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What cocoa products are in scope

Annex I covers cocoa across the chain, by HS code: [Reg. 2023/1115, Annex I]

A finished chocolate bar is in scope because it is a cocoa-derived Annex I product — the proportion of cocoa is not the test, the HS code is. Other ingredients matter too: if your bar also contains palm oil or soya lecithin, those are separately relevant commodities with their own origin-data needs.

Which role is yours?

• You import cocoa beans, mass or finished chocolate into the EU. First operator — you run due diligence and file the DDS before the goods move. [Reg. 2023/1115, Art. 4(2)]
• You are a bean-to-bar maker buying imported cocoa mass/beans within the EU and making chocolate under your brand. Placing that product on the market can make you an operator; if instead you buy an already-placed in-scope product and resell, you may be downstream and collect reference numbers. [Reg. 2025/2650, Art. 5]
• You are a micro or small chocolatier. Cocoa is not timber, so the 30 June 2027 date may apply if you meet the size test; larger makers are on 30 December 2026. [Reg. 2025/2650, Art. 38(3)]

What to ask your cocoa supplier for

Per lot, request: plot geolocation (coordinates, and polygons for plots over 4 hectares), harvest/production dates, country of production, legality evidence, and the DDS reference number where the supplier filed it. [Reg. 2023/1115, Art. 9 & Art. 2(28)]

Origin risk tiers for cocoa

The big cocoa origins — Côte d'Ivoire, Ghana, Nigeria, Cameroon, Ecuador and others — are generally standard risk under Implementing Regulation (EU) 2025/1093, meaning full due diligence. [Impl. Reg. 2025/1093] Because cocoa is so often blended across origins, a mixed-origin mass can drag the whole consignment to full due diligence; keeping origins documented per plot preserves any simplification.

What screening does and doesn't do

A screening determines your scope, role, deadline and documentary obligations for each product in your range. It does not verify that any cocoa plot is deforestation-free — that rests on the geolocation-plus-evidence your suppliers provide. You don't need a traceability platform to start; you need to know your position and exactly what to ask your cocoa supplier for.

General information about Regulation (EU) 2023/1115, not legal advice — and not a deforestation assessment. This kind of screening determines your scope, role, deadline and documentary obligations; it does not verify that any plot of land is deforestation-free. Confirm your classification with counsel before relying on it for a market-access decision.

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