[The EUDR Is Transforming Chocolate Production While Slashing Cocoa Emissions]
New analysis reveals the true climate impact of Big Chocolate for the first time – and how the EUDR is already driving down deforestation-linked emissions
Key points
- Analysis of public reporting from world’s largest chocolate companies shows emissions related to cocoa sourcing falling by a quarter in the last three years, even as global cocoa production increased globally
- Percentage of cocoa sourced by chocolate giants self-reported as “deforestation-free” has risen by nearly 17 percentage points on average across companies in same period, with Nestlé and Hershey reporting major improvements in 2025
- Anti-EUDR lobbyist and Toblerone-maker Mondelez reports highest cocoa-sourcing related emissions, equivalent to annual output of Croatia since passing of law
- Mondelez is also the only manufacturer in our analysis not to publicly report on traceability progress – and likely has the highest “carbon intensity” cocoa sourcing of any chocolate company
The EU’s new deforestation law appears to be driving major change in the global chocolate industry before it has even entered into force, a new Global Witness analysis suggests.
We found that emissions related to cocoa sourcing – mainly driven by deforestation – have collectively dropped by 24.5%, even as global cocoa production increased by an estimated 8% in 2025.
The European Union Deforestation Regulation (EUDR) was agreed at European level in 2023, initially giving companies 18 months to comply. Chocolate companies have been working to ensure compliance with the law. Legal obligations for large companies are expected to come into force at the end of this year.
The analysis shows the connection between a higher percentage of deforestation-free sourcing and reduced emissions. The average percentage of companies’ sourcing that was self-reported as “deforestation-free” increased by 17 percentage points among major producers.
The data indicates that emissions from cocoa sourcing have declined alongside rising deforestation-free ratios. By late 2025, the sector’s carbon footprint showed measurable improvement, driven largely by stronger supplier disclosures and tighter enforcement under EUDR.
The EU’s deforestation law hasn’t even entered into force, and it is already transforming the global chocolate industry
They have made more progress in the past two years than in the past 20 due to the upcoming law
The EU’s zero-deforestation regulations have forced a rapid shift in supply-chain practices within the chocolate sector, prompting companies to adopt stricter traceability measures and source more responsibly. A deep dive into the sustainability reports of leading firms – Nestlé, Mondelēz, Hershey, Mars, Lindt and Ferrero – reveals that cocoa‑related emissions fell by roughly one quarter over the last three years, while domestic production grew by eight percent. Of particular concern remains Mondelez, whose cocoa portfolio accounts for the largest share of emissions thanks to limited disclosure of deforestation‑free volumes. Despite mounting corporate improvements, notable gaps persist, underscoring that systemic change requires robust compliance mechanisms and continued regulatory vigilance.
"The EU’s deforestation regulation hasn’t even taken effect, and it’s already reshaping the global chocolate industry: emissions are dropping, traceability is advancing, and output continues to rise.
Beyond numbers, expert opinion reinforces the urgency. Marie Toussaint MEP, an influential European Green MEP, has praised the law’s impact, noting that “cocoa‑related emissions are falling, traceability is improving, and production keeps growing.”
Co‑founder of the VOICE Network Antonie Fountain added, “Companies are adapting quickly when rules are clear. There is no excuse for delay or dilution – implement EUDR now, lock in these gains for the long term, and extend them to all commodities.”
Mondelez leads the charge against the regulation through targeted lobbying campaigns, positioning itself against what it sees as an unnecessary burden on traders and producers.
