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The Cocoa Visibility Paradox: Compliance Is Scaling — Verification Is Not

CocoaRadar Exclusive: As the cocoa sector prepares for the unveiling of Farmforce’s latest findings in its First Mile Traceability Barometer, at Chocoa, one message is unmistakable: the industry has mobilised around traceability — but the foundations remain fragile

Image shows a farmer pointing to a tablet with traceability data for Farmforce
According to Farmfoce's Barometer, the ‘human layer’ of traceability is largely in place. Image: Farmforce

What looks like rapid progress on paper may conceal a deeper structural vulnerability, the Barometer reveals.

The Industry Has Moved — But Onto Unstable Ground

In just three years, cocoa has dramatically expanded farm-level traceability claims. Today, 77% of actors report high visibility, a sharp rise from 2023. At face value, this suggests a sector accelerating toward EU Deforestation Regulation (EUDR) compliance.

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But the Farmforce data tells a more complicated story.

The result is what the report terms the Traceability Paradox: the industry increasingly knows who its farmers are, but not precisely where their farms are located. In a regulatory environment that hinges on geospatial verification, this gap is not technical — it is existential.

Traders Are Compliance Engines. Producers Are Hitting a ‘Paper Ceiling’

The EUDR has polarised the supply chain.

Traders and processors have emerged as the fastest-moving segment:

Producers, however, face a different reality:

The bottleneck has shifted. In 2023, the challenge was technological capability. In 2026, it is financial capacity.

This ‘Paper Ceiling’ prevents satellite verification, slows audit readiness, and increases the risk of exclusion from EU markets. Compliance is no longer a matter of willingness — it is a question of capital.

The New Bottleneck: Data Quality, Not Data Collection

According to the Barometer, The ‘human layer’ of traceability is largely in place:

But precision mapping and verification quality lag significantly.

Most requested support areas, according to the report:

This shows that the sector has mastered the art of collecting names. It has not yet professionalised spatial data. Furthermore, without robust polygon accuracy, quality controls, and documented tenure rights, traceability claims may collapse under a forensic audit.

EUDR: Stress Test and Strategic Inflection Point

The EUDR has acted as a catalytic stress test.

The greatest burden is administrative and legal — not technological. Training, documentation systems, and verification standards now determine market access.

Cooperatives face a stark choice: achieve full compliance or risk exclusion from EU trade flows.

Beyond Deforestation: The Rise of Regenerative Agriculture

If Phase 1 was about identifying farmers and Phase 2 about mapping farms, Phase 3 is emerging rapidly: value creation through regenerative agriculture.

But regenerative agriculture requires far more than traceability. It demands advanced farm management systems capable of tracking:

The infrastructure built for EUDR could become the backbone of long-term resilience — if it is upgraded beyond minimum compliance.

A New Risk on the Horizon

While the industry scrambles to meet EUDR requirements, another regulatory wave is forming.

36% of traders remain unaware of the EU Digital Product Passport (DPP).

Without proactive education and alignment, the sector risks repeating reactive compliance cycles — shifting from one regulatory shock to the next without structural consolidation.

“The data suggests we’re sleepwalking into the next issue. The industry is so consumed by the administrative burden of EUDR that 36% of traders - typically the most prepared group - haven't yet heard of the Digital Product Passport. If the leaders are blind to this, another reactive shock seems inevitable,” said Arnaud Dupuis, Head of Marketing at Farmforce.

CocoaRadar’s Takeaway

The cocoa sector has successfully mobilised around traceability. It has not yet mobilised around verification quality. 2026 marks a decisive strategic inflection point:

As Farmforce highlights, the winners will not be those who merely comply with EUDR. They will be those who convert compliance systems into a long-term digital, operational, and sustainability advantage.

Cocoa’s visibility problem is no longer about transparency. It is about precision. And precision now determines market access.


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