does the deforestation regulation apply to products containing cacao, for example

Processed cocoa falls under the EUDR if it is a listed product

Yes, a product containing an EUDR material may fall under the regulation — but not because the material is in it, rather because the end product itself is on the product list. The deforestation regulation works with a list of products, linked to CN codes, in the annex to Regulation (EU) 2023/1115. Chocolate, for example, is listed there with cocoa, so a chocolate bar falls under the same obligations as the cocoa beans from which it is made. If cocoa is processed into a product not on the list, the regulation does not apply to that product, even though an EUDR material is indeed processed into it.

This is precisely why the question "does it contain cocoa?" is the wrong question. The correct question is whether the specific end product, with its own CN code, is mentioned in the annex. Two products with the same amount of cocoa in them can therefore be treated differently, solely because one product category is included and the other is not. Anyone in doubt about this for a specific article will find an overview of what exactly falls under the regulation on the page on which products fall under the EUDR. The list itself is not set in stone either: in July 2026, amendments to the product scope were made, and what exactly was added or removed is described on the page on the amended product list of July 2026.

What this is based on: the annex to the regulation

The scope of the EUDR is derived from the annex to Regulation (EU) 2023/1115, which links the relevant materials and products to CN codes; only products named and coded in that annex fall under the obligations. The Commission amended that product scope on 13 July 2026, which means the precise list currently presents a different picture than when the regulation was first adopted. For a specific product it is therefore necessary to consult the current annex and the CN code of that product, not merely to check whether a named material is processed into it.