EUDR screening for cocoa importers.
Cocoa is the best-traced of the smallholder-heavy Annex I commodities, and even its own sector scorecards report real gaps. Here's how EUDR applies to a cocoa importer, and what a satellite screen adds on top of a farmer-group record.
What counts as cocoa under EUDR
Annex I's cocoa entry covers beans, shells and husks, cocoa paste, cocoa butter, cocoa powder, and chocolate or other food preparations containing cocoa. Cocoa butter in particular shows up outside food entirely: it's a common cosmetics ingredient, which means a cosmetics importer can be an EUDR operator without ever touching a chocolate bar.
- Importing raw beans directly from a cooperative, exporter, or trader at origin makes you the operator: full geolocation, risk assessment, and a Due Diligence Statement per shipment.
- Buying already-processed cocoa mass, butter, or powder from another EU company that already filed a DDS is the lighter downstream-operator path.
- A cooperative can sometimes file its own DDS or act as an authorised representative for its members. If it hands data to you as the EU importer instead, you remain fully liable for its accuracy either way.
Cocoa is the best-traced smallholder commodity, and it's still not fully traced
Independent sector reporting (the Chocolate Scorecard) puts EUDR-bound cocoa volume at roughly 67% traceable to an individual farmer, and 84% traceable at least to a farmer group: the strongest figure of any smallholder-dominated Annex I commodity. Read the other way, a third of EU-bound cocoa still lacks individual farm traceability, and cocoa traded outside the EU-bound direct-trade channels is far less traced. Global indirect cocoa supply sits around 22% farm-traceable, up from 9% two years earlier.
No mass balance means a farmer-group average doesn't help at the shipment level. A cooperative that's "84% traceable to group" can still contain individual, un-geolocated farms in any given container. EUDR looks at the specific plots in your specific shipment, not the cooperative's overall traceability rate.
What a cocoa screening actually shows
Upload your farm, cooperative, or exporter list with coordinates (or names and addresses if that's all your supplier has given you) and every location is checked for forest-cover change signals since 31 December 2020.
One RED plot makes the whole lot RED, unless kept physically separate: the same no-blend rule the regulation itself enforces at the shipment level.
Typical origin countries in this project's own validated cocoa test sites include Ivory Coast, Ghana, Ecuador, Indonesia, and Cameroon. The underlying satellite layers have global coverage, so screening isn't limited to that list.
Agroforestry cocoa is a named false-positive risk here too
Cocoa is very often grown under shade trees, and the sector's larger EUDR-compliance vendors have specifically built and credentialed temporal/seasonal false-positive handling for exactly this reason. That's a signal that agroforestry misreads are a recognized, real problem for cocoa, not a fringe concern.
We don't yet have a confirmed example in our own ground-truth suite of this pipeline misflagging a genuine cocoa agroforestry plot, and extending that coverage is on our roadmap. Until then, treat a RED result on a known shaded cocoa farm as a prompt to check the before/after imagery yourself, not as a final answer.
Screen your cocoa suppliers
Send us your farm, cooperative, or exporter list and get a RED/AMBER/GREEN read back the same day, with before/after imagery for every screenable location. It supports your own Article 10/11 due diligence; it isn't a substitute for it and isn't a Due Diligence Statement.