- New Analysis Raises Doubts Over Ivory Coast’s Readiness for EU Cocoa Traceability Rules
Ivory Coast’s cocoa industry faces renewed scrutiny over its readiness for the European Union’s anti-deforestation law after a new analysis showed that less than half of the country’s cocoa exports can be traced back to the cooperatives that produced the beans.
According to analysis released by non-profit Trase shows that only 48% of Ivory Coast’s 2024 cocoa exports could be traced back to the farming cooperatives where the beans were grown, a level that has shown little improvement from Trase’s previous assessment two years ago.
The finding raises questions about how the world’s largest cocoa producer will comply with the European Union Deforestation Regulation, which from December will require EU importers of commodities and related products to prove that their supplies were not grown on deforested land. The rule also requires traceability of raw materials back to the plot where they were produced.
Ivory Coast’s challenge is particularly acute because much of its cocoa supply chain remains indirect, involving several intermediaries between farmers, cooperatives, buyers and exporters. That structure weakens visibility over the origin of beans and complicates efforts to verify whether cocoa is linked to deforestation or other sustainability concerns.
“The prevalence of indirect supplies of cocoa and the resulting lack of visibility into its origins makes it very difficult for companies to address issues such as deforestation or child labour,” Trase said.
The Ivorian cocoa regulator did not immediately respond to request for comment from the media. Ivory Coast has opted for a digitalised sales and purchasing system designed to support verification and help meet EU requirements.
The stakes are high for Ivory Coast and for global chocolate supply chains. The country produces just over one-third of the world’s cocoa, while the European Union is its largest trading partner, importing 66% of Ivorian cocoa beans.
The traceability gap therefore has direct commercial implications. If cocoa cannot be traced to compliant farms or plots, exporters and buyers may face difficulties selling into the EU market once the regulation is enforced. That could reshape sourcing decisions, raise compliance costs and create pressure on farmers, cooperatives and local buyers.
The EU deforestation regulation has been hailed by supporters as a landmark climate and biodiversity measure, but it has also faced resistance from trade partners who argue that compliance is costly and complex. Brussels has already delayed the implementation of the law twice and remains under pressure to further delay or scale it back.
Trade partners including Brazil, Indonesia and the United States have raised concerns over the regulation. Reuters reported that, as part of its trade deal with US President Donald Trump, the EU committed to working to address US concerns about the law.
For cocoa-producing economies in West Africa, the regulation is more than an environmental rule. It is fast becoming a market-access test. Countries that can prove traceability and demonstrate low deforestation risk may be better positioned to protect access to premium markets. Those with fragmented supply chains may face higher scrutiny.
The environmental backdrop is stark. Between 2000 and 2024, 79% of Ivory Coast’s forests were lost or degraded, according to Trase, with cocoa expansion accounting for nearly half of forest loss during much of the period.
Although deforestation rates in the country have declined over the past decade, Trase cautioned that this partly reflects the limited amount of forest left.
The report has implications beyond Ivory Coast. Ghana, the world’s second-largest cocoa producer, faces similar pressure to ensure that its cocoa supply chain can withstand EU scrutiny. For both countries, the shift from volume-driven cocoa exports to traceable, sustainability-compliant cocoa is likely to require deeper investment in farm mapping, digital purchasing systems, farmer registration, cooperative governance and data verification.
The risk is that compliance costs could be pushed down the supply chain, leaving smallholder farmers to carry obligations they are poorly equipped to meet. Without careful policy design, anti-deforestation rules intended to clean up global supply chains could also create exclusion risks for farmers outside formal, well-documented sourcing systems.
For exporters and chocolate manufacturers, the message is also clear: voluntary sustainability claims will no longer be enough. Under the EU regime, traceability must become evidentiary, plot-level and auditable.
Ivory Coast’s 48% traceability rate suggests that the industry still has a significant gap to close before the EU law takes full effect. For West Africa’s cocoa economies, the coming months will test whether digital systems, regulatory reforms and buyer commitments can move fast enough to protect market access while also addressing the environmental damage linked to cocoa expansion.
The wider lesson is that cocoa is entering a new commercial era. Price, quality and volume still matter. But in the EU market, proof of origin may soon matter just as much.
