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:
- EU companies with over 1,000 employees and a global net turnover exceeding €450 million.
- Non-EU companies generating more than €450 million in the EU market.
These companies are required to:
- Integrate due diligence into their corporate policies.
- Identify actual or potential adverse human rights and environmental impacts.
- Prevent or mitigate potential impacts and bring actual impacts to an end.
- Establish and maintain a complaints procedure.
- Monitor the effectiveness of their due diligence policies and measures.
- Publicly communicate on due diligence.
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."

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.
- The Cocoa Coalition is an informal group of companies (Ferrero, Hershey, Mars Wrigley, Mondelēz International, Nestlé, Toms Group, Tony’s Chocolonely, Unilever), certification organisations (Fairtrade International, Rainforest Alliance), NGOs (Fair Trade Advocacy Office, VOICE Network, Solidaridad) and multi-stakeholder organisations (International Cocoa Initiative).
cocoaradar.com is:
- Official Media Partner - World Cocoa Foundation Partnership Meeting in São Paulo, Brazil, 19-20 March 2025.
- Official Media Partner - Amsterdam Sustainable Cocoa Conference, Chocoa, 4-9 February 2025.
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