LONDON CHOCOLATE FORUM REVIEW 2026


EUDR RAISES THE STAKES FOR COCOA TRADERS


Nicko Debenham, Managing Director of Sustainability Solutions, told delegates at the London Chocolate Forum 2026 that the EU Deforestation Regulation will fundamentally change cocoa trading, turning farm-level traceability and due diligence into commercial necessities — with significant consequences for suppliers unable to demonstrate compliance.


F


or Nicko Debenham, the cocoa industry has reached a point where sustainability can no longer be treated as a voluntary commitment or a


response to reputational pressure. With the EU Deforestation Regulation (EUDR) approaching implementation, he warned delegates at the London Chocolate Forum 2026 that the ability to prove where cocoa comes from is becoming a condition of doing business. Drawing on four decades in cocoa and


chocolate, including his former role as Head of Sustainability at Barry Callebaut and his chairmanship of the World Cocoa Foundation, Nicko traced how the industry’s approach to sustainability has evolved. The catalyst, he explained, was the exposure of child labour in West African cocoa production in a UK television documentary in 2000, which prompted a political response in the United States and ultimately the Harkin–Engel Protocol. He was critical of the motives behind some


of the industry’s early responses. Certification, he argued, was not always introduced to solve the underlying problems. “It wasn’t really, they weren’t really thinking about a solution. They were thinking about defence against accusation,” he said. That distinction has become increasingly


important as governments move from voluntary initiatives and financial incentives towards regulation. Nicko described the EUDR as part of a wider shift in which companies must demonstrate that their supply chains meet legal requirements, rather than simply publish sustainability commitments. The regulation requires relevant cocoa and


cocoa products placed on or exported from the EU market to meet deforestation-free and legality requirements. Businesses must establish where products originate, assess risks and retain the information needed to demonstrate compliance. The European Commission’s current timetable sets 30 December 2026 for large and medium-sized operators and traders, with 30 June 2027 for most micro and small operators. For cocoa, the practical challenge is


18 • KENNEDY’S CONFECTION • OCTOBER 2026


considerable. Supply chains often involve thousands of smallholder farmers, numerous plots and several intermediaries between farm and buyer. Nicko explained that plots must be geolocated, data checked and records linked to the cocoa moving through the supply chain. “You cannot manage this on spreadsheets. It


just is not possible,” he said, arguing that digital systems are essential to handle the volume of farm and supplier information involved. The stakes are not confined to environmental


reporting. Nicko warned that a trader could face a far greater loss if cocoa arrived with data that


proved non-compliant than from the familiar risks of weight loss or quality issues. “If your supply chain is not compliant, then


you just go somewhere else,” he said. It was a blunt assessment of the commercial


choices facing buyers. In his view, businesses should distinguish between suppliers that can demonstrate compliance, those willing to become compliant with support, and those unwilling to make the necessary changes. The difficulty is that the cocoa industry cannot simply replace entire sourcing regions without consequences, particularly given West Africa’s importance to global supply. Nicko also highlighted the potential for


disputes when buyers and sellers interpret farm data differently. Without consistent systems and clear contractual arrangements, a supplier might consider a plot compliant while its customer reaches the opposite conclusion. He urged companies to think carefully about the information accompanying a transaction and their obligations if that information proves inadequate. Yet his argument was not simply that


YOU CANNOT MANAGE THIS ON SPREADSHEETS. IT JUST IS NOT POSSIBLE


businesses should protect themselves by excluding risk. He distinguished legal compliance from sustainability, while recognising that the two are connected. Farmers facing poverty may lack the resources to map their land, improve practices or meet new requirements. Helping producers address the causes of non- compliance, he suggested, must form part of a credible response. During the question-and-answer session,


delegates raised concerns that cocoa unable to meet EU requirements could be redirected towards markets such as the UK, where the equivalent regulatory framework is not yet in force. Nicko acknowledged that possibility, highlighting the potential for regulation in one market to alter trading patterns elsewhere. Asked whether the EUDR would make a


difference on the ground, he replied: “I think it will, personally.” He explained that mandatory traceability would force businesses to confront problems in their supply chains that might previously have remained hidden.


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