EU & UK regulations on deforestation and the social and environmental challenges facing the cocoa sector in Côte d'Ivoire

The document examines the potential for EU and UK deforestation regulations to drive legislative reform in Côte d'Ivoire's cocoa sector. While the EUDR's benchmarking and traceability requirements offer incentives for better forest governance and transparency, the report warns of risks to smallholder farmers, including potential exclusion from markets due to compliance costs and the persistence of child labour driven by poverty.

• The EUDR introduces a benchmarking system that assigns risk levels (low, standard, or high) to producer countries, which could incentivise Côte d'Ivoire to improve forest governance to gain a competitive advantage and lower compliance costs for operators.
• There is a significant discrepancy between EUDR definitions of deforestation and Ivorian legislative definitions, meaning cocoa produced through 'legal deforestation' under Ivorian law may still be non-compliant with EU regulations.
• The EUDR requires traceability to the farm level, which is currently lacking in Côte d'Ivoire; the report recommends a centralised national traceability system led by the Conseil Café-Cacao (CCC) to ensure transparency and public ownership of data.
• The EUDR's 'substantiated concerns' mechanism allows third parties to report non-compliance to EU authorities, providing an opportunity to strengthen Independent Monitoring (IM) by civil society organisations in Côte d'Ivoire.
• While the UK Environment Act focuses on legality regarding land use and ownership, the EUDR's scope includes labour and human rights protected by international law, meaning child labour in the cocoa sector could lead to non-compliance.
• Smallholder farmers face a high risk of being excluded from EU supply chains because they cannot afford the compliance and record-keeping costs associated with the EUDR, and the regulation's review of these impacts will not occur for five years.
• The implementation of geolocation and digital services required by the EUDR could indirectly benefit producers by enabling electronic payments, reducing the role of intermediaries, and combating fraud.
• The complexity and fragmentation of Ivorian land tenure and forestry laws create compliance risks; the report suggests creating non-exhaustive lists of relevant national and sub-national laws to guide operators and authorities.

APA

Kra, R., Godts, R., & Haywood, C. (2023). EU & UK regulations on deforestation and the social and environmental challenges facing the cocoa sector in Côte d'Ivoire. ClientEarth. https://www.clientearth.org/media/2olk01ph/eu-uk-regulations-on-deforestation-and-the-social-and-environmental-challenges-facing-the-cocoa-sector-in-cote-d-ivoire.pdf

Chicago

Kra, Raphaël, Raphaëlle Godts, and Caroline Haywood. EU & UK regulations on deforestation and the social and environmental challenges facing the cocoa sector in Côte d'Ivoire. ClientEarth, 2023. https://www.clientearth.org/media/2olk01ph/eu-uk-regulations-on-deforestation-and-the-social-and-environmental-challenges-facing-the-cocoa-sector-in-cote-d-ivoire.pdf.

Wikipedia

{{cite report |last1=Kra |first1=Raphaël |last2=Godts |first2=Raphaëlle |last3=Haywood |first3=Caroline |title=EU & UK regulations on deforestation and the social and environmental challenges facing the cocoa sector in Côte d'Ivoire |publisher=ClientEarth |date=July 2023 |url=https://www.clientearth.org/media/2olk01ph/eu-uk-regulations-on-deforestation-and-the-social-and-environmental-challenges-facing-the-cocoa-sector-in-cote-d-ivoire.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{kra2023regulations, author = {Kra, Raphaël and Godts, Raphaëlle and Haywood, Caroline}, title = {{EU \& UK regulations on deforestation and the social and environmental challenges facing the cocoa sector in Côte d'Ivoire}}, institution = {ClientEarth}, year = {2023}, month = jul, url = {https://www.clientearth.org/media/2olk01ph/eu-uk-regulations-on-deforestation-and-the-social-and-environmental-challenges-facing-the-cocoa-sector-in-cote-d-ivoire.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }