Geolocation is not a country of origin, a region, or a cooperative name. It is coordinates tied to plots. For plots above four hectares, that means polygons. And it must be reconstructable per lot — you have to be able to say which plots contributed to the container in front of you, not which plots your supplier works with in general.
That is a much harder requirement than it first appears in origins where beans pass through village buyers, town aggregators and regional consolidators before reaching an exporter. Each hand dissolves lot identity a little further. By the time a container is loaded, reconstructing plot-level contribution is often genuinely impossible — which is why so much origin-side EUDR work over the last two years has been an expensive retrofit.
Ask a prospective supplier one question: can you send me the plot geometry for a specific lot you shipped last season? The answer tells you everything about whether their traceability is real or aspirational.
When you evaluate a supplier's EUDR readiness, look for five components.
The reason geometry matters more than certificates is that geometry is checkable. Load the polygons into any forest-cover dataset you already use — Global Forest Watch, JRC's Global Forest Cover, your own provider — and check the plots against the cut-off date yourself. A supplier confident in their data will encourage exactly this. A supplier who offers a certificate instead of coordinates is asking you to take their word for it, and under EUDR their word is not the thing regulators will examine. Yours is.
If you are buying for the 2026/27 season, plot data needs to be in hand before contracting, not before shipment. Requesting geolocation after a lot is fermented and bagged means asking your supplier to reconstruct something they either recorded at collection or did not. Build the request into your supplier qualification instead: ask for a sample data pack during evaluation, run the geometry, and make the result part of the sourcing decision. It is a great deal cheaper to discover a traceability gap in a supplier questionnaire than in a due-diligence statement you have already filed.
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