Reg. (EU) 2023/1115 · large and medium operators from 30 Dec 2026 · micro and small enterprises from 30 Jun 2027 · cut-off 31 Dec 2020.
Cocoa is EUDR's stress test: two countries grow most of the world's supply across millions of smallholder plots, and every consignment entering the EU needs geolocation-backed proof it is deforestation-free. Chocolate makers do not have a sourcing problem — they have an evidence problem, and it starts at the farm gate.
Every producing plot mapped — point coordinates for small plots, polygons for larger ones — before beans can support a due-diligence statement.
No production on land deforested after 31 December 2020, checked against satellite and forest-cover data by operators and authorities alike.
Cocoa is pooled at buying stations, blended at export. The link between mapped plots and shipped lots must survive that pooling — the hardest engineering problem in the regulation.
Operators file due-diligence statements in the EU information system; references follow the beans through grinding and manufacture into chocolate.
Application is live for large operators, with smaller operators following mid-2026. Major chocolate makers are already contractually requiring mapped, verifiable origin from their supply base.
Plot registration works station by station. Prioritize the stations feeding EU-bound volumes and register plots to farmer identities.
Bag or lot identity at the buying station, linked to registered plots at intake, is the only honest way blended beans keep their origin story.
Evidence assembled at export is reconstruction; evidence assembled at intake is proof. Move the verification moment upstream, where the facts are.
Aeroz binds lot identity at the buying station, links it to registered plot geolocation, and writes every custody step — station to warehouse to container — as EPCIS 2.0 events. The due-diligence statement stops being a claim about a blend and becomes a record of what actually went into it. That is the difference between paperwork and proof, and EU authorities are equipped to tell them apart.
From 30 December 2026 for large and medium operators and traders; 30 June 2027 for micro and small enterprises. Cocoa and cocoa products from land deforested after 31 December 2020 cannot enter the EU market.
Both — the commodity scope includes cocoa beans and derived products including chocolate. Manufacturers inherit the due-diligence obligation for the beans inside their bars.
Farm-by-farm registration through cooperatives and buying stations: farmer identity, plot coordinates or polygons, and harvest lots linked to those plots at intake. The mapping is a season of work — which is why it cannot wait.
Mapped plots, due-diligence statement references, and increasingly a verifiable data chain rather than a certificate PDF. Origin that cannot prove itself is already trading at a discount.
A fixed-fee Aeroz audit maps your products against eudr for cocoa requirements and returns a written readiness assessment, a data-mapping review, and a scoped pilot plan with cost and timeline.