EUDR and Cocoa in 2026: Can African Smallholders and Cooperatives Stay in the EU Market?

By Almut van Casteren, COO, eProd Solutions

Introduction: The Countdown Is On

The countdown to the European Union's Deforestation Regulation (EUDR) is no longer measured in years.

Following two postponements, the European Commission confirmed in its May 2026 simplification review that the regulation will officially enter into application on 30 December 2026 for large and medium operators—with no further extensions [1].

The 13 July 2026 Delegated Act has now finalised the product scope under Annex I and the functioning of the EUDR Information System [1], closing the last open legislative questions.

For any agri-commodity exported to the EU from October onwards, organizations must prove—with precise geolocation data—that the product was not grown on land deforested after 31 December 2020 [2].

This applies across:

• Cocoa
• Coffee
• Rubber
• Palm oil
• Soy
• Timber
• Cattle
• Derived products

While the regulation aims to combat global deforestation—a goal eProd Solutions fully supports—its implementation reveals a stark reality:

The agricultural supply chain is not a level playing field.

The question is no longer whether compliance is required.

It is who will be able to afford it, and who will be left behind.

What Is the EUDR and Who Does It Apply To?

The EU Deforestation Regulation (Regulation (EU) 2023/1115) requires all operators and traders placing covered commodities or their derived products on the EU market—or exporting them from it—to submit a Due Diligence Statement (DDS) through the EU TRACES NT Information System.

That statement must be backed by:

• Geo-coordinates (polygon for plots above 4 hectares; single point for smaller plots) for every land plot from which the commodity was sourced.
• Documented evidence that sourcing areas were not deforested after 31 December 2020.
• A risk assessment covering the entire supply chain.
• Audit-ready traceability records available to competent authorities on request.

Non-compliance carries penalties of at least 4% of a company's total annual EU-wide turnover, plus:

• Confiscation of products and revenues
• Temporary market bans
• Exclusion from public procurement

[2]

The cocoa sector sits at the centre of this challenge.

West Africa produces around 60% of global cocoa volume [3], and the EU remains the world's largest cocoa market.

For Côte d'Ivoire:

• The EU accounts for approximately 66% of cocoa exports.
• Only an estimated 48% of that volume can currently be traced to a specific production area.

For Ghana:

• Cocoa represents around 95% of the country's EU-exposed EUDR commodity revenue.
• More than 800,000 smallholder farmers are involved.
• Typical farm size is just 2–4 hectares.

The Tale of Two Supply Chains: Who Is Ready and Who Is Not?

The EUDR readiness landscape within the cocoa sector is deeply fragmented—and the divide largely follows the line between large international players and smaller independent African operators.

Large multinational corporations and major trading houses are largely prepared.

Over the past decade, they have invested heavily in proprietary, in-house traceability systems and direct sourcing networks.

They already have:

• The data
• Field teams
• Capital
• Established compliance systems

The picture is very different for thousands of cooperatives and smaller companies operating in the indirect supply chain.

In some countries, governments have made meaningful efforts to build national traceability infrastructure.

Ghana's Ghana Cocoa Traceability System (GCTS) is a notable example [4].

However, these platforms are only effective for organizations that can successfully feed data into them—organizations with the digital tools, trained staff, and connectivity to do so.

What about cooperatives that cannot link produce to individual farmer fields?

What about tens of thousands of smallholder farmers in conflict-affected or remote regions who remain disconnected from global digital developments?

With mobile internet penetration in Sub-Saharan Africa at just 29%, compared with the global average of 58%, offline-first cooperative-based data collection is not simply a preference—it is a necessity.

This structural gap has created a troubling dynamic.

Large multinational buyers are increasingly stepping in to fill the compliance vacuum by:

• Deploying their own field teams
• Issuing hardware
• Onboarding cooperatives directly into proprietary traceability ecosystems

While this ensures compliance for the buyer, it fundamentally restructures the power dynamics of the supply chain.

The cooperative's access to the EU market becomes dependent on the technology and goodwill of a single buyer rather than operating as an independent, market-ready entity.

This is not compliance; it is dependency.

How Much Does EUDR Compliance Cost? The African Reality

The existence of EUDR compliance solutions is not in question.

The technology already exists.

The real barrier is cost.

European pricing models simply do not translate to the African market.

"I recently heard from a client in Nigeria who will be charged €40,000 yearly just for their deforestation analysis. That cost will inevitably eat a large part of their profit. Who pays for that? The farmer, through reduced margins, or the exporter who can no longer compete. It is absolutely possible to offer the exact same compliance services—but they must be offered at African prices, tailored to the African reality."

— Almut van Casteren, COO, eProd Solutions

Industry estimates suggest that geolocation data collection alone can cost a producer organisation between €5,000 and €15,000 [5], before accounting for physical segregation costs throughout the supply chain [2].

If compliance costs remain at these levels, the financial burden will inevitably flow downstream to smallholder farmers, further compressing already low farmgate prices.

The European Commission's May 2026 simplification package projected a 75% reduction in aggregate compliance costs for SMEs, reducing estimated total costs from approximately €8.1 billion to €2.0 billion.

This represents meaningful progress.

However, the projection is weighted toward EU-based downstream operators rather than African producer organisations working in low-margin, high-volume commodity supply chains.

The challenge remains clear:

EUDR compliance must be achievable without sacrificing the economic sovereignty of African cooperatives.

That requires solutions designed—and priced—for African realities.

How Can Smallholders and Cooperatives Comply With the EUDR?

Compliance is achievable, but it requires a fundamentally different approach.

Key principles include:

• Mobile-first, offline-capable data collection.
• Cooperative-level aggregation of thousands of smallholder plots.
• Modular pricing based on actual compliance needs.
• Direct integration with the EUDR Information System (TRACES NT).
• Farmer financial inclusion by linking traceability with payments, inputs, and productivity data.

eProd Solutions: Bridging the EUDR Compliance Gap in African Agriculture

At eProd Solutions, we believe environmental compliance should never come at the expense of local economic viability.

Since 2015, we have worked across 22 African countries with both small cooperatives and large agribusinesses in the:

• Cocoa
• Coffee
• Rubber
• Palm oil
• Soybean

sectors.

Our platform—eProdTrace™—provides modular, scalable, and cost-effective EUDR traceability tools specifically built for African agriculture.

These include:

• GPS and polygon mapping
• Legality and deforestation risk surveys
• Cooperative-level chain of custody
• DDS-ready reporting
• Farmer payment integration

Our solutions are priced for African market realities—not European enterprise budgets.

We are proud of the progress achieved alongside our partners.

With collaboration between producers, buyers, governments, and technology providers, EUDR compliance is achievable without leaving smallholder farmers behind.

What Should Your Organization Do Before 30 December 2026?

If your business sources, exports, or trades cocoa, coffee, rubber, or palm oil destined for the EU market, now is the time to act.

Ask yourself:

• Do you have GPS coordinates or polygon data for every farm plot in your supply chain?
• Can you demonstrate that sourcing areas were not deforested after 31 December 2020?
• Do you have a documented due diligence process that meets EUDR requirements?
• Are your traceability records audit-ready and ready for submission through the EU Information System?

If you answered No to any of these questions:

• Download our free EUDR Checklist.
• Assess your current level of readiness.
• Speak with our team about how we can help.

References

[1] European Commission (2026). Commission updates product scope and tools to support EUDR. 13 July 2026.
https://environment.ec.europa.eu/news/commission-updates-product-scope-and-tools-support-eudr-2026-07-13_en

[2] European Parliament (2023). Regulation (EU) 2023/1115 on commodities and products associated with deforestation and forest degradation.

[3] International Cocoa Organization (2025). February 2025 Quarterly Bulletin of Cocoa Statistics.

[4] Ghana Cocoa Board (COCOBOD) (2023). Ghana Cocoa Traceability System (GCTS) Launch.

[5] ISEAL Alliance (2025). Navigating EUDR: Compliance and Beyond | Cocoa.
https://isealalliance.org/node/5360