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Trump's Forced-Labour Tariffs Largely Spare Cocoa, but Risks Remain for Origin Processing

Special report: New US tariffs on 60 trading partners exempt cocoa beans and most semi-processed cocoa products. Finished chocolate exports, however, may still face additional duties – raising fresh questions for cocoa-producing countries seeking to move up the value chain

Image shows stacks of colourful containers on a crago ship.
The tariff initiative has already prompted some government action to fight forced labour. Image: Teng Yuhong / Unsplash

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The latest US tariff regime has raised concerns across global commodity markets, but its direct impact on cocoa-producing countries appears more limited than the headline tariff rates of 10% and 12.5% suggest.

The tariffs took effect on 24 July following a US Trade Representative (USTR) investigation into whether trading partners have adopted and effectively enforced prohibitions on imports produced with forced labour. The Trump administration says the measures are intended to encourage stronger action against goods linked to forced labour entering international supply chains.

However, the final USTR notice explicitly exempts several key cocoa products from the additional duties. These include cocoa beans, cocoa paste, cocoa butter, and unsweetened cocoa powder.

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For the cocoa sector, the distinction between exempt intermediate products and potentially exposed finished products could prove significant.

Major Cocoa Products Exempted

The exemptions cover Harmonized Tariff Schedule (HTS) headings 1801–1805, including:

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