For cocoa exporters, processors, traders, and brands, this update serves as a signal to fine-tune compliance systems now, ahead of the 30 December 2025 enforcement date for large and medium-sized companies.
Why This Matters
The EUDR requires that all cocoa and other key commodities placed on the EU market or exported from it must be:
- Deforestation-free
- Legally produced
- Fully traceable to the plot of land via geolocation data
With this latest update, the Commission is pushing for harmonised implementation across all Member States - reducing grey areas and aligning expectations for operators and authorities.
Key Changes in the 12 August 2025 Guidance
- Clearer Risk Definitions – More detail on what constitutes ‘negligible,’ ‘standard,’ and ‘high’ risk, making it easier to categorise suppliers and origins.
- Streamlined Due Diligence – Confirms measures to cut costs and complexity, such as:
- Reusing due diligence statements (DDS) for re-imports.
- Exemptions for service providers, such as freight forwarders.
- Group company compliance responsibilities clarified.
- Alignment With Risk Country List – High-risk origins (e.g., Belarus, Myanmar, Russia, North Korea) will face more stringent checks, while low-risk countries will see lighter scrutiny.
EUDR Timeline & Compliance Deadlines
Anthony Myers
Implications for the Cocoa Sector
- Origin Countries in Focus – Most cocoa origins will fall under ‘standard risk,’ meaning 3% of imports will be subject to checks.
- Tech Readiness is Critical – Digital traceability tools and interoperable geolocation systems will be essential to meet compliance requirements.
- Market Access Risk – Non-compliance could mean lost access to the EU market, fines, and reputational damage.
Action Points for Stakeholders
- Exporters & Co-ops – Train field teams on geolocation collection and ensure documentation is in place.
- Traders & Processors – Align internal risk assessment frameworks with the new definitions; prepare to justify ‘negligible risk’ claims.
- Brands & Retailers – Audit supplier readiness and invest in end-to-end digital traceability.
- Authorities & NGOs – Use the guidance to build awareness campaigns and support smallholder compliance.
Calls for More Clarity
The update was published a week after EU food importers reportedly sought clarity on the EUDR, amid speculation about the possibility of reopening the file.
In June, the European Parliament backed an amendment to relax the rules, which won the support of Christophe Hansen, the European Commissioner for Agriculture and Food.
News website euractiv.com reports that the Environment Commissioner, Jessika Roswall, has the final say, and Hansen confirmed in July that no decision had been made on easing or delaying the regulation.
‘Potential changes could be included in a simplification package aimed at farmers and foresters due this autumn’
CocoaRadar understands that the update welcomes clarification on how the EUDR relates to the CSDDD legislation. Writing on LinkedIn, Andreas Rasche, Professor and Associate Dean at Copenhagen Business School, said: “And if there is a conflict between the two, the EUDR takes precedence - because it is more specific - as long as both aim at the same objective.”
CocoaRadar’s Bottom Line
This guidance is more than a legal update - it’s the Commission setting the tone for how it expects the EUDR to operate in practice. For cocoa, the clock is ticking. The winners will be those who act now, building transparent, verifiable, and low-risk supply chains before enforcement begins.
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