LCF REVIEW
From voluntary goals to a legal imperative Vincent began by recalling the origins of the sector’s traceability drive. “It was the Cocoa & Forests Initiative that first made it explicit back in 2017 that we had an objective of 100 percent traceability,” he said. “That was the moment the sector declared where it wanted to go.” Those commitments, he noted, have
since been overtaken by law. “EUDR has accelerated everything. What was once voluntary is now non-negotiable.” The EUDR, part of the European Green
Deal’s sixteen legislative pillars, requires that all cocoa and chocolate entering the EU be proven deforestation-free and fully traceable to farm level. But Vincent reminded the audience to keep perspective: “We get very tied up in cocoa—we’re obsessed with EUDR and all its details. Yet cocoa represents only about two percent of the total economic value covered by this regulation.” That context matters, he argued,
because cocoa’s experience can either model or mirror the broader global shift in sustainable supply chains.
“A political, not just a technical regulation” Vincent devoted much of his talk to explaining how the EUDR came into being—and why its complexity is no accident. “EUDR didn’t drop out of nowhere,” he said. “It’s one building block of the Green Deal, which itself came out of EU voter demand for a greener agenda. When the law was written, three poles had to align—the Council, the Parliament, and the Commission—and each of them sees things differently.” That political architecture, he
explained, means implementation will vary across Europe. “You’ve got a law written by three different organisations, interpreted by the civil service, and then interpreted nationally again. Each of the 27 Member States has its own ‘competent authority’. That’s why it feels confusing— because it is.” As of his address, confusion was indeed
widespread. The European Commission had already signalled another delay to the law’s applicability, citing the unreadiness of national authorities and the EU’s own IT infrastructure. “Last year’s delay was deliberate,” Vincent told the room. “The national competent authorities were simply not ready—we weren’t getting any answers. Even the Commission itself couldn’t answer for six months. There was no way this was going to work.” He smiled wryly. “If what they’re asking for for one container of cocoa
Kiran Grewal and Chris Vincent REAL PROGRESS IN SUSTAINABILITY IS ONLY
POSSIBLE IF WE KNOW WHERE OUR COCOA COMES FROM. AND THAT JOURNEY HAS ALREADY BEGUN”
“If you’ve got no volume associated with a GPS point, anyone could put their cocoa on a truck, drive it to that point, and call it compliant. That’s not traceability—that’s fiction.” Instead, Vincent said, the industry needs
robust, interoperable systems validated by third parties. “We’re not going to write our own protocols. We need industry-wide standards,” he stressed. “We’ve worked with the European Forest Institute and the Joint Research Centre of the EU to validate our technical approach externally. That independence is crucial.”
is something like a gigabit of data, the system simply isn’t capable of taking it— even if it understood what it was asking for.”
Traceability: From GPS points to credible data The core of Vincent’s argument was that traceability—done properly—is both the industry’s biggest challenge and its greatest opportunity. “To comply, you need to know where your cocoa came from,” he explained. “That means GPS or polygon mapping of every plot, tied to a volume, then checking whether that plot has been deforested since 2020, and whether the cocoa was produced legally.” He warned against superficial solutions.
Readiness and reality For many in the room, the question was not whether traceability matters—but whether the sector can deliver it fast enough. Vincent was candid about progress:
“Traceability systems are now in place to an extent that was unthinkable three or four years ago. We’ve built a foundation.” But, he added, “real sustainability efforts have got to be based on traceability. We cannot make genuine progress if we don’t know where our cocoa comes from.” He acknowledged that companies
are anxious about shifting deadlines and uncertain compliance criteria. The Commission’s latest proposal would extend the EUDR’s applicability to 30 December 2026 for most operators, following industry concern over the readiness of the EU’s data platform. Yet Vincent cautioned against complacency. “Don’t assume delay means you can slow down,” he said. “Use the time to get ready. Because when the switch flips, only those with credible systems will be able to sell into Europe.”
Data, AI and the predictive future Perhaps the most forward-looking section
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