EUDR DDS for Cocoa Supply Chain in Belgium 

The EUDR DDS for Cocoa Supply Chain in Belgium requires all cocoa beans and cocoa-derived products placed on the EU market via Belgium to come from farms where no deforestation occurred after 31 December 2020, comply with national laws of the origin country, and be traceable down to the plantation. Belgian importers and traders must collect precise geolocation of farms, legislation compliance documentation, and issue a Due Diligence Statement (DDS) for each shipment. Without this, cocoa cannot legally enter the EU market under the EU Deforestation Regulation 

The EU Deforestation Regulation (EUDR) Landscape for Cocoa in Belgium 

As a core member of the EU and one of the world’s largest cocoa import and processing hubs, Belgium is at the forefront of EUDR implementation. The EU Deforestation Regulation (EUDR) directly applies to Belgian operators, traders, and exporters placing cocoa and cocoa-derived products such as cocoa beans, paste, butter, powder, and chocolate on the EU market. These companies must ensure that every shipment is deforestation-free (no forest cleared after 31 December 2020), legally sourced according to origin-country laws, and fully traceable to the farm level. 

Belgium plays a critical role in the European cocoa ecosystem: ports like Antwerp serve as major entry points for West African cocoa, which is then processed and distributed across the continent. Under EUDR, each actor in this supply chain must implement a Due Diligence System (DDS), collect geolocation data, verify legality of production, and submit a Due Diligence Statement through the EU’s central information system before placing products on the market. 

Scope 

The EUDR covers cocoa and cocoa-derived products placed on the EU market (including via Belgium). This includes raw cocoa beans (HS 1801), cocoa shells/husks (HS 1802), cocoa paste (HS 1803), cocoa butter/oil (HS 1804), cocoa powder (HS 1805) and chocolate/food preparations containing cocoa (HS 1806).  

Timelines & Belgian Context 

The EUDR was formally adopted as Regulation (EU) 2023/1115 on 31 May 2023. For cocoa, operators must comply from 30 December 2025 (large/medium enterprises) when placing products on the EU market. Micro and small enterprises generally have until 30 Dec 2026 to fully implement their due diligence systems. Belgium, as one of the top EU importers of cocoa and other deforestation-linked commodities, is intensifying its support and regulatory preparedness ahead of these deadlines.  

Implications for Belgian Cocoa Supply Chains 

• Belgian importers and processors must establish systems to trace cocoa to the farm level, capture geolocation data, and verify the legality of the origin country’s production laws. 

• They must engage with upstream suppliers in cocoa-producing countries to ensure data completeness, support for smallholder farmers, and transparent chain-of-custody documentation. 

• Non-compliant cocoa or cocoa derivatives cannot be placed on the EU market through Belgium after the deadline, exposing companies to regulatory enforcement and reputational risk. 

• With Belgium’s role as a major hub, companies using Belgian ports and logistics need to integrate EUDR compliance into sourcing, logistics and export frameworks. 

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What are the key challenges that Belgian cocoa companies face under the EU Deforestation Regulation (EUDR) 

1. Traceability and farm-level geolocation data 

Belgian cocoa traders and processors must trace cocoa beans all the way back to the farm plots and submit geolocation coordinates to comply with EUDR requirements. This is difficult because: 

• Many supplying smallholder farms in origin countries lack digital records or GPS mapping.  

• Indirect supply chains make up a large portion of cocoa sourcing; in 2023 average traceability in indirect chains was only ~22%. 

• Belgian companies must upgrade data systems and coordinate upstream suppliers to collect and manage this very granular data, representing considerable operational change. 

2. Compliance with origin-country legality and deforestation cut-off 

Under EUDR, Belgium-based operators must ensure that the cocoa they place on the EU market: (a) did not originate from land deforested after 31 December 2020, and (b) complies with the laws of the country of origin.  
Challenges include: 

• Determining whether land-use conversion is classed as deforestation under local law or international standards, especially in origin countries.  

• Managing suppliers across multiple countries with different legal regimes, documentation standards and enforcement levels. 

• Mapping and documenting parcels (often small plots) and verifying no deforestation or forest degradation occurred for many Belgian operators this is new territory and adds both cost and risk. 

3. Supply-chain complexity and indirect sourcing risk 

Belgium is a major EU hub for cocoa imports and processing, so Belgian companies often sit deep in complex, multi-tier supply chains 

Complications: 

• A large portion of cocoa comes indirectly (via intermediaries) rather than directly from known farms this increases blind spots for Belgian operators.  

• Ensuring that each tier from farmer to local buying agent to exporter to Belgian importer conforms to EUDR’s due-diligence system (DDS) is operationally demanding. 

• If any link fails compliance, the Belgian operator faces risk of placing non-compliant cocoa on the EU market, with consequences for market access and reputation. 

4. Operational, technological and cost barriers 

Belgian cocoa firms must upgrade systems and invest in digital traceability, risk-monitoring, and due-diligence workflows. According to industry commentary, such changes are “transformative” and resource intensive.  

Specific challenges: 

• Building or integrating digital platforms for recording farm-level data, supplier onboarding, lot tracking, and DDS generation. 

• Training staff and networks of upstream suppliers (often in rural origin countries) many of whom may not have the technical or infrastructural capacity.  

• Rising costs associated with auditing, certification, data capture and compliance not always easy for smaller Belgian firms to absorb. 

5. Timing, regulatory clarity and market risk 

Belgian cocoa companies operate under tight deadlines; for cocoa, EUDR obligations begin with large/medium operators by 30 December 2024 (note: some variations).  

Key issues: 

• Uncertainty remains around certain technical aspects of EUDR implementation, such as the EU’s Deforestation Information System and how all data flows will work.  

• Belgian operators risk supply-chain disruption if they cannot meet deadlines or if origin-supplier networks are not compliant. 

• Non-compliance could result in loss of access to EU markets, rejection of shipments, or reputational damage in the sustainability-sensitive chocolate sector. 

6. Smallholder inclusion and equity in sourcing 

Belgian companies sourcing cocoa know that much of the supply comes from smallholder farms in West Africa. Ensuring these farmers can meet EUDR requirements is vital yet challenging. Challenges include: 

• Many smallholders lack record-keeping, geolocation, certification or financial resources to upgrade. 

• If Belgian buyers exclude smallholders because they cannot comply, there’s a risk of unintended exclusion, loss of livelihoods, and supply-chain fragmentation raising ethical concerns. 

• Belgian firms must design inclusive programmes (capacity building, traceability support) to avoid disadvantaging smallholder farmer networks. 

In short, Belgian cocoa companies face a multi-dimensional challenge under EUDR: requiring enhanced traceability systems, legality verification across origin countries, management of complex indirect supply chains, significant investment in digital and organisational capabilities, adherence to tight implementation timelines, and ensuring inclusive sourcing of smallholder farmers. Successfully navigating these challenges will require operational transformation but it also offers an opportunity for Belgian firms to establish themselves as leaders in deforestation-free, transparent, and ethically sourced cocoa. 

How TraceX Simplifies EUDR DDS for Cocoa in Belgium 

As one of Europe’s largest cocoa import, processing, and chocolate manufacturing hubs, Belgium faces direct obligations under the EU Deforestation Regulation (EUDR). To maintain seamless access to the EU market and meet the regulation’s strict Due Diligence Statement (DDS) and traceability requirements, Belgian cocoa traders, processors, and exporters must ensure that all cocoa is legally sourced, deforestation-free, and fully traceable to the farm of origin. The TraceX EUDR Compliance Platform enables Belgian companies to automate compliance, ensure transparency, and future-proof their supply chains. 

Automated DDS Creation: 

TraceX automates the generation, validation, and submission of EUDR-compliant DDS reports directly within the EU information system. By consolidating data from farm geolocations, supplier declarations, and legality documents, it eliminates manual errors, ensures audit-readiness, and streamlines regulatory reporting for every cocoa consignment. 

Blockchain-Enabled Traceability: 

Each cocoa batch entering through ports such as Antwerp or Zeebrugge is digitally tagged and recorded on TraceX’s blockchain ledger, creating an immutable record of origin. This tamper-proof digital chain of custody guarantees transparent, verifiable compliance bolstering trust among regulators, buyers, and consumers across Europe. 

Supplier and Cooperative Onboarding: 

Through its mobile-based digital tools, TraceX allows Belgian importers and processors to onboard cooperatives and smallholders from major producing regions like Ghana, Côte d’Ivoire, and Nigeria, capturing farm-level GPS data, land ownership records, and legality documentation all mapped seamlessly into the DDS framework. 

AI-Powered Risk Assessment Dashboards: 

TraceX’s intelligent dashboards combine satellite analytics, AI-driven deforestation risk scoring, and supplier performance monitoring to help Belgian cocoa companies identify high-risk sourcing areas and act proactively. This ensures early detection, effective risk mitigation, and consistent compliance with EUDR’s due diligence expectations. 

Turning Compliance into Advantage: 

With TraceX, Belgian cocoa processors and exporters can transform EUDR compliance into a strategic advantage achieving digital traceability, enhancing sustainability credentials, and strengthening Belgium’s reputation as a leader in responsible, deforestation-free chocolate production. 

Why EUDR Compliance Matters for the Belgian Cocoa Sector 

Belgium stands at the heart of Europe’s cocoa and chocolate economy. As one of the world’s leading importers, processors, and exporters of cocoa and cocoa-derived products, the EU Deforestation Regulation (EUDR) has far-reaching implications for every segment of the Belgian cocoa value chain from bean importers and grinders to chocolate manufacturers and traders. Compliance is not just a legal necessity; it is becoming a defining factor for market access, brand reputation, and long-term competitiveness. 

Safeguarding EU Market Access 

The EUDR makes it illegal to place cocoa or cocoa products on the EU market unless they are deforestation-free, legally produced, and traceable to their plot of origin. As the regulation is directly enforceable across all EU Member States, Belgian companies that fail to meet EUDR standards risk supply chain disruptions, shipment rejections, and financial penalties. Given that Belgium serves as a major entry hub for cocoa imports particularly through the Port of Antwerp ensuring EUDR compliance is essential for keeping trade flows with other EU countries uninterrupted. 

Protecting Belgium’s Role as a Global Cocoa Hub 

Belgium’s cocoa and chocolate sector contributes billions of euros annually to the EU economy, with world-renowned brands such as Barry Callebaut, Puratos, and Godiva relying on the country’s strategic logistics and processing infrastructure. Compliance with the EUDR strengthens Belgium’s position as a trusted and responsible cocoa hub, safeguarding the export of high-value chocolate products to EU and global markets. 

Enhancing Supply Chain Transparency and Trust 

EUDR compliance drives the adoption of traceability technologies, farm mapping, and data transparency ensuring that every cocoa shipment can be traced back to legally managed, deforestation-free farms. For Belgian companies sourcing from West Africa and Latin America, this represents an opportunity to build direct relationships with producers, strengthen supplier accountability, and reassure European consumers who are increasingly demanding ethical and sustainable products. 

Aligning with Sustainability and ESG Commitments 

Belgian cocoa processors and chocolate manufacturers are under growing pressure from investors, regulators, and consumers to demonstrate tangible progress on ESG (Environmental, Social, and Governance) goals. The EUDR provides a framework for companies to align with the European Green Deal, reduce deforestation-linked emissions, and reinforce commitments to responsible sourcing, fair labor, and environmental stewardship. 

Mitigating Reputational and Financial Risks 

Failure to comply with the EUDR exposes Belgian operators to not only financial penalties and trade restrictions but also significant reputational risks. As sustainability becomes a core brand differentiator, companies that demonstrate leadership in compliance and traceability will benefit from stronger buyer confidence, premium pricing opportunities, and market preference from eco-conscious retailers and consumers. 

For Belgium’s cocoa sector, EUDR compliance is not just a regulatory hurdle it is a strategic imperative. It ensures continued EU market access, preserves Belgium’s reputation as a world-class cocoa hub, and drives digital transformation across supply chains. By adopting technologies such as blockchain traceability, geolocation mapping, and automated DDS systems, Belgian cocoa companies can turn EUDR compliance into a competitive advantage, reinforcing their leadership in sustainable, transparent, and deforestation-free cocoa trade. 

Strengthening Belgium’s Cocoa Future through EUDR DDS Compliance 

The EUDR DDS for Cocoa Supply Chain in Belgium marks a pivotal moment for the country’s cocoa and chocolate industry. As a leading European hub for cocoa imports, processing, and re-exports, Belgium’s compliance with the EU Deforestation Regulation is essential to safeguard its market leadership and sustainability reputation. Implementing robust Due Diligence Systems (DDS) integrating farm-level traceability, legality verification, and deforestation-free assurance will enable Belgian cocoa companies to meet EU requirements while building more transparent and resilient supply chains. Beyond compliance, this transformation positions Belgium as a global model for ethical cocoa sourcing, combining digital innovation with sustainability leadership to secure the future of responsible chocolate production. 

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