Every chocolate bar, cocoa powder, and candy coating entering the EU after December 30, 2025, needs deforestation-free proof. Sounds simple until you realize cocoa involves 5-6 million smallholder farmers, most with plots smaller than a football field, many who can’t read or write.

The Smallholder Reality

• Average cocoa farm: 2-4 hectares
• Farmers per chocolate bar: Often 50+
• Documentation level: What documentation?
• GPS coordinates: “It’s next to the big tree”

Why Cocoa Breaks Normal EUDR Rules

• Scale: Your supply chain might include 10,000+ individual farmers.
• Geography: 85% comes from Ghana and Côte d’Ivoire where land records are… informal.
• Structure: Cooperatives blend harvests from hundreds of farms.
• Technology: Most farmers have never used GPS.
• Cultural Context: Due diligence must be culturally appropriate and engage farmers on their terms, not on a Western corporate one. This means working with local communities and leaders.

The Supply Chain Nightmare

• Farmer harvests from 2-3 separate plots
• Cooperative pools hundreds of farmer harvests
• Trader buys from multiple cooperatives
• You blend beans from various traders
• Result: Traceability chaos

What Chocolate Companies Get Wrong

• Expecting smallholders to act like industrial farms.
• Not working with existing cooperative structures.
• Ignoring that cocoa grows under forest canopy (making satellite monitoring tricky).
• Assuming translations and cultural adaptation aren’t crucial.
• Overlooking a farmer-first approach. Simply demanding data will not work; companies need to invest in the infrastructure and training to make compliance a shared benefit.

The Numbers Don’t Lie

€2.3 billion in annual EU cocoa imports at risk. However, compliant cocoa commands 20-30% premiums, and consumer demand for sustainable chocolate is exploding.

You can’t audit millions of smallholder farms by yourself. That’s why N’entropy’s cooperative engagement platform is designed to handle cocoa supply chains with ease. We can help you map every plot of land, even those under 4 hectares, and provide you with real-time risk alerts. You get a single source of truth for your entire supply chain — from a farmer in Ghana to a warehouse in Brussels—making it easy to prove your product is deforestation-free.