NEWS EXTRA
A debate over the strength of due diligence The coalition has also raised concerns about how deforestation risk should be assessed under the UK regulation. Previous government guidance suggested that companies might apply an “as low as reasonably practicable” (ALARP) approach when conducting due diligence. Coalition members argue that this standard
For companies with ambitious sustainability
commitments, regulation is increasingly viewed as a mechanism to ensure that voluntary initiatives are supported by sector- wide standards.
Aligning with Europe’s deforestation rules Another central theme of the coalition’s position is the need for regulatory alignment between the UK and the European Union. The EU’s Deforestation Regulation
(EUDR) will apply fully from the end of 2026 and introduces strict due-diligence requirements for commodities including cocoa, coffee, palm oil and soy. Because many cocoa and chocolate
companies operate across both jurisdictions, differing regulatory systems could create unnecessary compliance burdens. The coalition therefore recommends
recognising EU due-diligence statements as valid evidence under the UK regulation and ensuring transparency across supply chains after the point of import. This would allow companies exporting
chocolate products from the UK to the EU to meet the requirements of both markets more efficiently.
does risk undermining the effectiveness of the legislation because it allows companies to balance risk management against commercial considerations. Instead, the group recommends adopting a “negligible risk” standard — similar to that used under the UK Timber Regulation — which requires companies to demonstrate that the risk of illegal deforestation is minimal. Supporters say this approach would provide
clearer legal expectations and more consistent enforcement across the sector.
What does the industry say?
Marc Donaldson, Chief Chocolate Officer, Oumé “The very last thing that the cocoa industry needs, is another splinter group who believe they will have some sort of impact. I thought that Together Cocoa was hopefully the end of this madness, but patently not. How can the UKCC have any impact, when clearly the entire industry has now clearly failed after 25 years, and billions of dollars of investment. The shambles that is the EUDR, soon to be re-shaped for the 3rd (4th) time, clearly demonstrates that this is not the way forward.”
THIS IS A MOMENT TO EMBED SHARED RESPONSIBILITY
FOR COMPLIANCE ACROSS THE SUPPLY CHAIN, WITH COMPANIES SUPPORTING
PRODUCERS THROUGH FAIR PRICING, INVESTMENT AND MEANINGFUL ENGAGEMENT
How cocoa sustainability regulation has evolved
2010s – Voluntary sustainability initiatives Chocolate manufacturers introduced programmes focused on certification, farmer training and traceability in response to growing scrutiny of cocoa supply chains.
2017–2020 – Focus on deforestation Attention turned increasingly to commodity-driven deforestation, with cocoa identified as a significant driver of forest loss in parts of West Africa.
2021 – UK Environment Act adopted The Environment Act 2021 introduced
provisions allowing the UK to regulate commodities associated with illegal deforestation.
2023–2026 – EU introduces new rules The EU Deforestation Regulation (EUDR) established strict due-diligence requirements for companies placing commodities such as cocoa on the EU market.
2026 – Formation of the UK Cocoa Coalition Industry and civil-society organisations launched the coalition to encourage the UK government to implement the regulation and align it with EU rules.
Simon Wright, Founder OF Plus Consultancy “I welcome the UKCC initiative to support cocoa farmers worldwide. As an industry we can only be confident about our future if we tackle the long-term issue of cocoa farmers not receiving a living income. For too long this has not been a priority for the major players in the cocoa processing industry, I hope that the formation of the UKCC indicates that the provision of a sustainable livelihood for cocoa producers is finally being taken seriously by those who can make a real difference.”
Clay Gordon, Creator & Moderator of TheChocolateLife “The UKCC has plans to lobby UK regulators to use the UKFRC as a lever to support farmer livelihoods, address human-rights violations, in the process of tackling illegal deforestation. Farmers will not benefit (from the UKCC’s efforts), unless specific targets that provide living wages are implemented in the UKFRC regulations, which provisions may not be legally enforceable in Ghana.”
APRIL 2026 • KENNEDY’S CONFECTION • 11
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