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Cocoa Coalition pleads with Brussels not to do an EUDR and stick to original CSDDD mandate

A collective of companies, NGOs, and organizations involved in the cocoa value chain has sent a letter to Ursula von der Leyen, president of the European Commission, outlining concerns about proposed discussions that may impact the Corporate Sustainability Due Diligence Directive (CSDDD)

The companies and organistions that make up the Cocoa Coalition.

The cocoa coalition has consistently called for EU-wide due diligence legislation since its joint paper in 2019. In a letter to the EC president and key commissioners, the coalition said: “We call upon the European Commission not to undertake any modification of the adopted text of the CSDDD, nor to reopen it for renegotiation by the co-legislators.”

What is the CSDD?

The CSDDD was officially adopted by the European Parliament and the Council of the European Union on 13 June, 2024, as Directive (EU) 2024/1760.  This directive mandates that large companies operating in the EU and certain non-EU companies with significant EU market activities identify and address adverse impacts of their operations on human rights and the environment. 

Scope and Requirements

The directive applies to:

These companies are required to:

As of 21 January, 2025, the directive has been formally adopted and is being implemented across member states. However, depending on the size of the company, the obligations will come into force over three to five years, starting from 2027, beginning with the largest. 

This new regulation will compel global companies to address modern slavery in their supply chains, highlighting the directive’s role in enhancing corporate accountability. 

Some sectors have expressed concerns about the administrative burden imposed by the directive. 

EU Commissioners plan to discuss the Omnibus package and proposal on 26 February 2025. The Omnibus would form part of the “simplification revolution” envisaged by the new EU competitiveness deal.

There has been some concern since von der Leyen’s announcement that the introduction of the Omnibus could lead to attempts to scale back some or all of the core reporting requirements of the CSDDD.

 A spokesperson for the European Commission said it is currently assessing ‘various files’ for inclusion in the proposal.

It is understood that some commissioners are advocating to freeze the package, while industry and economy commissioner Valdis Dombrokski is pushing to advance it.

In its letter, the Cocoa Coalition said: "In our view, the current CSDDD represents an important step forward in driving the necessary transformation of the cocoa and chocolate sector and in making human rights and environmental due diligence the norm in global value chains."

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Towards the end of last year, political meddling by some European Members of Parliament (MEPs) caused the EU's flagship Deforestation Regulation to be postponed by 12 months. The cocoa sector has been here before. The EUDR was also widely supported and yet again it appears that due diligence mandates introduced by the EU, are being forestalled - by its own members.


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