This checklist provides a 26-point framework for cocoa operators and traders to assess readiness for the EU Deforestation Regulation. It is organised by supply chain tier — from smallholder sourcing through buying stations, cooperatives, and export — reflecting the extreme fragmentation of cocoa production, where millions of smallholders with plots averaging 2-5 hectares feed into aggregation networks before reaching the EU market.
Completing this checklist does not constitute compliance. The EUDR requires operators to exercise due diligence and file a Due Diligence Statement substantiated by evidence. This checklist helps identify where your evidence chain has gaps before a competent authority finds them.
What is the EUDR cocoa compliance obligation?
Regulation 2023/1115 prohibits placing on or exporting from the EU market commodities that are not deforestation-free or were not legally produced. Cocoa and its derived products — cocoa beans (HS 1801), cocoa paste (HS 1803), cocoa butter (HS 1804), cocoa powder (HS 1805), and chocolate (HS 1806) — are among the seven covered commodity groups.
For cocoa, the supply chain spans 4-5 tiers: smallholder to pisteur (itinerant buyer) or buying station, buying station to cooperative, cooperative to exporter, exporter to EU importer. In West Africa — approximately 60-70% of global production — millions of smallholders sell through informal buying networks where traceability has historically been minimal. The operator filing the DDS — typically the EU importer — bears the full burden of proof under Article 4.
Cote d'Ivoire and Ghana have experienced among the highest deforestation rates globally, with significant encroachment into classified forests and protected areas.
What this template covers
Sourcing and geolocation (Articles 9(1)(d), 9(1)(e))
- All source plots identified and geolocated in WGS84 (EPSG:4326) at 6-decimal precision
- Single GPS point captured for plots of 4 hectares or less; polygon boundaries captured for plots exceeding 4 hectares (most cocoa smallholdings fall within the single-point threshold)
- Geolocation data includes collection timestamp, device metadata, and collector identity — not just raw coordinates
- Each plot linked to an identified farmer with tenure documentation on file — land title, customary tenure record, or attestation from local authorities
- Planting year or crop establishment date recorded for each plot to verify production against the December 31, 2020 deforestation cutoff
- For plots in or near classified forests, protected areas, or high-deforestation zones: satellite imagery analysis performed to confirm no forest loss after December 31, 2020
- Farm production system documented — full-sun monoculture, shade-grown, or agroforestry — as this affects deforestation risk profile and canopy interpretation in satellite imagery
Risk assessment (Article 10)
- Country risk classification confirmed for each origin (standard, low, or high risk) using current EU benchmarking
- Deforestation screening performed using satellite imagery anchored to the December 31, 2020 baseline
- Proximity to classified forests and protected areas assessed for each source plot
- Independent deforestation alert systems cross-referenced for each source area (e.g., Global Forest Watch, GLAD alerts)
- Risk assessment methodology documented: data sources, resolution, thresholds, and decision criteria recorded
- Where concerns identified: risk mitigation measures documented and implemented before DDS filing (Article 10(2))
Legality verification (Article 9(1)(e))
- Relevant legislation of the country of production identified (land use laws, forestry regulations, environmental protections, labour laws including child labour prohibitions, tax obligations, and community rights including FPIC)
- Legal compliance evidence collected or supplier attestation obtained with supporting documentation for each origin
- Child labour risk assessed and documented (Article 10(2)(j)) — particularly for West African origins where child labour in cocoa production remains a documented concern
- Applicable permits, cooperative registrations, or export authorisations on file and verified as current
Processing and traceability (Articles 4, 9)
- Buying station and pisteur networks mapped — each buying point's contributing smallholders documented
- Cooperative-level aggregation tracked — each cooperative's member farms enumerated and linked to outbound lots
- Post-harvest processing documented — fermentation and drying protocols recorded with batch linkage from wet beans to dried, export-grade cocoa
- Batch or lot identifiers maintained from cooperative through exporter with traceability links at each transfer
- No mass balance applied — the EUDR prohibits mass balance; physical segregation or identity preservation required
Documentation and filing (Articles 4, 9, 12)
- DDS prepared with all required fields under Article 4(2) before the product is placed on the EU market
- All supporting evidence archived and retrievable for the mandatory 5-year retention period (Article 12)
- Evidence chain auditable end-to-end: competent authority can trace from filed DDS to individual smallholder plot through each aggregation stage
- DDS reference number obtained from the EU Information System and linked to shipment and customs documentation
How to use this template
Step 1 — Map your supply chain. Document every tier from source plot to EU market entry: smallholders, pisteurs or buying stations, cooperatives, exporters, and the EU importer. For cocoa, map the buying station and pisteur network first — the collector tier between farmer and cooperative is where traceability most often breaks.
Step 2 — Work through each section. Mark items complete only when documentary evidence exists — not when a process is planned or verbally confirmed.
Step 3 — Close gaps before filing. Prioritise smallholder geolocation, as fragmented buying networks make retroactive farm enumeration extremely difficult.
Step 4 — Review quarterly. New contributing farmers, cooperative changes, and risk reclassifications require reassessment.
How to implement this in your organisation
Assign ownership. Your compliance officer or sustainability manager owns this checklist and is accountable for its completeness. Cooperative managers, buying station supervisors, and procurement staff contribute sourcing and traceability evidence; the export manager reviews the assembled package before DDS filing.
Set the review cadence. Align checklist reviews with buying seasons — October through March for the main crop and May through August for the mid-crop in West Africa — so evidence is current before each season's volumes enter the supply chain. Conduct a full reassessment quarterly and immediately when triggered by a new contributing farmer, a cooperative change, or a country risk reclassification by the European Commission.
Define your escalation path. Any gap identified during review halts DDS preparation for the affected consignment until the gap is closed. The responsible team member escalates unresolved gaps to the export manager within 48 hours, with a documented explanation of the gap and a proposed remediation timeline.
Connect to existing workflows. Integrate smallholder geolocation capture into your farmer registration and cooperative enrolment process so plot data is collected before the first purchase. Link batch traceability and fermentation documentation to your existing QC handover points at buying stations and warehouses, and attach completed checklist evidence to export documentation packages alongside commercial invoices and quality certificates.
Who needs this template
- Cocoa exporters assembling DDS evidence packages for EU-bound consignments
- Cooperatives and processors documenting farmer enumeration, batch traceability, and post-harvest processing linkage
- Compliance officers auditing evidence chains across multi-tier cocoa supply chains before DDS filing
- EU importers verifying upstream evidence meets the standard for a defensible Due Diligence Statement
FAQ
How do I handle traceability through informal buying networks (pisteurs)?
Each farmer selling through a pisteur or buying station must be individually geolocated and linked to the resulting batch. Traceability to cooperative level alone is insufficient — the EUDR requires traceability to the plot of land where the commodity was produced (Article 9(1)(d)).
Does shade-grown or agroforestry cocoa have different compliance requirements?
The compliance requirements are identical. However, shade-grown systems challenge satellite-based deforestation screening: the transition from natural forest to cocoa agroforestry may not appear as deforestation in canopy-based analyses. Operators must ensure their screening methodology can distinguish natural forest from shade-coffee agroforestry established after December 31, 2020.
How does child labour risk factor into EUDR due diligence?
Article 10(2)(j) requires operators to consider concerns in relation to the country of production. Child labour is documented in West African cocoa production. Risk assessments for origins with known child labour prevalence should document how this risk is assessed and what mitigation measures are in place, as it relates to the legal production requirement.
Does completing this checklist mean I am EUDR compliant?
No. This checklist helps identify evidence gaps. Completing every item means you have documented your evidence chain — it does not certify compliance, guarantee a successful regulatory review, or substitute for independent legal counsel. Operators must exercise due diligence and substantiate their DDS with evidence a competent authority can verify.
Cocoa supply chains involve extreme smallholder fragmentation, informal buying networks, and high deforestation rates in key origins that make plot-level traceability the defining challenge for EUDR compliance. A checklist identifies gaps — a platform closes them. Book a demo to see how ResourceLedger provides evidence-grade traceability from smallholder plot to EU port of entry.