Which Cocoa Products and HS Codes Fall Under the EUDR

Updated 2026-11-02 · 4 min read · By the akar.earth specialist team

EUDR HS codes for cocoa: beans, shells, paste, butter, powder and chocolate (HS 1801 to 1806), and how Indonesian grinders trace local and imported beans.

Under the EUDR, cocoa products in Annex I span HS headings 1801 to 1806: cocoa beans, cocoa shells and waste, cocoa paste or liquor, cocoa butter, cocoa powder, and chocolate and other food preparations containing cocoa. For Indonesia, where much cocoa leaves the country as butter and powder from domestic grinders, this means traceability must survive grinding and pressing, and must cover any imported beans as well as Sulawesi beans.

The cocoa headings in Annex I

The product list was updated by Delegated Regulation (EU) 2026/2102. Check the current Annex I for any changes to subheadings or exclusions before relying on this table.

Why grinding makes traceability harder

Indonesia developed a grinding industry that converts beans into liquor, butter and powder. Grinding is a continuous process. Beans from many lots are cleaned, roasted, winnowed and ground together, then liquor is pressed into butter and cake, and cake is milled into powder.

Mass balance is not accepted under the EUDR. A grinder producing EU-bound butter must be able to show which bean lots went into it, and which gardens supplied those lots. Practical options:

• Fully verified intake. All beans entering the plant are EUDR-verified. Simplest to prove, hardest to achieve.
• Dedicated runs. Verified beans processed in separate campaigns, with line clearance between runs.
• Dedicated lines. A separate line for EU-bound production.

Each option needs batch records linking outputs (butter, powder, liquor) to input bean lots. See segregation.

Imported beans

Indonesian grinders use both local and imported beans. Under the EUDR, the country of production is where the beans were grown. For an EU-bound batch of butter made partly from imported beans:

• The plot geolocation for imported beans must come from the origin country.
• The risk assessment must consider that origin’s country benchmark.
• Imported and local beans need traceable lots, even if ground together in a verified run.

Grinders without plot data for imported beans should keep them out of EU-bound runs.

By-products

Cocoa shells and husks (1802) are often sold as by-products, for example for feed, mulch or extraction. If they are exported to the EU, they are covered too. Keep their link to the bean lots they came from.

Chocolate and confectionery

Indonesian chocolate makers exporting to the EU fall under heading 1806. They need traceability for the cocoa inputs: beans, liquor, butter or powder. If they buy butter or powder from an Indonesian grinder, they rely on the grinder’s batch records. If they buy from an EU-covered supply chain, they rely on the upstream due diligence statement reference.

For mixed food products, check the code. A biscuit containing chocolate may be classified under a different heading, and whether it is covered depends on Annex I.

Steps for Indonesian processors

1. List all products exported to the EU and their codes.
2. Check each code against the current Annex I.
3. For covered products, map bean sources: local districts and import origins.
4. Choose a segregation model for the plant.
5. Keep batch records linking every output to input lots and gardens.
6. Agree the data format with the EU importer. See due diligence statement.

Upstream work still matters most

All of this depends on the bean lots being traceable to gardens in the first place. That work happens with farmers and collectors. See cocoa due diligence and cocoa and the EUDR.

Indonesian chocolate makers and bean-to-bar producers

Indonesia has a growing bean-to-bar and craft chocolate sector, often using beans from specific regions or farmer groups in Sulawesi, Java, Bali or Sumatra. These producers usually know their farmers, which puts them ahead of bulk grinders on traceability. For EU exports, they still need garden geolocation for each bean source, a deforestation check, and batch records linking bars to bean lots. Sugar, milk and other ingredients are not covered unless they include another relevant commodity, such as palm oil in fillings.

Next steps

See the EUDR hub for the full topic map. For help linking grinder batches to garden-level data, see our EUDR compliance services or message us on WhatsApp.