Updated: The UKFRC & UKCC: EUDR 2.0 Lite? | #PSC 192
Episode 192 of #PodSaveChocolate takes a look at the recent formation of the UK Cocoa Coalition, which hopes to influence the implementation of the UK Forest Risk Commodities regime. OR, is it Brexit-induced EUDR FOMO?
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Episode 192 streamed on Tuesday, March 31st, 2026.
Click a link below to view the archived episode.
Click a link below to view the archived episode.
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This post was updated on Wednesday, April 1st, to include the link to the UKCC post on LinkedIn with an embedded PDF that (IMO) does not clarify the most important issues I discussed in the episode. I have also included the link to Cocoa Radar coverage on this topic.
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Episode 192 Overview
This episode of #PodSaveChocolate takes a look at a story that exploded in my feeds on Monday, March 30th (much of the information is behind registration paywalls, but I was able to retrieve it using other means):
Barry Callebaut, Ferrero, Hershey & Tonyâs Chocolonely join Cocoa Coalition
A look at how major chocolate makers (Barry Callebaut, Ferrero, The Hershey Company & Tonyâs Chocolonely), NGOs (Rainforest Alliance, Fairtrade Foundation, WWF, International Cocoa Initiative, Sustainable Trade Initiative, and VOICE Network) and retailers (Sainsburyâs, Marks & Spencer, and Waitrose) uniting under the UK Cocoa Coalition marks a pivotal shift toward sustainable cocoa sourcing - and why this collaboration signals positive change for the future of cocoa and chocolate.
Donna Eastlake
Exclusive: UK Cocoa Coalition aims to deliver sustainable sourcing goals - Confectionery Production
Barry Callebaut, Ferrero, Hershey and Tonyâs Chocolonely are among a landmark UK Cocoa Coalition alongside leading civil organisations, coinciding with the 2026 International Day of Forests, seeking urgent delivery of key industry legislation
UK Cocoa Coalition Calls for Action - International Confectionery Magazine
To mark International Day of Forests 2026, a new UK Cocoa Coalition has launched today in Parliament.
Editor
Chocolate industry pushes UK Government for ban on deforestation-linked imports - edie
Marks & Spencer, Barry Callebaut and Ferrero are among the members of a new cocoa industry coalition urging the UK Government to âurgentlyâ implement a much-delayed ban on deforestation-linked imports.
Sarah George
Some detail on the UKFRC (registration âpayâwall).
UK Cocoa Coalition publishes position statement on UK Forest Risk Commodities Regulation - Business and Human Rights Centre
Check out this page via the Business and Human Rights Centre
The UKCC âPosition Paperâ
UK Cocoa Coalition position statement on Environment Act | UK Cocoa Coalition
UK Cocoa Coalition calls for action on Environment Act provisions on forest risk commodities Cocoa production is still too often accompanied by deforestation and human rights abuses. The UK government can play a role in combating this and contributing to the development of secure and sustainable cocoa supply chains by bringing into force legislation that places conditions on the ways in which the cocoa imported into the UK is grown and harvested. The UK Forest Risk Commodities Regulation included in the Environment Act 2021 is designed to do just this, but more than four years after the Act was passed, it is still not in force, and the government has failed to confirm that it intends to do so or to set out a timetable. The UK Cocoa Coalition calls on the government to: 1 End the current uncertainty over the entry into force of the UK Forest Risk Commodities Regulation. 2 Publish the necessary statutory instrument as soon as possible. 3 Align the requirements of the Regulation with those of the EU Deforestation Regulation. 4 Engage with all stakeholders in the cocoa and chocolate supply chains in implementing and reviewing the requirements of the UK Regulation. For more detail, see the attached position statement.
UK Cocoa Coalition
Cocoa Radarâs Questions
Three Uncomfortable Questions for the UK Cocoa Coalition
CocoaRadar comment: A strong political signal â but can it deliver real-world change?
Anthony Myers
This post appears to be free. There is more detailed coverage (behind a paywall) here.
Topics
- What are the UK Forest Risk Commodities Regulations? Goals? Status?
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The UK Forest Risk Commodities rules are a not-yet-operational UK dueâdiligence regime targeting illegally produced forestârisk commodities.
- What is the UK Cocoa Coalition? Who are its members, and what is its mission?
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The UKCC âlaunchedâ around International Day of Forests 2026 (specifically, on March 24th).
Members include major chocolate manufacturers (Barry Callebaut, Ferrero, The Hershey Company, Tonyâs Chocolonely), large UK retailers (e.g., Sainsburyâs, Marks & Spencer, Waitrose), and prominent NGOs and trade bodies (Rainforest Alliance, Fairtrade Foundation, WWF, International Cocoa Initiative, IDH, VOICE Network, among others).
Members include major chocolate manufacturers (Barry Callebaut, Ferrero, The Hershey Company, Tonyâs Chocolonely), large UK retailers (e.g., Sainsburyâs, Marks & Spencer, Waitrose), and prominent NGOs and trade bodies (Rainforest Alliance, Fairtrade Foundation, WWF, International Cocoa Initiative, IDH, VOICE Network, among others).
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Note: Take a close look for webs of potential conflicts of interest. For example, Antonie Fountain is a C-Suite employee of VOICE Network and is an advisor to Be Slavery Freeâs Chocolate Scorecard; that affiliation is not acknowledged on The Chocolate Scorecard website.
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The coalition is not neutral; it is explicitly calling on the UK government to: a) bring the UK Forest Risk Commodities Regulation into force swiftly; b) align UKFRC closely with the EUDR, including a strong deforestationâfree standard; c) use the UKFRC as a lever to support farmer livelihoods, address humanârights violations, and tackle illegal deforestation.
One of the key framings (in the announcement and reporting) is that âsustainability is no longer a competitive differentiator but an industry baseline.â That is a normative statement from industry and civil society that regulations like UKFRC/EUDR are becoming table stakes for market access and brand legitimacy, particularly for cocoa.
One of the key framings (in the announcement and reporting) is that âsustainability is no longer a competitive differentiator but an industry baseline.â That is a normative statement from industry and civil society that regulations like UKFRC/EUDR are becoming table stakes for market access and brand legitimacy, particularly for cocoa.
- How is the UKFRC different from (and the same as) the EUDR?
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UKFRC â legality-based, âillegal deforestationâ focus. The UKFRC is built around local legality, not an absolute deforestation ban: affected UK businesses must not use covered commodities if they were produced on land used or occupied in violation of local landâuse or landâtenure law in the country of production.
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EUDR â noâdeforestation + legality. The EUDR combines an absolute deforestation cutâoff with a legality requirement. Products must be deforestationâfree, meaning they cannot come from land deforested after 31 December 2020, regardless of whether that deforestation was legal locally.
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Scope: covered (in-scope) commodities
UKFRC: Cattle products (beef and leather; dairy excluded), cocoa, palm oil, soy. Products derived from these commodities are also covered (including âwasteâ and byâproducts). Timber is excluded here because it is handled under separate UK timber rules.
EUDR: Wood and wood products, soy, beef, palm oil, cocoa, coffee, rubber; plus a wide range of derived products (e.g., chocolate, leather, paper, some furniture).
UKFRC: Cattle products (beef and leather; dairy excluded), cocoa, palm oil, soy. Products derived from these commodities are also covered (including âwasteâ and byâproducts). Timber is excluded here because it is handled under separate UK timber rules.
EUDR: Wood and wood products, soy, beef, palm oil, cocoa, coffee, rubber; plus a wide range of derived products (e.g., chocolate, leather, paper, some furniture).
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Scope: who must be in compliance
UKFRC: Targets large, highâvolume UK users. Size threshold: global annual turnover > ÂŁ50 million. Volume threshold: use of more than 500 tonnes/year of each inâscope commodity; those using â¤500 tonnes may apply (not automatically) for an exemption. Covered activities include: producing, manufacturing, processing, distributing, selling, supplying, or purchasing covered commodities and derivatives as part of UK commercial activity (irrespective of the consumersâ location(s)).
EUDR: Applies to operators and traders placing covered commodities and products on, or exporting them from, the EU market. There is no turnover or tonnage de minimis; instead, SMEs get somewhat simplified obligations, but they are still in scope. The obligations cascade across the supply chain (importers, manufacturers, traders), creating a wider net than UKFRCâs current design.
UKFRC: Targets large, highâvolume UK users. Size threshold: global annual turnover > ÂŁ50 million. Volume threshold: use of more than 500 tonnes/year of each inâscope commodity; those using â¤500 tonnes may apply (not automatically) for an exemption. Covered activities include: producing, manufacturing, processing, distributing, selling, supplying, or purchasing covered commodities and derivatives as part of UK commercial activity (irrespective of the consumersâ location(s)).
EUDR: Applies to operators and traders placing covered commodities and products on, or exporting them from, the EU market. There is no turnover or tonnage de minimis; instead, SMEs get somewhat simplified obligations, but they are still in scope. The obligations cascade across the supply chain (importers, manufacturers, traders), creating a wider net than UKFRCâs current design.
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Scope: compliance
UKFRC: Affected businesses must implement a documented due diligence system and publish an annual report. That system must a) gather information on origin and supply chains; b) assess the risk that local landârelated laws were not complied with; c) take mitigation steps to address identified risks; and d) report annually on the system and its findings.
EUDR: The EUDRâs due diligence model is significantly more dataâheavy: Operators must collect geolocation coordinates at the plot level for all production areas supplying the regulated products. They must conduct risk assessment and mitigation that explicitly considers both deforestation risk and legal compliance. This makes the EUDR both more intrusive and more technologically intensive than UKFRC, and it pushes supply chains toward granular, plotâlevel traceability.
UKFRC: Affected businesses must implement a documented due diligence system and publish an annual report. That system must a) gather information on origin and supply chains; b) assess the risk that local landârelated laws were not complied with; c) take mitigation steps to address identified risks; and d) report annually on the system and its findings.
EUDR: The EUDRâs due diligence model is significantly more dataâheavy: Operators must collect geolocation coordinates at the plot level for all production areas supplying the regulated products. They must conduct risk assessment and mitigation that explicitly considers both deforestation risk and legal compliance. This makes the EUDR both more intrusive and more technologically intensive than UKFRC, and it pushes supply chains toward granular, plotâlevel traceability.
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Scope: enforcement
UKFRC: Because implementing regulations are not in force, enforcement is still a designed but not fully detailed architecture. Legal analyses anticipate: Civil sanctions, including an unlimited monetary civil penalty for serious breaches, plus tools like stop notices and enforcement undertakings, and possible publication of nonâcompliance; Targeted criminal sanctions for certain failures (e.g., failure without reasonable excuse to keep/supply required information); and Investigatory powers for the enforcement authority (expected to be the Secretary of State/DEFRA and designated agencies), including entry to premises, inspection of records, and potential seizure of products. But until secondary legislation is laid, these remain intentions, not fully specified rules.
Under the EUDR, Member States must provide for penalties that are: Effective, proportionate, and dissuasive, including: Fines up to 4% of EU turnover; confiscation and/or destruction of nonâcompliant goods; exclusion from public procurement; potential marketâaccess restrictions or bans.
UKFRC: Because implementing regulations are not in force, enforcement is still a designed but not fully detailed architecture. Legal analyses anticipate: Civil sanctions, including an unlimited monetary civil penalty for serious breaches, plus tools like stop notices and enforcement undertakings, and possible publication of nonâcompliance; Targeted criminal sanctions for certain failures (e.g., failure without reasonable excuse to keep/supply required information); and Investigatory powers for the enforcement authority (expected to be the Secretary of State/DEFRA and designated agencies), including entry to premises, inspection of records, and potential seizure of products. But until secondary legislation is laid, these remain intentions, not fully specified rules.
Under the EUDR, Member States must provide for penalties that are: Effective, proportionate, and dissuasive, including: Fines up to 4% of EU turnover; confiscation and/or destruction of nonâcompliant goods; exclusion from public procurement; potential marketâaccess restrictions or bans.
The UK Forest Risk Commodities Regulations
An overview
One source.
EUDR Update: Legislatorâs Remorse? | #PodSaveChocolate Ep 137
Episode 137 explores some implications of a recent vote by the EU Parliament to amend the EUDR, as well as calls to delay (again) it coming into force. [Updated to include links to other episodes dedicated to EUDR coverage.]
Clay Gordon
The EUDR, CSDDD, CSRD, and ESRS | #PodSaveChocolate Ep82
Episode 82 of #PodSaveChocolate features an exploration of four related EU regulations that affect the cocoa and chocolate industries â how they relate and who needs to worry about compliance will be addressed.
Clay Gordon
The EUDR and You â w/ Antonie Fountain | #PodSaveChocolate
Episode 9 of #PodSaveChocolate features Antonie Fountain of the VOICE Network. Starting time: 10 am PST / 1 pm EST / 6 pm GMT on December 19th, 2023.
Clay Gordon
- What is the overlap with the recently announced TogetherCocoa foundation?
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Apart from having one co-member (The Hershey Company), the focus of the UKCC is broader than TogetherCocoa.
Adapted from above: [the UKCC plans to lobby UK regulators to] use the UKFRC as a lever to support farmer livelihoods, address humanârights violations, in the process of tackling illegal deforestation.
Adapted from above: [the UKCC plans to lobby UK regulators to] use the UKFRC as a lever to support farmer livelihoods, address humanârights violations, in the process of tackling illegal deforestation.
Mars, MondelÄz, NestlĂŠ, Hershey, and Lindt team up to transform future of cocoa
The worldâs leading confectionery companies - Mars, MondelÄz, NestlĂŠ, Hershey, and Lindt & SprĂźngli - have launched TogetherCocoa, a new foundation aimed at supporting cocoaâgrowing communities in CĂ´te dâIvoire and Ghana, and strengthening sustainability across the global cocoa supply chain.
Donna Eastlake
- Who benefits financially? Who foots the costs of compliance?
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Financially? Not farmers. In the EUDR, the real winners are the companies supplying the technologies used for satellite surveillance and hardware and software necessary to perform compliance reviews. UKCC members will use their efforts to secure additional financial support (NGOs) and market greenwashing to customers.
Farmers will not benefit unless specific targets that provide living wages are implemented in the regulations. (Which may not be legally enforceable in countries like Ghana.)
Who will foot the bill? Ultimately, consumers, taxpayers, and farmers.
Farmers will not benefit unless specific targets that provide living wages are implemented in the regulations. (Which may not be legally enforceable in countries like Ghana.)
Who will foot the bill? Ultimately, consumers, taxpayers, and farmers.
- Can the UKFRC, like the EUDR, be considered a form of economic imperialism?
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YES! Itâs a group of actors â megacorporations, governments, and NGOs â that are not domiciled in producing countries trying to impose regulations on actors in producing countries without including them in the decision-making processes.
- Is it too little, too late?
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Probably.
- Is it the (or even a) right thing to do?
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Probably not, based on the history of all such previous attempts, including, most recently, the EUDR. Beware unintended consequences that will arise from the combative process of writing regulations that end in unworkable compromises because the people writing the regulations seem blissfully unaware of what they donât know they donât know.
Related Reporting
Updated: March News & AMA | #PSC 186
OVERVIEW: Episode 186 of #PodSaveChocolate features chocolate and cocoa news fit to eat, as well as the monthly live AMA (Ask Me Anything about chocolate or cocoa) for March 2026.
Clay Gordon
The formation announcement of the TogetherCocoa Foundation is covered in this episode.
Future Episodes
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Friday, April 10th
A conversation with Shawn Askinosie on the 20th anniversary of our first bean sourcing trip (to Mexico and Venezuela).
A conversation with Shawn Askinosie on the 20th anniversary of our first bean sourcing trip (to Mexico and Venezuela).
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#chocolate #chocolat #craftchocolate
#PodSaveChoc #PSC
#LaVidaCocoa #TheChocolateLife
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