The EUDR requires the precise geolocation of a production area, which can be a significant challenge to ascertain in the context of smallholder production. The sourcing of cocoa is currently split 50:50 between direct and indirect supply chains. In the latter case, cocoa is purchased via local intermediaries with raw material from various production plots potentially being mixed, complicating the tracing of cocoa beans back to plot. The difficulty with providing 100% traceability is most challenging for smallholder farmers who risk losing market access to the EU if their conditions of production and trade do not meet traceability requirements. This will directly affect the livelihoods and income of millions of farmers who may not have the financial means to set up their traceability and compliance systems at source.

The process of collecting and validating quality geolocation data is labour intensive. This burden often falls on the farmer organisations and their members, potentially diverting resources from other essential farming activities. Fairtrade International’s producer networks estimate that each producer organisation requires between €5,000 and €15,000 to fund geolocation data collection, depending on the region and size of the groups. This could put further financial pressure on cocoa producers already struggling with low incomes, climate change and economic insecurity.

The EUDR’s legal production requirement means that, as well as being deforestation-free, products in scope must have been produced in compliance with the laws of the country of production. Proving legality can be difficult – particularly when it comes to land rights.

In major cocoa-producing countries like Ghana and Côte d’Ivoire, most land is held under customary tenure rather than formal titles: around 80% of land in Ghana is under customary ownership and largely undocumented, and in Côte d’Ivoire, only about 4% of rural land is covered by a certificate or title. While farming on such land is often legal, most smallholders lack documentation to prove their land-use rights – making it harder to demonstrate compliance.

The Fairtrade cocoa standard requires certified producer organisations to strengthen their deforestation prevention, monitoring and mitigation. While Fairtrade’s deforestation cut-off date for cocoa is 2018 – earlier than the EUDR’s 2020 cut-off – the system is being adapted to further support businesses with the regulation. In line with the EUDR, farms larger than four hectares or located in high-risk areas must use polygon mapping, while smaller farms may use single geolocation points.

To support deforestation monitoring, Fairtrade International has partnered with Satelligence to provide free satellite data to all certified cocoa producer organisations. This helps cooperatives understand deforestation risks in their supply base and share relevant information with trade partners. Fairtrade also offers essential guidance on the data and formats required by the EUDR, along with detailed multilingual support materials to ensure producers can access and use this information effectively. Fairtrade support materials provided to cooperatives are combined with access to direct support from Fairtrade’s producer networks who are based in the countries of production. This cooperative support includes assistance from data analysts to help cooperatives who may encounter challenges with geolocation data quality.

The Rainforest Alliance’s Sustainable Agriculture Standard does not allow the certification of farms where natural ecosystems were destroyed or converted after 1 January 2014, also going beyond the EUDR’s cut-off date. They’ve developed automated deforestation risk assessment maps and require all certified farms to be GPS mapped with satellite verification. Deforestation risk is assessed using forest baseline data that covers farms and risks beyond certified crops. These results are shared with farm certificate holders and the certification bodies that audit them. All cocoa farm certificate holders are also audited against additional EUDR-aligned requirements.

Credible VSS can play a key role in verifying information required to comply with the EUDR’s legal production requirements. The Rainforest Alliance’s Sustainable Agriculture Standard requires legal and legitimate land use rights, which auditors verify through official documents or the absence of land disputes. All farm certificate holders must comply with applicable laws and collective bargaining agreements. Certification bodies undertake an applicable law assessment for each country to ensure auditors can verify legal compliance. Fairtrade International’s Standards require producers and hired labour operations to comply with national laws on land tenure, labour rights, and environmental protection, with audits conducted by FLO-CERT, Fairtrade’s independent certification body, to verify compliance.

Fairtrade International recognises that data and information are key to tracing products back to their origin. It provides support to producer organisations through its regional producer networks, offering guidance on EUDR data requirements and facilitating the collection of geolocation data. Producer organisations submit data via FairInsight, a platform which enables producers to report and share information with their trade partners. Crucially, Fairtrade’s approach places producer ownership of this data at its core.

Fairtrade offers various chain of custody (CoC) models, depending on the product:

• Identity preserved (IP): traceable to the producer organisation.
• Segregated: certified and non-certified products are kept separate.
• Mass balance: certified and non-certified products may be mixed, with strict volume tracking.

The Fairtrade Cocoa Standard requires segregation of fairtrade cocoa from non-certified cocoa, from the producer organisation level up to first buyer. Additionally, geolocation and plot-level traceability data may be transferred with certified cocoa to support EUDR compliance. Traders within the Fairtrade system may use IP and segregated CoC models to support their EUDR compliance. The mass balance CoC model remains a permitted and recognised model for cocoa.

Rainforest Alliance also offers multiple CoC models for cocoa:

• Identity preserved: traceable to an individual certified farm or farm group.
• Mixed IP: material from multiple certified farms or farm groups is mixed but remains traceable to one or more known groups of producers.
• Segregated: certified and non-certified products are kept separate.
• Mass balance: certified and non-certified material may be mixed, with strict volume tracking.

For supply chains choosing IP or mixed IP models, certified supply chain actors can use the Rainforest Alliance Certification Platform and digital dashboard to identify farm certificate holders who are EUDR-aligned. These farms and farm groups have provided and agreed to share geolocation data for all relevant cocoa plots, with polygon mapping required for larger plots. The Rainforest Alliance supports data collection at farm level with tools and training and makes EUDR relevant data available to supply chain certificate holders in downloadable files and in a format compatible with the EU System.

Since cocoa sourced via segregated or mass balance supply chains is not traceable back to farm level, EUDR-alignment needs to be ensured outside of the Rainforest Alliance certification and traceability system. However, a list of EUDR-aligned farm certificate holders is publicly available on the Rainforest Alliance website.

Traceability is central to EUDR compliance, and credible VSS like Fairtrade and Rainforest Alliance help ensure it is implemented fairly through strong engagement across the supply chain. They clarify roles and responsibilities not only for traders and importers, but also for brands and producers, support data transfer through digital platforms, and help share compliance responsibilities, reducing the risk that smallholders are excluded. This turns traceability from a box-ticking exercise into a foundation for more inclusive and resilient supply chains.

Both schemes go beyond regulatory requirements by addressing the underlying drivers of deforestation, particularly poverty and insecure livelihoods. Fairtrade promotes fair pricing, supports income improvements through Fairtrade prices, and empowers producer organisations to invest the Fairtrade Premium in forest protection. A Fairtrade International project funded by the ISEAL Innovations Fund is working to strengthen smallholder control over their data and influence in the supply chain. The Fairtrade approach is also one which goes beyond mere regulatory compliance, aligning with an ecosystem approach to data ownership and a commitment to protecting forests that predates the EUDR. Further, Fairtrade views the relationship between achieving economic gains and protecting forests as mutually reinforcing; By addressing root causes of deforestation such as poverty through income-relevant interventions, producers are better positioned to adopt climate-resilient practices, including adaptation and mitigation plans and good agroecological practices that help combat deforestation. Likewise, sustainable agricultural practices have the potential to positively impact producers’ economic gains.

As well as supporting livelihoods, the Rainforest Alliance stresses the crucial role of landscape-level approaches, investing in sustainable land management, biodiversity conservation, restoring degraded lands and climate-smart, regenerative agriculture. By taking a broader ecosystem-level approach, it encourages companies to support geodata collection and invest in producer livelihoods as part of longterm forest conservation. This direct economic focus on improving livelihoods to combat deforestation is an important holistic approach to tackling issues like deforestation, going well beyond a regulatory approach that bans the entry of products linked to deforestation in the EU market.

Both organisations play a vital role in enabling smallholder producers to meet complex data and risk monitoring requirements. Rather than placing the burden solely on producers, Fairtrade and the Rainforest Alliance provide guidance, training, and in-field support to facilitate the collection and use of geolocation and deforestation-risk data.

Fairtrade offers practical resources and access to satellite-based deforestation data, while the Rainforest Alliance has developed automated risk assessment tools and customised satellite-based risk maps that support farm groups and certification bodies with proactive risk monitoring.

By embedding these services within their sustainability frameworks, both systems reduce the administrative burden on producers and ensure that the producers themselves retain data ownership. This approach goes beyond compliance by strengthening long-term producer capacity, improving decision-making, and ensuring that smallholders can actively participate in and benefit from global supply chains.

Credible VSS, including Fairtrade and Rainforest Alliance, provide reliable guidance, tools, and support to help businesses meet their EUDR requirements while fostering more resilient, inclusive, and sustainable cocoa supply chains.

• Fairtrade Standard for Cocoa
• Fairtrade Risk Map – Cocoa
• Fairtrade Impact Platform
• The effect of Fairtrade on forest protection and deforestation prevention
• Rainforest Alliance list of EUDR-aligned farm certificate holders
• Rainforest Alliance Learning Network E-course on EUDR
• How the Rainforest Alliance Supports EUDR Compliance from Farm to Retailer
• Rainforest Alliance Tools for Deforestation-free Supply Chains
• ASI’s Independent Assessment of Rainforest Alliance’s Alignment with EUDR Guidance Document