COMMODITY · COCOA · HS 1801–1806

Cocoa under the EUDR.

From beans to chocolate — the whole Chapter 18 chain is in scope, and most of it starts on smallholder plots under 4 hectares.

FIG 01 — YOUR OBLIGATIONS

Three facts before anything else.

SCOPE

HS 1801–1806

Cocoa products under the listed HS codes — plus listed derivatives. Representative table below; the current Annex I is the boundary.

GEOLOCATION

POINT ≤4 HA · POLYGON >4 HA

Smallholder reality: plots of 2–5 ha qualify for points; the work is collecting one per farm across thousands of cooperative members.

DEADLINE

30 DEC 2026 / 30 JUN 2027¹

Bean traders to chocolate makers: micro/small prepare for 30 Jun 2027, medium/large for 30 Dec 2026, per Regulation (EU) 2025/2650.

D-0 · 30 DEC 2026D-0 · 30 JUN 2027

¹ Regulation (EU) 2025/2650.

FIG 02 — WHAT'S IN SCOPE

The Annex decides, not the label.

The cocoa chapter of Annex I spans the whole processing chain — from raw beans to finished chocolate — and has applied since Regulation (EU) 2023/1115 as amended.

No July 2026 removals touched cocoa’s listed products as amended; the chain from 1801 to 1806 stands. Confirm the current Annex I for your exact code.

HS CODEPRODUCT NOTE
1801Cocoa beans, whole or broken, raw or roasted
1802Cocoa shells, husks and skins
1803Cocoa paste (liquor)
1804Cocoa butter, fat and oil
1805Cocoa powder, unsweetened
1806Chocolate and cocoa food preparations

REPRESENTATIVE CODES ONLY — ALWAYS CONFIRM AGAINST THE CURRENT ANNEX I OF REGULATION (EU) 2023/1115 AS AMENDED.

FIG 03 — GEOLOCATION RULES

One threshold, two formats.

≤ 0 ha

POINT ALLOWED

A single WGS84 coordinate at six decimal places locates plots of 4 ha or less.

> 0 ha

POLYGON REQUIRED

Plots above 4 ha need a closed vertex ring tracing the full boundary.

COCOASmallholder reality: plots of 2–5 ha qualify for points; the work is collecting one per farm across thousands of cooperative members.

FIG 04 — SUPPLY-CHAIN REALITY

Cocoa is a smallholder crop: in Côte d’Ivoire and Ghana — roughly two-thirds of world supply — typical farms are 3–5 ha, at or below the 4-hectare polygon threshold. That means points, not polygons, for most of the supply base.

The friction is aggregation. First-buying stations and cooperatives mix beans from hundreds of farms within hours of harvest. By fermentation and drying, a single lot already carries many plot origins — and the DDS wants every one of them.

Cooperatives that collect member coordinates once — at registration, with a phone GPS app — convert an impossible per-lot task into a per-member one. Polygons still matter for larger estates and expanding farms.

For chocolate makers, the chain multiplies again through processors and traders; keeping DDS reference numbers from suppliers is what keeps the chain traceable.

The hard part isn’t the satellite check — it’s getting polygons from ten thousand smallholders.

KEY RISK — COCOA

Lot mixing at buying stations means one bag can carry beans from dozens of plots. Collect plot geolocation at farmgate or cooperative intake — not after blending.

FIG 05 — SCREEN A COCOA PLOT

See it run on a real-shaped plot.

The scope-checker validates the geometry, screens it against open satellite datasets, and returns an indicative signal summary — one plot, free, no card.

Screen your cocoa plot — free

SAMPLE PLOT

CÔTE D’IVOIRE · SMALLHOLDER PLOT · POINT

5.3512, -4.0283

NO SIGNAL DETECTED0.02 ha / 12 mo

DATASET: WHISP · HANSEN GFC v1.11 · GLAD ALERTS

Indicative screening for decision-support only — not a compliance determination, certification, or legal advice. Due-diligence obligations remain with the operator (EUDR Art. 10). · DEMO RESULT — configure the Whisp API in admin settings for live screening.

FIG 06 — QUESTIONS

Asked about cocoa.

COCOA · SCOPE-CHECKER

Screen your cocoa plots.

Free, one plot, indicative screening in about two minutes — prefilled for this commodity.

Run the scope-checker — free

Indicative screening for decision-support only — not a compliance determination.