EUDR for cocoa and chocolate
Bean importers and chocolate makers: control the origin of your cocoa, verify suppliers and file your due diligence with Sourevo.
Products affected
- Cocoa beans
- Paste, butter and oil
- Cocoa powder
- Chocolate and couverture
What information you need
- Cocoa suppliers and cooperatives
- Geolocation of the farms
- Batches and origin blends
- Evidence of legality
Cocoa is in scope end to end: beans, paste, butter, powder and chocolate (headings 1801 to 1806). The DDS is filed by whoever places the product on the EU market first. If a manufacturer in Valencia imports beans from Côte d'Ivoire, the DDS is theirs at clearance; when they later sell bars in Spain, they are a downstream operator and only keep the reference numbers.
Cocoa comes from small farms, many under 4 ha, grouped by cooperatives or local buyers. A 25 t lot can pool several hundred growers. So the first thing to establish is whether the exporter keeps traced cocoa apart from what it buys on the local market, because a single untraced sack leaves the lot uncovered.
CN codes in scope
| CN code | Product |
|---|---|
| 1801 | Cocoa beans, whole or broken, raw or roasted |
| 1803 | Cocoa paste, whether or not defatted |
| 1804 | Cocoa butter, fat and oil |
| 1805 | Cocoa powder, not sweetened |
| 1806 | Chocolate and other food preparations containing cocoa |
Cocoa shells, husks, skins and other cocoa waste (1802) are also in Annex I. A product containing cocoa that is classified outside these headings (a chocolate biscuit under 1905, for example) is out, although the chocolate you buy to make it is in.
Check another codeWhat to ask your supplier
Grower list per lot
Who supplied beans to that container, with name, country and region. In Côte d'Ivoire and Ghana this information usually sits with the cooperative or exporter, not the grower.
Geolocation for every plot
A point for plots up to 4 ha and a polygon for larger ones. Check the decimals: a point with two decimals has a margin of over a kilometre and is useless.
Segregation of traced cocoa
Ask how it is kept apart in the warehouse and at the port. If the exporter works on mass balance (mix first, allocate later), that model is not enough for the EUDR.
Harvest date
The main or mid crop in which it was harvested, to set the production period.
Proof of legality
Land rights, environmental and labour law of the country of production. Child labour is a known risk in cocoa; the country's labour law is part of the legality you have to verify.
Deadlines
- Large and medium-sized companies importing cocoa or chocolate, plus all downstream operators and traders.
- Micro and small enterprises (and natural persons) importing cocoa or chocolate.
Dates under Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650.
Frequently asked questions
I buy couverture from a European manufacturer. Do I need to do anything?
You do not file a DDS: the importer of the cocoa did. You are a downstream operator and keep the reference numbers your supplier gives you for 5 years. If you are not an SME, you also register in the information system.
What about chocolate I import ready-made from outside the EU?
Heading 1806 is in Annex I. If you import chocolate from Switzerland or the UK, the DDS is yours and you need the geolocation of the cocoa in it, even if the country of manufacture is low risk.
What risk level do Côte d'Ivoire and Ghana have?
Côte d'Ivoire is standard risk under Implementing Regulation (EU) 2025/1093. Standard risk means full due diligence: information, risk assessment and mitigation where the risk is not negligible.
Does mass balance work?
No. The EUDR requires the product you import to be linked to the plots where it was produced. Mixing traced and untraced cocoa and allocating volumes on paper does not comply.
Sweetened cocoa powder too?
Yes. Unsweetened cocoa powder is in 1805 and sweetened powder in 1806, and both headings are in Annex I.
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