EUDR guide for exporters
EUDR guide for cocoa exporters
Under the EU Deforestation Regulation (Regulation (EU) 2023/1115), the company that brings your cocoa into the EU has to collect your plot data before the goods reach customs. This guide sums up what it will ask you for. Print it or save it as a PDF and share it with your team.
Which products are covered
Cocoa beans, shells and other cocoa waste, paste, butter, powder and chocolate (headings 1801 to 1806).
What is specific to cocoa
- The list of growers who supplied that container, with name, country and region, and one point or polygon per plot. A point with two decimal places can be more than a kilometre off and is not valid.
- Traced cocoa has to stay separate in the warehouse and at the port. Mass balance (mixing and then allocating) is not enough for the EUDR.
- Proof of legality covers land rights and the environmental and labour law of the country of production. Child labour is a known risk in cocoa and falls under the labour law that has to be checked.
What a cocoa buyer will ask you for
Container and bag lots
The container your buyer will declare and the warehouse or bag lots it was filled from.
Purchase records from buying centres
Weighing slips or purchase registers showing which growers sold the beans in those lots, with dates and weights.
Farmer and plot register
One line per plot: grower name, plot name or code and area in hectares. A grower with several plots has one line for each.
The plot file
GeoJSON with a point for each plot up to 4 ha and a polygon above that, six decimals, and ProducerName and ProducerCountry on each Feature.
How traced beans are kept apart
Where traced beans are stored, how the bags are marked and how they reach the port without being mixed with beans bought on the open market.
Crop and purchase dates
Main crop or mid crop and the purchase dates, which set the production period.
Legality documents
Land rights documents and what you hold on environmental and labour law, child labour included. Your buyer decides what it needs.
Example: a cooperative ships one container of beans
A cooperative buys beans from its members at several buying centres during the main crop. Every purchase is weighed and written down with the grower’s name. Beans from members with mapped plots are bagged, marked as traced and stored apart from beans bought from passing traders.
When a container is filled for an EU buyer, the cooperative lists the bag lots that went in and, from the purchase records, the growers behind them. The GeoJSON for that container holds only those growers’ plots: points for most of them, polygons for any plot above 4 ha.
The buyer receives the file, the grower list, the crop period and the legality documents, checks the plots against the cut-off date of 31 December 2020 and files its statement. If one bag of unmarked beans went in, the container is no longer covered.
Mistakes that get cocoa data sent back
- Points with too few decimals copied from an old survey. With two decimals a point can be more than a kilometre off.
- Topping up a traced container with beans bought on the open market to reach the weight.
- One point for a grower who farms several separate plots. Each plot needs its own entry.
- Names spelled one way in the grower list and another way in the GeoJSON, so the buyer cannot match them.
Key dates
- 31 December 2020: cut-off date. Land deforested after this date cannot supply the EU market. It does not move with the postponements.
- 30 December 2026: large and medium-sized EU companies must comply, and so must every company for timber products that were under the old EU Timber Regulation.
- 30 June 2027: micro and small EU companies.
Questions from cocoa exporters
Ghana is classified low risk. Do Ghanaian exporters still send plot data?
Yes. Low risk spares the buyer the risk assessment and mitigation (simplified due diligence), but the geolocation of every plot is still part of the statement.
We sell cocoa paste, butter and powder, not beans. What does the buyer need?
The same plot data, traced back through your production batch to the bean lots that went into it. Paste, butter and powder are in Annex I like the beans, so each batch has to be linked to its beans and their plots.
A grower has farmed the same land for decades but has no land title. Can the plot go in?
Legality covers land use rights under the law of your country. Send the documents that exist locally for how the plot is held and explain the situation. Your buyer decides whether that is enough for its legality check.
Do cocoa shells and husks need plot data too?
Yes, when they are sold under heading 1802 (shells, husks, skins and other cocoa waste). That heading is in Annex I.
The basics, for every product
Whatever the product, the EU buyer needs the same base data: where each plot is (a point up to 4 ha, a polygon above, six decimals), who produced there and in which country, when it was harvested, and information showing that the land was not deforested after 31 December 2020 and that production followed the law of your country.
How to prepare this data and share it with all your buyers