EUDR and cocoa sourcing: what changes on 30 December 2026
Summary. From 30 December 2026, cocoa, soy, coffee, palm oil, rubber, cattle, and wood can only be placed on the EU market with a due diligence statement proving the goods are deforestation-free and legally produced. The statement requires plot-level geolocation for every farm in the consignment. Côte d'Ivoire, which produces around 40 percent of the world's cocoa, is classified standard risk. Ghana is classified low risk. Russia is one of four high-risk countries. Penalties reach at least 4 percent of an operator's annual EU turnover. Buyers who have not secured geolocated supply by the fourth quarter of 2026 will be competing for a smaller pool of compliant origin at a premium.
What the regulation does
Regulation (EU) 2023/1115, the EU Deforestation Regulation, entered into force on 29 June 2023. It prohibits placing on the EU market, making available on it, or exporting from it, any covered commodity produced on land deforested after 31 December 2020, or produced in breach of the laws of the country of origin.
The cut-off date is the part that surprises operators. Legality in the producing country is necessary but not sufficient. Cocoa grown on land that was legally cleared in 2021 is non-compliant. The regulation looks at the land, not the permit.
When does it apply?
The application date has moved twice. The regulation was originally due to apply from 30 December 2024. In December 2024 the co-legislators postponed it by one year. In December 2025 the Council adopted a second postponement together with a package of simplifications.
The dates that now stand: 30 December 2026 for large and medium operators and traders, 30 June 2027 for micro and small enterprises. The European Commission has stated it will not reopen the text again. Anyone planning around a third delay is planning around a statement the Commission has already contradicted in writing.
Which products are covered?
Seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya, and wood. The regulation also covers derived products listed in its Annex I, which for cocoa means beans, shells, paste, butter, powder, and chocolate. A chocolate bar sold in Rotterdam carries the same due diligence obligation as a container of beans discharged there.
What is a due diligence statement?
Before a covered product is placed on the EU market, the operator submits a due diligence statement through the EU's information system. The statement carries a reference number that accompanies the customs declaration. Submitting it is a legal declaration that the operator has collected the required information, assessed the risk, and reduced any risk to negligible.
The December 2025 revision narrowed who must file. The statement is now required only from the company that first places the product on the EU market. Downstream operators no longer file their own statements, and small primary operators file a one-off simplified declaration instead of one per consignment.
For a physical cocoa trade this concentrates the obligation on the importer of record. The importer's due diligence is only as good as the origin data behind it, which is why the geolocation requirement is where compliance is actually won or lost.
What do the geolocation rules require?
Every plot of land where the commodity in a consignment was produced must be identified by coordinates. Plots larger than 4 hectares require a polygon describing the perimeter, not just a point. For cocoa this is demanding by design: a single consignment of Ivorian beans can aggregate production from hundreds of smallholder plots, most under 4 hectares, many never previously mapped.
The practical consequence is that compliance is built at the cooperative and buying-station level, seasons before shipment. An exporter who cannot produce plot coordinates for the full consignment cannot support the buyer's due diligence statement, whatever else the paperwork says.
How does country benchmarking change sourcing?
On 22 May 2025 the Commission published the first country benchmarking list, classifying every country as low, standard, or high risk. The tier sets the depth of due diligence and the rate at which national authorities must check operators: checks cover at least 1 percent of operators sourcing from low-risk countries, 3 percent for standard risk, and 9 percent for high risk.
Four countries are high risk: Belarus, Myanmar, North Korea, and Russia. 140 countries are low risk, including every EU member state, the United States, China, and Ghana. Everything else is standard risk, including Côte d'Ivoire, Cameroon, Nigeria, Brazil, and Indonesia.
Two entries on that list matter most for cocoa.
Côte d'Ivoire at standard risk means full due diligence on roughly 40 percent of global supply: complete risk assessment, mitigation, and plot-level traceability on every consignment.
Ghana at low risk qualifies for simplified due diligence. The operator collects information but is not required to run the assessment and mitigation steps. Analysts at CZ called the divergence between the two neighbours a surprising anomaly, and the commercial effect is already visible: Ghanaian origin carries a compliance discount in effort that will express itself in price as the deadline approaches.
Russia at high risk closes the EU door on Russian-origin soy in practice. The 9 percent check rate and enhanced scrutiny apply to any operator placing it on the EU market. Trade in Russian agricultural commodities to non-EU destinations sits outside the regulation entirely, since EUDR governs the EU market and EU exports, not third-country trade.
The benchmarking is dynamic. The first review is scheduled for 2026, drawing on updated FAO Global Forest Resources Assessment data, so a country's tier can move.
What are the penalties?
Member states set penalties within the regulation's floor: fines of at least 4 percent of the operator's total annual EU turnover, confiscation of the products and of the revenues from them, and exclusion from public procurement and public funding. Non-compliant product is barred from the market. For a trading business the operational penalty arrives earlier than any fine: cargo that cannot clear customs.
What should EU buyers do before December?
Map current suppliers against the benchmarking list and identify which volumes come from standard-risk origins with incomplete plot data. Ask every origin supplier one question now: can you deliver plot coordinates, polygons above 4 hectares, for the full volume you intend to ship in the first quarter of 2027? Suppliers who answer with certification logos instead of coordinates are not ready. Certification schemes can carry some of the data burden, but the due diligence statement is the operator's own legal act and cannot be delegated to a label.
Contract for it. Purchase contracts signed now for post-deadline delivery should make delivery of EUDR-conformant geolocation data a documentary obligation alongside the phytosanitary certificate and the bill of lading, with rejection rights if it fails verification.
What should origin exporters do?
Treat plot mapping as a sales asset rather than a cost. From 30 December 2026, an Ivorian or Cameroonian exporter with verified polygons holds access to a market their unmapped competitors are locked out of. The scramble in the final quarter of 2026 will not be for cocoa. It will be for cocoa with coordinates.
Where Sovran sits
Sovran Commodities structures cocoa transactions between origin exporters and buyers in Europe and Asia. The firm maintains a physical presence in West Africa, and origin verification is carried out on the ground: plots, cooperatives, and export documentation are checked at source before a transaction is structured, then managed remotely through to delivery. Counterparty screening and EUDR data obligations are written into the contract chain rather than bolted on at customs.
This briefing is a working note on regulated trade, not legal advice. Regulation (EU) 2023/1115, the December 2025 amending regulation, and the Commission's implementation materials are the authoritative sources.
Inquiries: mandates@sovrancommodities.com