What EUDR Actually Requires From You
The EU Deforestation Regulation (EUDR) says any cocoa entering the EU market must come from land that wasn't deforested after December 31, 2020. That's it — that's the core rule. In practice, it means your EU buyers can no longer take your word for where the cocoa came from. They need documented, verifiable proof, and they'll be asking you for it before they place an order.
The Deadline
December 30, 2026 for large and medium operators and traders. June 30, 2027 for micro and small enterprises. This is later than originally planned — the EU pushed the date back from December 2025 via Regulation (EU) 2025/2650, passed in December 2025. If you were told the deadline was 2025, that information is out of date.
What You Need Ready — The Checklist
1. Plot-level geolocation data for every farm your cocoa comes from — GPS coordinates or a mapped boundary, not just a district or region name.
2. Proof the land wasn't deforested after December 31, 2020 — satellite-verifiable land history, not a verbal assurance from the farmer.
3. A completed Due Diligence Statement (DDS). If you're a downstream, non-SME operator under the 2025 simplification, you may only need to retain your supplier's original DDS reference number rather than filing a new one.
4. A documented risk assessment for each sourcing region — what makes that region higher or lower risk for deforestation.
5. Five years of records retained and ready to hand over the moment an authority or buyer asks.
What Changed in 2025 (And Why It Matters For You)
In December 2025, the EU simplified how downstream due diligence works. Non-SME buyers further down the supply chain no longer file a duplicate DDS — they just keep your original DDS reference number on file. Micro and small primary operators in lower-risk countries can use a single simplified declaration instead of a full statement. For a smallholder cooperative, this means less paperwork. For a larger exporter, it means the opposite: your DDS now gets reused by everyone downstream, so it has to be right the first time — there's no second filing further down the chain to catch a mistake.
What Happens If You're Not Ready
Non-compliant cocoa can be blocked at the EU border. Importers who accept it face fines reported at a minimum of 4% of their EU-wide annual turnover, confiscation of the goods and any revenue from them, and possible exclusion from public contracts. In practice, that means an EU buyer simply won't take the risk on a supplier who can't produce clean documentation — they'll source from someone who can.
See This Working in a Real Cocoa Supply Chain
reGenesis already captures plot-level geolocation, deforestation-cutoff documentation, and due diligence records for cocoa exporters — built with Telcar Cocoa, Cameroon's largest cocoa exporter, across 40,000 farmers.
Read the Telcar Cocoa case study →
