For an EUDR declaration for cocoa, you typically need five types of documents: trade documents that record product and quantity, information about your supplier, geolocation data from the parcels where the cocoa was grown, proof that production complies with the legislation of the country of origin, and — if you are not the first link in the chain — the reference numbers of earlier declarations already submitted in the chain.
With cocoa, one component is almost always the most difficult: the geolocation data. Cocoa often comes from many small parcels that are combined via a cooperative or local buyer before they reach you. This means you do not need to trace one parcel, but potentially dozens or hundreds, scattered across different growers. In practice, this detail determines how much time and consultation a cocoa dossier requires, more so than with raw materials with less fragmented agricultural land.
The basic documents that belong to virtually every cocoa supply chain
The core of every dossier consists of the usual trade papers: invoices, purchase contracts, delivery notes and the commodity code under which the consignment is imported. You also record who the supplier is, with name, address and possibly a business number. This is similar to what applies to every raw material, and that is correct — it is the foundation on which the rest of the dossier rests. Without a complete record of who supplied what, the rest of the dossier cannot be substantiated.
Why this requires slightly more attention with cocoa
With cocoa, supplier relationships often run through multiple layers: grower, cooperative, local exporter, and only then your direct trading partner. Each layer adds a link that you must make transparent. That is not a problem of document type, but of number of links — and that number is typically higher with cocoa than with, for example, timber or cattle.
Geolocation data: the document that raises the most questions
Geolocation data is the component where cocoa importers most often run into difficulties. For each parcel the cocoa comes from, a location is needed, and for larger parcels it involves a complete boundary rather than a single coordinate. The problem is not the rule itself, but the practice: a cooperative often works with hundreds of affiliated growers, and that information must be recorded centrally and consistently somewhere before it reaches you.
It is therefore advisable to discuss early with your supplier or cooperative how those parcels are registered and whether that overview already exists, or still needs to be developed. Those seeking more background on this will find in the knowledge base where geolocation is explained per situation a detailed explanation of what geolocation data must exactly contain.
Proof of legality in the country of origin
In addition to the origin itself, the dossier should also include evidence that production complies with the legislation of the country from which the cocoa originates. Think of land use rights, permits for agricultural land, and where applicable export documentation. Which documents are exactly relevant varies by country: some countries have a more extensive licensing system than others, and the risk classification of the country of origin plays a role here. That is not a fixed template that you can simply adopt — it requires looking at what is standard and required for each country of origin.
Aggregation via cooperatives: the point where time is most often lost
Because cocoa often flows through cooperatives, it is customary for plots from multiple growers to be combined into a single supply batch. This does not invalidate the file, but it does require care: double counting of the same plot across different deliveries, or plots that are accidentally missing, are the most common errors. A good starting point is to ask whether the cooperative already maintains a central overview of affiliated growers and plots, rather than having you reconstruct this yourself per shipment.
Retention and submission of the file
The collected documents must not only be complete, they must also be retained for a set period and in a way that you can retrieve later. How you structure that data and where it comes from, you can read in how we process supplied data into a file. Supplier and grower data is also sensitive information, and it is good to know in advance how that data is handled before you share it.
Which documents exactly belong to your situation depends on your role in the supply chain and on the country of origin. Do you want to first know where you stand before building a complete file? Take the free role check and find out in a few questions which role and obligation apply to you, or browse through the knowledge base for more topics on cocoa and the other commodities.