EUDR and cocoa from Peru: what it requires and what your supplier must deliver.

What the regulation requires for cocoa

Regulation (EU) 2023/1115, known as the EUDR, has covered cocoa from the start, together with its products: beans (code 1801), shells (1802), paste (1803), butter (1804), cocoa powder (1805) and chocolate (1806). To sell them in the EU, three things must be proven:

1. Deforestation-free: the cocoa does not come from land deforested after 31 December 2020.
2. Legality: the cocoa was produced in line with Peruvian law (land tenure, environment, labour).
3. Geolocation: the coordinates of every plot the cocoa came from.

Every product and its code is listed in EUDR Annex I.

The dates

The May 2026 review simplified procedures but kept these dates. In practice you need the data earlier to prepare your statement: cocoa arriving in Europe in 2027 is already being contracted on that condition.

Will it be delayed again? See the EUDR timeline and latest news.

Point or polygon: how each plot is recorded

Coordinates are delivered as GeoJSON, the format accepted by the EU information system.

Shade-grown cocoa: when the map mistakes a cocoa farm for forest

If the cocoa grows under shade trees, in an agroforestry system, it is not forest for the EUDR: the regulation counts agroforestry systems as agricultural plantations and excludes them from the definition of forest.

The problem is that on a satellite image, a shaded cocoa farm can look like forest. The EU's own 2020 forest map states that it is not mandatory or legally binding. And a study by Germany's Thünen Institute (2025) reviewed 600 coffee plots of 1 to 5 hectares in Mexico: according to the maps, three out of four did not comply, even though many had been farmed for decades. That is why your suppliers should keep evidence for each plot that it was already farmland before 2021: photos, cooperative records and historical satellite images.

Who does what

1. The farmer and the cooperative record the plots and keep the evidence for each one.
2. The exporter pools that data per shipment and hands it to the buyer.
3. The EU operator, usually the importer, files the due diligence statement in TRACES and is legally accountable to its competent authority.
4. The chocolate maker in Europe that uses cocoa already covered by a statement does not file another one: it keeps the reference number of the importer's statement.

How it works, step by step: the EUDR due diligence statement (DDS) in TRACES.

The real problem: collection centres pool cocoa from dozens of farmers

A cocoa lot almost never comes from a single plot: at the collection centre, beans from many farmers are pooled to be fermented and dried. If a single plot does not comply, that cocoa cannot be mixed with compliant cocoa, and the European Commission does not accept mass balance with cocoa of unknown origin. That is why every plot should be verified before the shipment is assembled, not when you are already asking for the data.

How Origen solves it

The cooperative's technician records each plot on a phone, even without signal. Origen checks it against four open satellite sources, including the EU's own 2020 forest reference map, and generates one dossier per shipment with a TRACES-ready GeoJSON. If a plot is flagged, it tells you which one, so it can be excluded or substantiated.

Origen does not certify: it delivers verifiable evidence for your due diligence statement.

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