EUDR DDS for Cocoa Supply Chain in Spain

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, 15 minute read

Quick summary: TraceX helps cocoa companies in Spain meet EUDR requirements with automated Due Diligence Statement (DDS) generation, farm-level traceability, and deforestation risk verification.

EUDR DDS for Cocoa Supply Chain in Spain ensures that all cocoa imported, processed, or exported by Spanish operators is deforestation-free, legally sourced, and fully traceable. Under the EU Deforestation Regulation (EUDR), Spanish cocoa importers, processors, and traders must implement a Due Diligence System (DDS) to verify farm-level geolocation, legality, and deforestation-free status before placing products on the EU market. By adopting digital traceability and risk assessment platformsSpain’s cocoa sector can ensure compliance, maintain EU market access, and strengthen its reputation for sustainable and transparent cocoa supply chains. 

Stay ahead of the 2025 regulation with our expert guide on Due Diligence Statements, traceability workflows, and category-specific obligations for operators, traders, and downstream entities.

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The EUDR Landscape for Cocoa & Spain 

The EU Deforestation Regulation (EUDR) establishes a transformative compliance framework for the global cocoa industry one that Spain, as a key EU importer and processor of cocoa, must align with. The regulation’s objective is clear: to prevent deforestation and forest degradation driven by the production of commodities like cocoa, coffee, timber, and palm oil. For Spain, a major gateway for cocoa entering the European Union, this means implementing full traceability, legality verification, and deforestation-free assurance across its cocoa supply chain. 

Why Cocoa Matters 

Cocoa, in both raw bean and semi-processed forms (such as cocoa liquor, butter, and powder), is explicitly included among the commodities regulated under the EUDR. Every operator placing cocoa or cocoa-derived products on the EU market must demonstrate that they originate from deforestation-free and legally cultivated land. 

To do so, companies are required to submit a Due Diligence Statement (DDS) before products are sold or distributed within the EU. This DDS must include: 

  • Farm-level geolocation data for all cocoa plots of origin. 
  • Proof of legality in accordance with local land tenure and agricultural laws. 
  • Risk assessments and mitigation measures confirming deforestation-free sourcing. 

For Spain whose confectionery, chocolate, and beverage industries rely heavily on cocoa imports from West Africa (Côte d’Ivoire, Ghana, Nigeria) and Latin America (Ecuador, Brazil) — compliance is both a legal necessity and a reputational imperative. 

Why Spain 

Spain is one of the largest cocoa importers and processing centers in Southern Europe, with major ports such as Valencia, Bilbao, and Algeciras serving as critical entry points for raw cocoa beans destined for European markets. Spanish chocolate manufacturers and ingredient processors play a pivotal role in the EU’s cocoa value chain, supplying both domestic and cross-border markets.

This central position means Spanish operators are directly responsible for ensuring EUDR compliance, including: 

  • Mapping all upstream cocoa suppliers to verified geolocations. 
  • Conducting legality and deforestation risk assessments. 
  • Submitting verified DDS for every shipment or processing batch placed on the EU market. 

The Spanish competent authority expected to operate under the Ministry for the Ecological Transition and Demographic Challenge (MITECO) will oversee enforcement, including audits, risk-based inspections, and DDS verification. 

Implementation Timelines 

The EUDR applies uniformly across all EU Member States, including Spain. The key deadlines are: 

  • By December 30, 2025: Large and medium-sized Spanish operators must have a fully operational Due Diligence System (DDS) and submit verified DDS reports before placing cocoa or cocoa-derived products on the market. 
  • By June 30, 2026: Micro and small enterprises must comply with the same due diligence requirements. 

These timelines make it critical for Spanish companies to start supplier mapping, digital data collection, and risk assessment integration immediately to avoid trade disruptions once enforcement begins. 

Scope of EUDR for Cocoa 

The EUDR applies to cocoa and all cocoa-derived products entering or circulating within the EU. For Spain, this includes: 

  • Raw cocoa beans (HS 1801) 
  • Cocoa paste, whether defatted or not (HS 1803) 
  • Cocoa butter, fat, and oil (HS 1804) 
  • Cocoa powder (HS 1805) 
  • Chocolate and other food preparations containing cocoa (HS 1806) 

All these categories fall under the EUDR’s commodity scope due to their direct link to forest-based production systems in tropical regions. Spanish companies involved in import, transformation, or re-export of any of these products must ensure traceable, legal, and deforestation-free sourcing. 

How the Regulation Shapes Spain’s Cocoa Industry 

The EUDR compels Spain’s cocoa and chocolate sector to digitally transform its sourcing and traceability systems, adopting blockchain-based traceability, satellite mapping, and supplier onboarding tools. 
Beyond compliance, this shift enhances supply-chain resilience, ESG performance, and market competitiveness, positioning Spanish companies as trusted suppliers in a European market increasingly defined by ethical and environmental accountability. 

By aligning with the EUDR, Spain’s cocoa industry not only safeguards access to the EU market but also strengthens its leadership in sustainable, deforestation-free chocolate production and trade. 

Master the step-by-step process of submitting Due Diligence Statements under the new EUDR rules. 
Read the blog on filing DDS for EUDR compliance 

Explore how cocoa importers can achieve traceability, transparency, and compliance under EUDR. 
Read the full blog on EUDR Cocoa Compliance 

What are the Key Challenges Spanish Cocoa Companies Face under EUDR 

The introduction of the EU Deforestation Regulation (EUDR) presents both an opportunity and a complex compliance challenge for Spain’s cocoa importers, processors, and traders. As one of Europe’s largest cocoa import and processing hubs, Spain faces multiple operational, technical, and regulatory hurdles in aligning its cocoa supply chain with EUDR’s deforestation-free and legality requirements. 

1. Traceability to Farm-Level Origin 

The biggest challenge for Spanish cocoa companies lies in mapping cocoa beans to their exact farm or plot of origin a fundamental EUDR requirement. Most of Spain’s cocoa imports come from smallholder farms in West Africa (Côte d’Ivoire, Ghana, Nigeria) and Latin America (Ecuador, Brazil), where land fragmentation, informal land tenure, and limited digital infrastructure make geolocation collection difficult. 

Spanish importers must now ensure that every batch of cocoa can be linked to precise GPS coordinates and that no deforestation occurred after December 31, 2020 a technically demanding and data-intensive process. 

2. Supplier Data Gaps and Documentation Inconsistency 

The EUDR requires comprehensive supplier documentation, including legality proof, ownership records, and sustainability declarations. However, many smallholder farmers and cooperatives lack standardized record-keeping systems, resulting in inconsistent or incomplete data. 

For Spanish processors, consolidating data from hundreds of upstream suppliers across multiple countries introduces significant traceability gaps. This creates risks of non-compliance or delays in submitting accurate Due Diligence Statements (DDS) to EU authorities. 

3. Complex Global Supply Networks 

Spain’s cocoa supply chain is deeply globalized, involving intermediaries, exporters, and logistics providers spread across several continents. This multi-tiered structure makes it difficult to track cocoa from origin to final processing, especially when beans are blended from multiple sources before entering Spain. 

The EUDR’s zero-deforestation standard requires companies to maintain segregated or traceable supply chains, which may demand redesigning sourcing models, logistics, and documentation processes. 

4. Compliance with Multiple Regulatory Frameworks 

Spanish cocoa importers and manufacturers must now navigate overlapping regulatory systems, including: 

  • EUDR (deforestation-free sourcing and DDS submission) 
  • EU Corporate Sustainability Due Diligence Directive (CSDDD) 
  • EU Green Claims Directive (environmental marketing) 
  • Existing sustainability certifications (Fairtrade, Rainforest Alliance, UTZ) 

Balancing these frameworks requires significant investment in legal expertise, data integration, and ESG alignment a challenge particularly for small and mid-sized enterprises in Spain’s confectionery and chocolate manufacturing sectors. 

5. Digitalization and Data Infrastructure Readiness 

EUDR compliance depends on the ability to collect, manage, and report large volumes of digital traceability data. However, many Spanish cocoa processors and importers lack integrated digital systems to manage supplier mapping, geolocation verification, and DDS submission. 

Building interoperable systems that connect with EU reporting portals, blockchain traceability solutions, and supplier data platforms represents a critical technological challenge one that requires cross-industry collaboration and investment. 

8. Verification of Deforestation-Free Claims 

Validating that no deforestation occurred on a cocoa plot after the EUDR cut-off date requires satellite imagery, GIS mapping, and cross-referencing with deforestation databases. Spanish firms will need access to high-quality spatial data and may need to partner with technology providers or certification bodies to verify claims effectively a new operational competency for much of the sector. 

9. Stakeholder Coordination and Communication 

EUDR compliance requires seamless coordination between farmers, cooperatives, exporters, importers, processors, and regulators. For Spanish companies, establishing transparent data-sharing agreements and standardized communication channels across multiple languages and jurisdictions is both logistically and administratively complex. 

In short, Spanish cocoa companies face a dual challenge adapting existing sourcing structures to meet new EUDR obligations while maintaining supply stability and profitability. Achieving compliance will require digital transformation, multi-stakeholder collaboration, and proactive risk management. 
Those who invest early in traceability, data systems, and supplier partnerships will not only ensure EUDR readiness but also strengthen Spain’s position as a leader in ethical and sustainable cocoa trade within the EU. 

How TraceX Simplifies EUDR DDS for Cocoa (Spain) 

As the EU Deforestation Regulation (EUDR) comes into full effect, Spain’s cocoa importers, processors, and traders must ensure that all cocoa sourced, processed, or placed on the EU market is deforestation-free, legally produced, and traceable to its farm of origin. The TraceX EUDR Compliance Platform provides Spanish cocoa companies with a unified digital system to streamline Due Diligence Statement (DDS) generation, automate data collection, and maintain complete supply-chain transparency from farm to factory to EU buyer. 

Automated DDS Creation and Validation 

TraceX automates the creation, verification, and submission of EUDR-compliant DDS reports for every cocoa batch imported or processed in Spain. Integrated directly with the EU’s central reporting framework, the platform consolidates supplier data, legality documentation, and farm geolocation into one secure system. This eliminates manual errors, reduces administrative load, and ensures Spanish companies are fully audit-ready for inspections by the national competent authority. 

Blockchain-Enabled Traceability and Proof of Origin 

Each shipment of cocoa imported through key Spanish ports like Valencia, Bilbao, or Algeciras is recorded on a blockchain ledger, providing a tamper-proof chain of custody from farm to processing plant. This immutable record guarantees that cocoa is sourced from verified deforestation-free plots, allowing Spanish manufacturers and traders to demonstrate transparent and compliant sourcing to EU partners and certification bodies. 

Supplier and Farmer Onboarding Tools 

TraceX simplifies the challenge of working with fragmented smallholder networks by offering mobile and cloud-based onboarding tools. Cooperatives, exporters, and intermediaries can digitally register farmer data, capture GPS coordinates, and upload legality and sustainability certifications (e.g., Fairtrade, Rainforest Alliance). This inclusivity enables Spanish companies to extend EUDR compliance downstream to their global supply partners, even in high-risk regions. 

AI-Driven Risk Intelligence and Deforestation Monitoring 

The platform’s AI-powered dashboards provide real-time analytics on deforestation risk, supplier performance, and sourcing integrity. Integrated satellite-based land-use monitoring detects forest loss or encroachment near cocoa-producing areas, allowing Spanish importers to take proactive action before non-compliance arises. Automated risk scoring supports continuous monitoring and early-warning alerts, safeguarding EU market access. 

Practical Use Case: Spanish Cocoa Importer and Processor 

A Spanish chocolate manufacturer sourcing cocoa beans from Ghana and Ecuador can use TraceX to onboard cooperatives, collect farm-level geolocation data, and auto-generate EUDR DDS files for each import batch. Within weeks, the company can achieve full digital traceability, cut compliance preparation time by over 60%, and strengthen trust with EU buyers and regulatory authorities. 

Transforming Compliance into Competitive Advantage 

By merging blockchain-backed traceability, AI-based monitoring, and automated DDS workflows, TraceX empowers Spanish cocoa companies to turn EUDR compliance into a strategic advantage. Businesses gain operational efficiency, enhance ESG credibility, and build stronger relationships with EU partners seeking verified, deforestation-free cocoa supply chains.

Simplify EUDR DDS generation for cocoa importers and manufacturers in Spain

TraceX’s EUDR Compliance Platform today and ensure transparent, trusted, and deforestation-free cocoa sourcing for your EU-bound operations.

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Why It Matters: Impacts for the Spanish Cocoa and Chocolate Sector 

cocoa supply chain, eudr dds, eudr compliance, eudr dds, cocoa traceability

The enforcement of the EU Deforestation Regulation (EUDR) represents one of the most consequential shifts for Spain’s cocoa and chocolate value chain in decades. As a leading European hub for cocoa import, processing, and chocolate manufacturing, Spain’s compliance with EUDR requirements will shape not only its market access but also its reputation as a champion of sustainable production, ethical sourcing, and environmental accountability. 

Ensuring Market Access and Regulatory Continuity 

The EU remains the world’s largest importer and consumer of cocoa-based products. Spanish companies that fail to demonstrate EUDR compliance risk losing access to this critical market due to non-conforming shipments or rejected DDS filings. 

By aligning early with EUDR traceability and legality standards, Spanish cocoa importers, processors, and exporters secure uninterrupted trade flows, avoid costly disruptions, and maintain long-term access to EU and global buyers increasingly demanding verifiable sustainability credentials. 

Strengthening Supply Chain Transparency 

For decades, cocoa supply chains have been criticized for opacity, child labor risks, and environmental impact. EUDR compliance forces the industry to achieve end-to-end transparency from smallholder farms in Ghana and Côte d’Ivoire to chocolate factories in Spain. 

Digital traceability platforms, such as TraceX, enable Spanish companies to map their supply chains, monitor risk zones via satellite, and validate supplier data in real time. This not only enhances regulatory confidence but also builds consumer trust in “clean, traceable” chocolate. 

Driving Sustainability and ESG Leadership 

EUDR compliance positions Spain as a leader in sustainable cocoa transformation, aligning the industry with broader EU Green Deal and corporate sustainability goals. 

Spanish chocolate manufacturers and processors adopting verified deforestation-free supply chains can strengthen their ESG reporting, attract sustainability-conscious investors, and differentiate themselves in competitive European retail markets where green credentials drive purchasing decisions. 

Boosting Brand Reputation and Consumer Trust 

Today’s consumers demand ethical transparency knowing where their chocolate comes from and under what environmental and social conditions it was produced. 

EUDR compliance enables Spanish chocolate brands to communicate credible sustainability stories, backed by verified data. Companies can highlight deforestation-free sourcing, farmer partnerships, and carbon-conscious production, reinforcing brand equity and market preference both domestically and across the EU. 

Empowering Smallholder Integration and Fair Trade 

Spain’s chocolate and cocoa industries depend heavily on smallholder farmers in West Africa and Latin America. The EUDR, though compliance-intensive, provides an opportunity to digitally empower these producers through geolocation mapping, training, and fair-trade inclusion. 

By leveraging digital onboarding tools and partnerships with cooperatives, Spanish companies can support rural traceability and inclusivity turning compliance into a social impact initiative that uplifts smallholder livelihoods while ensuring legality and sustainability. 

Encouraging Technological Modernization 

EUDR mandates a fundamental shift from paper-based systems to data-driven digital traceability infrastructure. For Spain’s cocoa processors and chocolate manufacturers, adopting these technologies drives operational efficiency, real-time data access, and competitive agility. 

Early digital adoption enhances readiness for other EU regulations, such as the Corporate Sustainability Due Diligence Directive (CSDDD) and Green Claims Directive, ensuring long-term regulatory alignment and business resilience. 

Positioning Spain as a Sustainable Trade Leader 

Spain’s strategic location, advanced logistics network, and strong industrial base make it a natural hub for Europe’s sustainable cocoa trade. By successfully implementing EUDR-compliant DDS workflows, Spanish operators can establish the country as a model of ethical cocoa sourcing, attracting global partners and sustainability-oriented investments. 

The EUDR DDS for the Spanish Cocoa Supply Chain is far more than a compliance mandate it is a catalyst for systemic transformation. It redefines how cocoa is sourced, verified, and marketed, embedding sustainability and accountability into the DNA of Spain’s chocolate industry. 
Those who act early investing in digital traceability, supplier engagement, and risk intelligence — will not only meet EUDR obligations but also lead a new era of transparent, responsible, and deforestation-free chocolate production in Europe. 

Understand the key components of EUDR compliance and how to streamline your DDS process efficiently. 
Read the blog on EUDR Due Diligence 

Learn how AI-driven automation and intelligent workflows simplify data collection, verification, and reporting. 
Explore the blog on Agentic AI for EUDR 

Unpack the biggest hurdles faced by importers under EUDR  and how technology can turn compliance into a competitive edge. 
Read blog on Challenges for EU Importers 

Frequently Asked Questions (FAQ’s)


What is the EU Deforestation Regulation (EUDR)? 

The EUDR is a regulation by the European Union aimed at preventing deforestation-linked commodities like cocoa from entering the EU market. It requires full supply chain traceability and submission of Due Diligence Statements (DDS) proving compliance. 

What is a Due Diligence Statement (DDS) under EUDR? 

A DDS is a formal declaration confirming that cocoa imported or sold in Spain is deforestation-free and legally sourced. It must include farm-level geolocation data and risk assessment documentation. 

Who needs to comply with the EUDR for cocoa in Spain? 

All Spanish importers, traders, processors and retailers handling cocoa are required to comply. Both large corporations and small operators must provide DDS documentation for their supply chains. 

What challenges do cocoa companies in Spain face with EUDR DDS generation?

Common difficulties include gathering farm-level data, verifying deforestation-free claims, managing multiple smallholders, and preparing DDS documents manually. 

How does TraceX help automate EUDR DDS generation? 

TraceX digitizes the entire process mapping cocoa farms, verifying deforestation risks via satellite data, and auto-generating compliant DDS reports ready for submission. 

 Is TraceX suitable for smallholder-based cocoa supply chains?

Yes. TraceX is built for scalability and ease of use. It supports both large enterprises and smallholder networks, enabling simple data collection via mobile apps 

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Download your EUDR DDS for Cocoa Supply Chain in Spain here

Download your EUDR DDS for Cocoa Supply Chain in Spain here

Download your EUDR DDS for Cocoa Supply Chain in Spain here

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