As the EU importer filing the Due Diligence Statement, you bear the full legal burden of proof under Article 4. Cocoa presents particular verification challenges: millions of West African smallholders with 2-5 hectare plots, informal buying through pisteurs and buying stations, and origins where Cote d'Ivoire and Ghana are likely to receive standard or high-risk classifications. This checklist helps you verify what your cocoa supplier has provided and flag evidence requiring additional investigation.
What is the EU importer's verification obligation?
Under Regulation 2023/1115, the operator placing a product on the EU market must exercise due diligence — not merely collect evidence, but critically assess it. Article 10 requires evaluation using "adequate and verifiable information." For cocoa, high deforestation rates, smallholder fragmentation, and informal buying networks mean supplier evidence is likely to contain gaps. The competent authority holds the filing operator accountable. If evidence relies on cooperative summaries rather than individual farmer data, the importer must resolve this before filing.
What this template covers
Supplier documentation review
- Verify the supplier has provided individual farmer-level documentation — not cooperative-level summaries
- Confirm documentation identifies every tier: farmers, pisteurs or buying stations, cooperatives, processors, and exporter
- Check internal consistency — farmer names, coordinates, and volumes align across geolocation files, buying station records, and transport documentation
- Verify certifications (Rainforest Alliance, Fairtrade, UTZ) are supplementary only — certifications do not satisfy the EUDR
- Confirm raw evidence files are provided, not just attestation letters
Red flags: Cooperative-level aggregates without individual farmer identification. Single attestation covering the entire consignment. Traceability at "community" or "village" level rather than plot level.
Geolocation data verification
- Verify coordinates are field-captured with GPS devices, not estimated from village names, with collection timestamps and device metadata
- Confirm coordinates use WGS84 (EPSG:4326) at 6-decimal precision
- For plots of 4 hectares or less (most cocoa smallholdings): verify single GPS centroids. For plots exceeding 4 hectares: verify polygon boundaries
- Cross-check a sample against satellite imagery to confirm cocoa-producing land, not forest or built-up areas
- Verify plot count matches the number of individual farmers claimed
Red flags: Round-number coordinates (e.g., 6.000000, -5.500000) — likely estimated. Multiple farmers sharing identical coordinates — copy-paste. Missing timestamps on geolocation records. Coordinates within classified forests or protected areas. Plot count significantly lower than farmers the cooperative claims to represent.
Deforestation-free evidence assessment
- Verify screening uses satellite imagery anchored to the December 31, 2020 baseline
- Confirm screening methodology accounts for the difference between natural forest canopy and shade-grown cocoa canopy — satellite imagery may not distinguish the two
- Verify full-sun cocoa plots are screened separately from shade-grown plots, as full-sun establishment on previously forested land after the cutoff is deforestation
- Cross-reference against at least one independent alert system (Global Forest Watch, GLAD alerts)
- Verify methodology documentation: data sources, imagery provider, resolution, and decision criteria
Red flags: No deforestation alerts in a high-deforestation region — may indicate inadequate methodology. Imagery resolution too coarse for 2-5 hectare plots. No documentation for distinguishing shade canopy from natural forest. No independent cross-referencing.
Legality evidence assessment
- Verify the supplier identified relevant legislation: land use laws, forestry regulations, labour laws (including child labour prohibitions), tax obligations, and community rights including FPIC
- Verify child labour risk is assessed and documented per Article 10(2)(j) — West African cocoa origins have documented child labour concerns
- Confirm legal evidence goes beyond self-attestation — permits, cooperative registrations, or third-party verification on file
- Verify land tenure documentation per farmer — title, customary tenure record, or local authority attestation
- Confirm export authorisations are current for the specific consignment
Red flags: No child labour risk assessment for West African origins. Land tenure based on verbal claims only. Supplier cannot provide cooperative registration details.
Processing and traceability verification
- Verify buying station intake links each delivery to a specific farmer and plot
- Confirm pisteur purchases are individually linked to identified farmers, not aggregated
- Verify cooperative aggregation maintains individual farmer linkage to outbound lots
- Verify post-harvest processing records maintain batch linkage through fermentation and drying
- Check volume reconciliation: outbound should reconcile against inbound within tolerance
Red flags: Volume gaps exceeding 5% unexplained. Cooperative summaries despite claims of farmer-level traceability. Mass balance language anywhere — EUDR prohibits mass balance (Article 9). Uniform weights from all farmers (suggests estimated measurements).
Risk assessment and DDS readiness
- Verify the risk assessment covers all Article 10 factors, including child labour for West African origins
- For Cote d'Ivoire and Ghana: confirm enhanced due diligence measures are documented
- Confirm the "negligible" conclusion is supported by evidence, not merely asserted
- Verify documented mitigation measures were implemented before shipment where risks were identified
- Confirm evidence is archived for the 5-year retention period (Article 12)
How to use this template
Step 1 — Request the full evidence package. Ensure your supplier has provided individual farmer-level geolocation, screening reports, legality evidence (including child labour assessment), and traceability records linking each farmer through the buying chain to the export lot. For cocoa, verify individual farmer data exists behind cooperative summaries — aggregate data at the cooperative level does not satisfy Article 9.
Step 2 — Work through each section. Mark items verified only when independently confirmed. Focus on whether data is truly at individual farmer level, not cooperative aggregates presented as farmer-level data.
Step 3 — Escalate red flags. Any red flag requires additional investigation. Do not file a DDS with unresolved red flags.
Step 4 — Document your verification. Record what you checked and how you resolved issues. Your verification process is itself due diligence evidence.
How to implement this in your organisation
Assign ownership. Your EU compliance officer owns the checklist end-to-end, from receiving the supplier evidence package through to the filing decision. Procurement acts as the first filter, performing a completeness check on each incoming package before forwarding it for substantive review. An internal auditor should review the compliance officer's verification work at least annually to confirm procedures are followed consistently.
Set the review cadence. Run this checklist for every consignment before filing the DDS — per-consignment review is non-negotiable. Conduct a full supplier re-assessment annually, and trigger immediate re-verification whenever a supplier reports changes to their farmer base, buying station network, or cooperative structure. Cross-check buying season dates against delivery dates for each consignment to detect temporal mismatches — cocoa delivered outside the expected harvest window for a stated origin warrants investigation.
Define your escalation path. Any red flag identified during verification pauses the DDS filing immediately. Procurement holds the next payment milestone until the issue is resolved. If a red flag remains unresolved within 30 days, escalate to the head of compliance or legal counsel. Document every escalation, including the date raised, parties involved, and resolution or outcome.
Connect to existing workflows. Embed the evidence specification directly in purchase contracts so suppliers know what to provide before shipment — particularly the requirement for individual farmer-level data, not cooperative-level summaries. Gate customs release on checklist sign-off — no signed-off checklist, no release authorisation. Integrate QC inspection at port with the verification process so that physical quality assessment and documentation review happen as a coordinated step rather than separate procedures.
Who needs this template
- EU importers verifying cocoa supplier evidence packages before filing a DDS
- Compliance officers assessing whether upstream evidence from smallholder-fragmented origins supports a defensible Due Diligence Statement
- Procurement managers evaluating supplier evidence quality for West African or other high-deforestation-risk origins
Does completing this checklist mean my DDS will pass?
No. Completing every item means you have systematically reviewed the evidence — it does not certify compliance, guarantee a successful regulatory review, or substitute for independent legal counsel. The competent authority assesses the substance of your evidence, not whether you completed a checklist.
What if my supplier provides cooperative-level data but not individual farmer data?
Cooperative-level summaries are insufficient. The EUDR requires geolocation to the plot of land where the commodity was produced (Article 9(1)(d)). Require individual farmer and plot data or decline the consignment.
How should I evaluate child labour risk for West African origins?
Article 10(2)(j) requires considering "concerns in relation to the country of production." Child labour in West African cocoa is documented and well-established. Your risk assessment must explicitly address this. Silence on child labour in a West African cocoa risk assessment is itself a red flag.
Do certifications like Rainforest Alliance or Fairtrade satisfy EUDR verification?
No. Certification schemes may provide supplementary information but do not satisfy the EUDR. The regulation requires operators to conduct their own due diligence, file their own DDS, and maintain their own evidence.
Cocoa verification demands that EU importers look beneath cooperative-level summaries to confirm individual farmer evidence across fragmented West African supply chains. A checklist structures the review — a platform automates the verification. Book a demo to see how ResourceLedger helps EU importers verify supplier evidence with audit-grade traceability from smallholder plot to port of entry.