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Carbon Compliance

Carbon Compliance or Climate Colonialism? The EUDR–Carbon Nexus in Cocoa Landscapes

Analysis: As the European Union’s ambitious European Deforestation Regulation (EUDR) rolls out globally by the end of the year, an unlikely battleground has emerged: cocoa landscapes in West Africa and beyond

,   and  Anthony Myers
4 min read
Image shows a mock-up of significant untapped carbon sequestration potential in a tropical forest.
Growing cocoa beneath a canopy of shade trees – holds significant untapped carbon sequestration potential, according to emerging academic research. Image: PHLAIR / Unsplash

Built to curb deforestation and embed sustainability into supply chains, the EUDR’s compliance mechanisms now intersect with carbon sequestration efforts – and critics warn the result may create new forms of climate inequality rather than deliver climate justice.

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Ahead of a major conference in London next week to discuss this topic in a panel moderated by cocoaradar editor Anthony Myers, this exclusive report probes a core tension: Does EUDR advance climate goals by recognising cocoa agroforestry as carbon sinks - or does it deepen structural imbalances that leave smallholder farmers with the costs while Western markets reap the environmental credits?

Drawing on academic research, civil-society critiques, and real-world implementation data, we unpack the ambitions and blind spots of this landmark policy at the crossroads of climate, trade and global power.

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A Regulation with Global Reach and Local Stakes

The EUDR – formally the EU Regulation on Deforestation-Free Products – mandates that certain commodities sold in the EU, including cocoa, must be free of deforestation and forest degradation after 31 December 2020. Companies must prove supply chain due diligence, including geo-tagging and traceability of origin plots. 

Originally celebrated as a breakthrough for forest and climate protection, the law’s implementation has been delayed and weakened amid political pushback and industry pressure. Critics argue that changes dilute enforcement and introduce uncertainty for businesses and producer countries alike. 

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Background and rolling updates on the *DELAYED* European Deforestation Regulation (EUDR) with expert comments and analysis
From The Desk of CocoaRadar™Anthony Myers

For cocoa producers – particularly in Côte d’Ivoire and Ghana, which together supply the majority of the world’s beans – EUDR compliance isn’t abstract policy. It shapes market access, impacts trade flows, and channels financial and technical support into traceability systems and forest-related requirements. 

Agroforestry and Carbon: Lost in Translation?

Agroforestry – growing cocoa beneath a canopy of shade trees – holds significant untapped carbon sequestration potential, according to emerging academic research. A 2024 study finds that West African cocoa landscapes, if managed with tree cover in mind, could offset a substantial share of the sector’s carbon footprint without reducing yields. 

Yet the EUDR’s framing centres primarily on deforestation avoidance rather than climate contribution through carbon storage. Under the regulation, what matters is whether land was cleared after 2020, not the ongoing carbon sequestration performance of existing cocoa systems. This gap risks leaving agroforestry practices – many of which enhance carbon stocks and biodiversity – insufficiently recognised in compliance frameworks.

As one practitioner’s guide explains, detecting “agroforestry or shade-grown cocoa” within regulatory systems remains technically challenging, creating blind spots that exclude carbon-rich systems from formal credit or premium pricing mechanisms. 

Climate Colonialism? Unequal Costs and Claims

Some scholars frame EUDR’s global enforcement as a form of green or climate colonialism. Research applying a ‘Green Colonialism–Development Theory’ lens suggests that compliance costs disproportionately burden smallholders and national economies while European actors shape rules without fully integrating producers’ priorities or benefits. 

Under EUDR, smallholder farmers face expensive traceability requirements; in Côte d’Ivoire, for example, cooperatives report costs as high as $100 per ton of cocoa to meet compliance metrics—with little consistent financial support. 

Meanwhile, carbon markets and voluntary climate initiatives like REDD+ have historically struggled with integrity and equity. Forestry-based carbon credits often suffer from issues like ‘phantom credits’ permanence uncertainties and benefit distribution gaps, raising concerns about whose climate contributions are recognised—and rewarded. 

Critics argue that if cocoa landscapes’ carbon sequestration is not formally recognised or monetised, the climate benefits accrue invisibly to major consuming markets while producers shoulder compliance costs.

The Promise and Limits of EUDR’s Climate Logic

Proponents of the EUDR maintain the law can reduce global deforestation and embedded carbon emissions tied to EU consumption - cocoa included. By making deforestation-free supply chains a legal requirement, the EU aims to reduce its contribution to forest loss and biodiversity collapse. 

But deforestation avoidance and climate mitigation via carbon storage are not the same. To fully harness the climate potential of cocoa landscapes, policies must evolve to value carbon sinks – particularly shade-grown systems that combine production with robust ecosystem services like biodiversity and soil health.

Emerging work on policy principles for sustainable land systems stresses the need for integrated approaches that balance livelihood security, equity, climate mitigation and biodiversity outcomes rather than single-issue compliance. 

What’s Next? Toward Equitable Recognition

For cocoa-producing countries, the challenge is twofold: meeting current regulatory demands while advocating for frameworks that recognise agroforestry’s climate value and distribute benefits equitably. Civil society and producer networks argue that compliance must be paired with capacity building, financial support, and co-created metrics that recognise carbon sequestration and social justice alongside deforestation avoidance.

Whether the EUDR becomes a template for inclusive global climate governance or deepens divides between consuming and producing regions will depend on how emerging issues like carbon accounting, agroforestry valuation, and equitable benefit sharing are addressed in the next phase of policy design and market mechanisms.

CocoaRadar's Takeaway

In summary, the EUDR represents a significant step in linking trade and environmental protection – but stopping deforestation alone won’t unlock cocoa landscapes’ climate potential. Without explicit recognition of carbon sequestration and the fair distribution of compliance costs and climate benefits, the law risks reinforcing patterns in which the planet’s richest carbon sinks are preserved at the economic expense of those who steward them.

Further reporting draws on a University of Oxford expert comment on cocoa market volatility and climate risks.  https://www.ox.ac.uk/news/2025-12-15-expert-comment-why-has-price-chocolate-become-so-volatile

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