Sustainable cocoa sourcing under the EUDR Maximizing benefits for planet and people – research dialogue results, WCC Brussels, Belgium POLICY BRIEF No. 97 Background The European Union Deforestation Regulation (EUDR) stands out as a tangible opportunity to catalyze positive changes within the cocoa sector, emphasizing the need for companies to adopt traceability solutions down to the plot level to ensure they are not contributing to deforestation. The Sustain Cocoa Research Dialogue in Brussels brought together stakeholders and researchers to discuss opportunities for livelihoods, climate and biodiversity. Policy recommendations • Leverage data availability: Anonymized data should be made available to national governments, farmer organizations, and NGOs to support monitoring of compliance, the provision of advisory services, and the development of landscape conservation initiatives. • Embrace agroforestry systems: The EUDR should be complemented by positive incentives and funding for the conservation and creation of those cocoa agroforestry systems that are desirable from a biodiversity and climate action point of view, to make them viable livelihood options. • National and international collaboration: The EU should support the development of national traceability systems, as alternatives to private systems, which are inclusive of smallholder farmers and work to set up adequate funding. Meanwhile, given the global nature of the cocoa supply chain, international collaboration is required to ensure the overall effectiveness of the EUDR. Therefore, the EU should be encouraging similar regulations in other major consumer markets. 2 | POLICY BRIEF Key challenges and uncertainties • Data availability and use: Who has access to the data collected under the EUDR, and how can it be used for effective monitoring and farmer support? • Aspects of justice: How can the costs and benefits of EUDR implementation be fairly distributed, and how can negative impacts on vulnerable farmers be mitigated? What data sources are accepted? • Impact on cultivation methods: How does the EUDR affect the design and management of cocoa farms, and what incentives are needed to promote agroforestry systems? CIAT/C. Bunn Opportunities of the EUDR • Transparency and accountability: The EUDR improves company accountability for compliance by increasing transparency in the supply chain. • Value creation potential and improved visibility: Compliant farms could benefit from higher prices, more stable partnerships, and new opportunities such as payments for ecosystem services or carbon credits. • Incentives for improved farm management: The EUDR could curb land expansion and incentivize increased productivity and more resource-efficient farming practices. Risks of the EUDR • Cost burden: Establishing and maintaining traceability systems is costly and could place a disproportionate burden on farmer cooperatives. • Livelihood impacts for vulnerable farmers: Farmers who are unable to meet the requirements of the EUDR or are deemed as risky could experience negative impacts on their livelihoods. This particularly applies to farmers in remote regions, those near forests, and those with more complex agroforestry systems. • Risk of leakage and fraud: Cocoa from non- compliant plots may be falsely attributed to compliant ones, leading to leakage in the system. On the other hand, with imbalanced access to information between producers and buyers, opportunistic behaviour might occur where buyers offer discounted prices based on claims of non-compliance. • Narrowed focus: Prioritizing EUDR compliance could lead companies to neglect other sustainability goals and to stop sourcing from regions with higher deforestation risks but potentially greater environmental and social needs. • Biased verification: Deforestation checks using Earth observation data may disproportionately classify biodiverse, high- carbon agroforestry systems as forest, and thereby exclude them from markets. Key results 3Sustainable cocoa sourcing under the EUDR | Conclusions The EUDR presents both opportunities and challenges for sustainable cocoa sourcing. To maximize the positive effects and mitigate negative impacts, complementary policy measures and close cooperation between all actors along the value chain are essential. The EUDR implementation needs to be accompanied with public information systems which are inclusive to smallholders farmers, encourage sustainable practices, and leverage smallholder data in the public interest. Workshop objectives and methods • Stocktaking of current approaches to sustainable sourcing in the context of the EUDR. • Discussion on the opportunities and risks of EUDR implementation for smallholders. • Identification of new research topics and policy recommendations. The workshop consisted of three parts: 1. Input presentations: Presentations of the research results of the SUSTAIN-cocoa project. 2. Group work: Analysis of the impact of the EUDR on climate, livelihoods, and biodiversity. 3. Overall consensus: Definition of common positive and negative impacts, and derivation of policy recommendations for action. Additionally, identification of uncertainties and research needs. Reference publications from SUSTAIN cocoa Addoah, T., Lyons-White, J., Cammelli, F., & Garrett, R. (2023). West Africa: make cocoa production truly sustainable. Nature, 616(7955): 33–33. https://doi.org/10.1038/d41586-023-00891-8 Grabs, J., Cammelli, F., Levy, S. A., & Garrett, R. D. (2021). Designing effective and equitable zero-deforestation supply chain policies. Global Environmental Change, 70, 102357. https://doi.org/10.1016/j.gloenvcha.2021.102357 Kalischek, N., Lang, N., Renier, C., Daudt, R. C., Addoah, T., Thompson, W., Blaser-Hart W. J., Garrett, R., Schindler, K. & Wegner, J. D. (2023). Cocoa plantations are associated with deforestation in Côte d’Ivoire and Ghana. Nature Food, 4(5):384–393. https://doi.org/10.1038/s43016-023-00751-8 Kamath, V., Sassen, M., Arnell, A., van Soesbergen, A., & Bunn, C. (2024). Identifying areas where biodiversity is at risk from potential cocoa expansion in the Congo Basin. Agriculture, Ecosystems & Environment, 376, 109216. https://doi.org/10.1016/j.agee.2024.109216 Parra-Paitan, C., Meyfroidt, P., Verburg, P. H., & zu Ermgassen, E. K. (2024). Deforestation and climate risk hotspots in the global cocoa value chain. Environmental Science & Policy, 158, 103796. https://doi.org/10.1016/j.envsci.2024.103796 Renier, C., Vandromme, M., Meyfroidt, P., Ribeiro, V., Kalischek, N., & Zu Ermgassen, E. K. (2023). Transparency, traceability and deforestation in the Ivorian cocoa supply chain. Environmental Research Letters, 18(2), 024030. https://doi.org/10.1088/1748-9326/acad8e Sellare, J., Börner, J., Brugger, F., Garrett, R., Günther, I., Meemken, E. M., Pelli, E. M., Steinhübel, L., & Wuepper, D. (2022). Six research priorities to support corporate due-diligence policies. Nature, 606(7916):861–863. https://doi.org/10.1038/d41586-022-01718-8 Thompson, W. J., Blaser-Hart, W.J., Joerin, J., Krütli, P., Dawoe, E., Kopainsky, B., Chavez, E., Garrett, R. D., & Six J. (2022). Can sustainability certification enhance the climate resilience of smallholder farmers? The case of Ghanaian cocoa. Journal of Land Use Science 17(1):407–428. https://doi.org/10.1080/1747423X.2022.2097455 Trase. (2024). SEI-PCS Côte d’Ivoire cocoa v1.1 supply chain map: Data sources and methods. Trase. https://doi.org/10.48650/3KGC-VB46 Van den Broeck, G., & Akaribo, F. N. (2024). Is Cocoa Production a Main Driver of Children’s Work in Ghana? The Journal of Development Studies, 1–16. https://doi.org/10.1080/00220388.2024.2401416 Zinngrebe, Y., Berger, J., Bunn, C., Felipe-Lucia, M. R., Graßnick, N., Kastner, T., Pe’er G., Schleyer, C., & Lakner, S. (2024). Prioritizing partners and products for the sustainability of the EU’s agri-food trade. One Earth, 7(4):674–686. https://doi.org/10.1016/j.oneear.2024.03.002 zu Ermgassen, E. K., Renier, C., Garcia, A., Carvalho, T., & Meyfroidt, P. (2024). Sustainable commodity sourcing requires measuring and governing land use change at multiple scales. Conservation Letters, 17(3), e13016. https://doi.org/10.1111/conl.13016 Acknowledgements The workshop was hosted by the SUSTAIN-COCOA project, funded through the 2019–2020 BiodivERsA joint call for research proposals, under the BiodivClim ERA-Net COFUND programme. Correct citation Schmidt PG; Bunn C. (2025). Sustainable cocoa sourcing under the EUDR. Workshop report SUSTAIN–cocoa Research Dialogue, WCC Brussels, Belgium. Policy Brief No. 97. International Center for Tropical Agriculture, Cali, Colombia. 4p. March 2025 Supported by The SUSTAIN research project investigates the conditions under which supply chain sustainability initiatives (SSIs) can lead to reduced deforestation and increased shade-tree cover in cocoa production systems. A key focus is on how SSIs can support agroforestry practices, particularly the integration of shade trees, to reduce deforestation and promote sustainable land management. The Alliance is part of CGIAR, a global research partnership for a food-secure future dedicated to transforming food, land and water systems in a climate crisis. For further information please visit the project website CONTACT Christian Bunn, Climate Action in coffee and cocoa. Climate Action, Alliance of Bioversity International and CIAT c.bunn@cgiar.org CIAT/C. Bunn https://www.sustain-cocoa.earth/ mailto:c.bunn%40cgiar.org?subject=