The EU deforestation rule starts to apply to cocoa on 30 Dec 2026 without another delay
The test The EUDR's due-diligence duties apply to large and medium operators placing cocoa on the EU market from 30 Dec 2026, with no new postponement adopted before that date.
Not under way · Confidence: medium · Reviewed 1 Nov 2026 · Scores from 1 to 10
This page answers: What could happen, how it is scored, and who is exposed?
Using this page
- Read the two scores: Likelihood and Impact are kept apart.
- Check what is happening, each fact with its source.
- Use the calendar for the dates to watch.
Follow this riskSign in to follow; one weekly email if you ask for it.
Impact is the average of the four parts, rounded, plus one point when Canada is directly hit on two or more channels, up to 10.
Two separate scales from 1 to 10. Strature never multiplies or merges them.
What changed
Dated, newest first
- Cote d'Ivoire harvested 2.06 million t in 2025/26; Ghana about 750,000 t in 2025/26 and its cocoa board expects about 650,000 t in 2026/27 [3]
Why it matters
The EU Deforestation Regulation, postponed twice, is due to apply to large and medium operators on 30 Dec 2026. The Commission's review of 4 May 2026 found no further change to the law warranted and confirmed no further delay. Cote d'Ivoire (2.06 million t in 2025/26) and Ghana (about 750,000 t) would then sell into the EU only with traceable, deforestation-free beans.
Why Likelihood 6 Brakes: two past delays.
Why Impact 5 Threshold case duties apply on the date.
The other facts on file (3)
- By 17 Dec 2025 Parliament had voted a second one-year delay: 30 Dec 2026 for larger companies, 30 Jun 2027 for smaller ones; Commission review due by 30 Apr 2026 [2] (17 Dec 2025)
- Regulation (EU) 2025/2650 published 23 Dec 2025; Commission review of 4 May 2026: no further amendment warranted, no further delays; compliance costs about 75% lower [1] (5 Jun 2026)
- Only the first downstream operator collects references; micro and small primary operators may file a one-time declaration; cooperatives may act as authorised representatives [1] (5 Jun 2026)
Where it sits
Where this risk sits
Size shows Impact. Colour shows the Likelihood band. The two scores are never combined.
- Low 1–3
- Elevated 4–6
- High 7–8
- Severe 9–10
- Bigger circle: higher Impact
- Solid ring: under way
- Red ring: highest Impact on this map
- Where it starts
- Who it reaches
The risk on this map
- The EU deforestation rule starts to apply to cocoa on 30 Dec 2026 without another delayImpact 5 of 10, Elevated. Likelihood 6 of 10, Elevated. · Ivory Coast
How it spreads
The EUDR's due-diligence duties apply to large and medium operators placing cocoa on the EU market from 30 Dec 2026, with no new postponement adopted before that date.
Not under wayChannels 4 on the card
- CanadaNo Canadian loss sourced.
- Cocoa exportersEvery lot sold to the EU needs plot data and a due-diligence statement (Strature's view).
- FarmersCooperatives carry the mapping work for smallholders.
- EU buyersImporters file one statement for cocoa beans; downstream makers rely on it.
Goods 1
- Cocoa
Sectors 2
- Agriculture and food
- Ports and logistics
Countries 2
- Ivory Coast primary
- Ghana primary
Who is exposed
- Countries
- Ivory Coast, Ghana
- Sectors
- Agriculture and food, Ports and logistics
- Goods
- Cocoa
Three scenarios and their signposts
- S1
Applies on time
Duties start on 30 Dec 2026 with the simplified regime.
- S2
Soft start
The date holds but enforcement is light in the first months.
- S3
Third delay
A late proposal postpones the date again.
| Path | Signpost |
|---|---|
| S1 | EUDR information system fully open in December 2026 |
| S2 | Commission guidance on checks in early 2027 |
| S3 | A Commission proposal before 30 Dec 2026 |
No probability is given for the three paths.
Dates to watch
The dates to watch
A dot is a day, a bar a month or a year; a hollow mark is tentative. The line marks today.
- 30 Nov 2026 Rescore: 30-day test; Likelihood to 7 or more if no postponement is on the table [1] Declared · Strature date
- 30 Dec 2026 EUDR applies to large and medium operators [1] Declared · Outside event
- 30 Jun 2027 EUDR applies to micro and small operators [1] Declared · Outside event
Sign in, with alerts on, for an email 7 days and 1 day before.
The other side
Exporters with mapped, certified supply can sell into the EU with less competition from untraceable beans, and the Commission's cost estimate falls by about three quarters [1].
Connected in Strature
- A cocoa farmers' sales stoppage in Cote d'Ivoire visibly cuts deliveries Shares a channel: Farmers' costs and incomes in the same season.
- Ghana's 2026/27 cocoa crop comes in below 500,000 tonnes Shares a channel: The same cocoa exports to the EU.
- The EU moves to delay its carbon price on fuel and heating a second time Shares a channel: Another EU rule whose start date is under pressure.
Sources
3 sources, numbered as the text cites them
- The EUDR Clock Is Running: What the Commission's May 2026 Review Means for You. SCS Global Services via 3BL Media · 5 Jun 2026 · Industry · confidence medium · retrieved 1 Nov 2026
- EUDR delay confirmed. ConfectioneryNews · 17 Dec 2025 · Industry · confidence medium · retrieved 1 Nov 2026
- Cocoa falls as African harvests rise and ICE inventories approach a two-year high. XTB · 18 Sep 2026 · Commentary · confidence low · retrieved 1 Nov 2026
Reviewed 1 Nov 2026 · version 1 · last change: first review · All risks