Beyond compliance to EUDR in the cocoa sector
The proposed delay to the EUDR is regrettable. IDH believes that clear, predictable regulations on environmental and human rights responsibilities are important for the EU’s long-term competitiveness and for tackling deforestation.
This article shares insights and recommendations which came out of our regional learning exchange in Ghana - with key partners from Africa’s cocoa sector - earlier this year.
Inclusion from the ground up - why it matters for impact beyond compliance
The cocoa sector is ready to move from voluntary commitments to government regulation. But meaningful impact requires more than compliance – it requires collaboration. IDH brings together key partners from Africa’s cocoa sector to strengthen regional collaboration and align company investments, EU regulations and the ARS-1000 standard. This series shares insights from the government, industry, and civil society representatives we work with.
As the developments around the EU Deforestation Regulation (EUDR) and ARS-1000 show, implementation and compliance will require more than technical fixes - it demands political will, coordination, and trust across fragmented supply chains.
The EUDR can be a powerful lever for change, but its success depends on inclusive implementation. Many farmers already produce deforestation-free cocoa, but without support, they may struggle to prove it. Our ‘beyond compliance approach’ helps bridge public-private gaps, ensuring smallholders aren’t left behind and forest protection remains central.
National strategies must inform, include and fairly incentivise farmers. And the private sector should be seen not just as data providers, but as co-investors in building inclusive, sustainable systems.
Beyond the boardroom – collaboration is key
Investments in EUDR readiness have shown that no single actor can meet due diligence demands alone. It takes joint action - not just policy discussions - to tackle the root causes of deforestation and make compliance a stepping stone to long-term change.
We’re proud to support efforts in:
- Côte d’Ivoire: aligning national and private systems for traceability and forest monitoring
- Ghana: public-private field-testing of traceability with 16,000 farmers
- Cameroon: building trust between companies and national institutions to create a shared farm database and include smaller traders.
Utilising Data – building trust across cocoa supply chains
Preparations towards EUDR compliance have triggered real investments in data systems. Insights in traceability and due diligence are laying the groundwork for a foundation for data-driven decision making.
Yet while data is both a powerful enabler, it also presents one of the sector’s biggest challenges. Fragmented systems and unclear data ownership are slowing progress - without alignment, we risk duplication, inefficiency and mistrust.
A key concern is ensuring that farmers - who are producing deforestation-free cocoa - can access and share the necessary data to prove it. Without inclusive, farmer-friendly systems, we risk leaving behind those who are already doing the right thing.
Investments which go beyond compliance won’t be achieved through siloed solutions — it requires shared standards, interoperable platforms, and above all, concrete collaboration. That’s why we’re working with public and private partners to support the use of systems that are inclusive, scalable, and built on mutual trust.
The role of public leadership in inclusive policy implementation
For effective policy implementation, from EUDR to ARS-1000, public institutions must lead the way. Governments are uniquely placed to set clear standards, establish traceability systems and secure land tenure – essential for effective and inclusive compliance. Supporting the indirect supply chain toward EUDR compliance is not just realistic, it’s essential. The most efficient way to do this is through government-led coordination, in partnership with the companies that will ultimately be responsible for providing data when importing cocoa to the EU.
Without public coordinated leadership, efforts risk becoming fragmented, inefficient and duplicative. With it, we can create a shared framework that works for producers and exporters, including those in the indirect supply chain who are often left behind.
EUDR is a regional challenge – and it needs a regional response
Cocoa producing countries across Africa must work together to share learnings, align systems and raise a joint voice in EU dialogues. Frameworks like ARS1000 offer a strong foundation for this. A regional task force or knowledge platform could help countries navigate evolving EU expectations - reducing duplication and amplifying impact.
Nearly 50 stakeholders from Ghana, Côte d’Ivoire, and Cameroon came together for a rare moment of open, cross-country dialogue during IDH’s event. The event fostered mutual learning, identified shared priorities, and laid the groundwork for stronger regional cooperation.