Cocoa Coalition’s joint position on the European Commission’s Deforestation regulation

Thursday, 24 March 2022

The Cocoa Coalition believes that the European Commission’s proposed Regulation on Deforestation represents an important step forward in driving the necessary transformation of the cocoa and chocolate sector.

As a coalition of companies, certification organisations, NGOs and multi-stakeholder organisations operating in the cocoa and chocolate sector, we have consistently called for the EU to introduce mandatory obligations of due diligence extending throughout the supply chain.

We welcome many elements of the regulation, including the application of the due diligence requirements throughout the cocoa and chocolate supply chain within the EU, and the inclusion of the requirement for full geolocation information on the origin of the products covered by the regulation.

We believe it could be further strengthened through the following steps, explained in more detail in the attached position statement:

– A strengthening of the requirements on the Commission to develop partnerships with producer countries, recognising that effectiveness of the legislation will be limited unless it is coupled with the creation of the enabling environment required to address the root causes of deforestation.
– The Commission should conduct a comprehensive needs assessment of the challenges that will be faced by smallholder farmers in complying with the regulation; this should not wait for the regulation to enter into force. 
– The scope of the regulation should be extended to other natural ecosystems as well as forests.
– The threshold company size should be changed to from SMEs to micro-enterprises.
– Operators should be obliged to engage with relevant stakeholders, including smallholder farmers, as part of the due diligence procedure, and measures should be required to ensure that the ownership of the geolocation data provided as part of the information requirements remains with the farmers.
– The benchmarking analysis should be extended to include a wider range of elements in the producer country.