Deforestation Risk Assessment for Cocoa Supply Chains
Deforestation risk in cocoa supply chains: how to assess Sulawesi and other Indonesian cocoa sources for EUDR, including replanting and imported beans.
Deforestation risk assessment for a cocoa supply chain means rating each sourcing area, each garden and each bean source for the chance that cocoa came from land cleared after 31 December 2020 or from illegal production, then verifying and mitigating before an EU lot ships. For Indonesian cocoa, the plot-level deforestation risk is often lower than people expect, because most gardens are decades old, while traceability risk is high because beans pass through collectors without records.
Where cocoa deforestation risk sits in Indonesia
The cocoa boom in Sulawesi in the 1980s and 1990s converted large areas of forest and other land into gardens. That history is before the cut-off date and does not affect EUDR compliance. Today’s risk is about new clearing.
| Situation | Risk level | Why |
|---|---|---|
| Established lowland gardens, planted before 2020 | Lower | Already agricultural use |
| Rehabilitated or replanted gardens | Lower, but often flagged | Satellite products may show loss |
| Upland gardens at forest edge, Central and South Sulawesi | Higher | Gardens can expand into forest |
| Gardens near protected areas | Higher | Deforestation and legality risk |
| New planting areas outside Sulawesi | Higher until screened | Less history to rely on |
| Imported beans | Depends on origin country | Different benchmark and data quality |
This is a qualitative guide for prioritising work. The Commission’s country benchmarking category for Indonesia, and for any import origins, sets the baseline due diligence level.
Risk factors to score
Forest proximity. Gardens within a short distance of forest, especially upslope, carry more risk of expansion.
Garden age. Cocoa planted after 2020 on land that was forest in 2020 fails. Cocoa planted after 2020 on old farmland or as replanting passes.
Protected areas and forest estate. Gardens inside national parks or protection forest raise legality issues even if old.
Unregistered supply. The share of beans bought from collectors who cannot name farmers.
Yield plausibility. Beans sold per garden compared with realistic yields for its area and condition.
Labour. Child labour and unsafe work are legality risks within the EUDR scope; assess them through farmer surveys and audits.
The replanting problem
Sulawesi cocoa needs rehabilitation, and many programmes promote cutting old trees and replanting or grafting. Satellite products can record this as tree cover loss after 2020. Without records, an EU operator may treat such gardens as non-compliant.
Defend rehabilitated gardens with:
- Programme records showing replanting dates and garden IDs.
- Time-series imagery showing the garden existed before 2020.
- Field photos and stem measurements.
See satellite verification and EUDR and agroforestry.
A scoring workflow
- Area screen. For each sourcing district, map forest cover, recent loss and protected areas.
- Garden screen. Check every registered garden against 2020 cover and post-2020 loss.
- Legality overlay. Forest estate, protected areas, known land disputes.
- Traceability check. Compare bean volumes with registered gardens and collector records.
- Field verification. Visit flagged gardens; record land use, crop age and context.
- Decision. Accept, exclude or mitigate each garden and each collector, and record the reason.
Imported beans in the risk picture
Indonesian grinders that blend local and imported beans need a separate risk assessment for each origin, using plot data from suppliers there. Where imported beans cannot be traced to plots, they should not enter EU-bound grinding runs. See cocoa derived products.
Mitigation for cocoa
- Exclude gardens with post-2020 forest clearing and gardens without legal basis.
- Shift buying to registered farmer groups and collectors.
- Monitor forest-edge villages with deforestation alerts.
- Support intensification and rehabilitation on existing gardens, reducing pressure to open new land.
- Run labour risk checks alongside deforestation checks.
Context and carbon
Cocoa expansion is one of several drivers of forest loss in Sulawesi, alongside other crops and mining. See drivers of deforestation in Indonesia. The garden and imagery data used for risk assessment can also support agroforestry carbon programmes in rehabilitated gardens.
Labour and community risks
The EUDR’s legality test includes labour rights and human rights. In cocoa, child labour has been a major concern in West Africa, and buyers apply similar scrutiny to Indonesia. Indonesian cocoa is mostly family farming, where children may help on family gardens. Due diligence should distinguish light family help outside school hours from work that harms health or schooling. Farmer surveys, school attendance data and group-level monitoring give a reasonable picture. Record the approach and any follow-up in the same file as the deforestation evidence.
Next steps
Risk assessment feeds into cocoa due diligence. See the EUDR hub for the full topic map, or message us on WhatsApp about screening your cocoa supply base through our EUDR compliance services.
Frequently asked questions
How risky is Indonesian cocoa for deforestation under the EUDR?
Most Sulawesi cocoa was planted long before 2020 and should pass the cut-off test. Risk concentrates at forest edges, in upland areas near protected forest, and in any new planting areas.
Is replanting old cocoa counted as deforestation?
No. Replanting cocoa on land already in agricultural use is not deforestation. Keep records, because satellite products may flag it as tree cover loss.
How do imported beans affect risk?
Indonesian grinders that use imported beans must assess risk in the beans' origin countries, using that country's benchmark category and plot data.
What is the biggest non-deforestation risk in cocoa?
Traceability. Beans bought through collectors without farmer records cannot be linked to plots, so they cannot be shown to be compliant.