EUDR Compliance for Cocoa: Supporting Smallholder Farmers in Thailand
Updated: Oct 7
The impending European Union Deforestation Regulation (EUDR) has sparked debate, with contrasting perspectives on its potential repercussions. Opponents emphasize the financial burden and technological challenges smallholder farmers may face, while supporters advocate for its role in promoting sustainability and transparency in the supply chain.
Opponents claim the cost of geolocation and supply chain verification will hurt farmers. They argue the average smallholder farmer cannot afford the necessary technology to accomplish these goals and will lose EU market opportunities.
Supporters of EUDR advocate for sustainability and transparency in the supply chain. They maintain that regulation is essential to ensure that farms remain deforestation-free and that supply chains are traceable and verifiable. Moreover, they contend that EUDR presents an opportunity to uplift smallholder farmers and their communities, countering the indifference of certain industry segments.
At ECOSHIFT, we believe EUDR compliance presents a unique opportunity to empower smallholder farmers by building sustainable, verifiable supply chains. Our mission is to re-think sustainability for these farmers and leverage technology and industry expertise to enhance quality, increase productivity, and improve their livelihoods. Embracing compliance enables access to market opportunities while contributing to sustainable practices.
EUDR Compliance for Cocoa in 2026: From Farm Geolocation to Due Diligence
Since this article was first published in 2024, both the EUDR regulatory framework and ECOSHIFT’s work on the ground have evolved.
For cocoa supply chains, compliance increasingly means connecting farm-level information with traceability and due diligence requirements: identifying producers and plots, collecting geolocation data, structuring and verifying supply chain information, assessing deforestation risk, and ensuring that the required information can follow cocoa from origin to the EU market.
Working with smallholder cocoa supply chains in Thailand, ECOSHIFT has put these steps into practice — coordinating farm-level data collection, GPS and polygon mapping, data structuring and conversion to GeoJSON, deforestation-risk assessment, and traceability documentation to support EUDR due diligence.
This experience has reinforced a key lesson: EUDR compliance is not simply a technology or data-collection exercise. It requires reliable first-mile information, clear links between farmers, plots and products, and a practical system for turning fragmented field data into usable due diligence information.
Helping Smallholder Cacao Farmers in Thailand Grow Sustainable Livelihoods
Thailand’s smallholder cocoa farmers operate in fragmented supply chains where farm information, traceability records and market requirements are not always connected. Meeting EUDR requirements therefore involves more than collecting geolocation data: information needs to remain linked to farmers, plots, cocoa lots and downstream supply chain actors.
ECOSHIFT works with producers and supply chain partners to structure this first-mile information, strengthen traceability and connect farm-level data with the requirements of buyers and EU market access.
In practice, ECOSHIFT has coordinated the collection and structuring of first-mile data for smallholder cocoa supply chains in Thailand, including farmer and farm information, GPS coordinates and plot polygons. Field data has been prepared and converted into formats such as GeoJSON for integration into EUDR compliance workflows, including deforestation-risk assessment and due diligence documentation.
Technology platforms can support this process, but ECOSHIFT remains technology-agnostic: the priority is to ensure that reliable field data can move through the systems and tools required by each supply chain and buyer.
Empowering Smallholder Farmers for a Sustainable Future
The EUDR is scheduled to apply from 30 December 2026 for large and medium operators, with later application for micro and small operators. For cocoa-producing countries, the challenge is therefore no longer simply understanding the regulation, but ensuring that producers and supply chains can provide the information required for continued access to the EU market.
For smallholder farmers, this creates both a challenge and an opportunity. Compliance depends on supply-chain actors being able to connect farm geolocation and production information with traceability and due diligence systems — without transferring disproportionate costs or administrative burdens to farmers themselves.
“Operators shall not place relevant products on the market or export them without prior submission of a due diligence statement.”
European Union Deforestation Regulation, Article 4
Economic Prosperity Through EUDR Compliance
EUDR compliance does not automatically create higher prices for smallholder farmers. Its more immediate economic value is market access: cocoa that cannot meet the applicable due diligence requirements risks being excluded from EU supply chains.
For smallholder-producing regions, the opportunity is therefore to build compliance into supply-chain infrastructure in a way that supports — rather than burdens — producers.
The potential benefits include:
Market Access: Maintaining access to EU buyers by ensuring that cocoa can be traced back to compliant production plots and supported by the information required for due diligence.
Risk Mitigation: Giving buyers and supply-chain partners better visibility over origin, deforestation risk and traceability gaps before products reach the EU market.
Capacity Building: Developing practical systems for farm geolocation, traceability, risk assessment and data management that can continue to serve producers beyond a single transaction.
Stronger Supply-Chain Relationships: Creating clearer information flows between farmers, aggregators, exporters and buyers, reducing the disconnect between first-mile realities and downstream compliance requirements.
EUDR Implementation Requires More Than Technology
No single platform can make a fragmented agricultural supply chain EUDR-compliant on its own. Effective implementation requires coordination between producers, aggregators, exporters, buyers, technology providers and, where relevant, research and technical partners.
ECOSHIFT works across these layers, connecting field realities with the data and due diligence requirements of downstream supply-chain actors. Depending on the project, this can include farm and supplier onboarding, geolocation and polygon collection, traceability design, data structuring, risk assessment, technology integration and coordination with specialised partners.
This technology-agnostic approach allows the compliance workflow to be built around the supply chain — rather than forcing the supply chain to fit a particular platform.
From EUDR Requirements to Implementation
For cocoa and other agricultural supply chains, EUDR compliance ultimately depends on what happens between the farm and the due diligence system.
ECOSHIFT supports organisations across this process — from first-mile data collection, farm geolocation and supplier onboarding to traceability, data structuring, risk assessment and due diligence implementation.
Our approach is designed for fragmented supply chains and can be adapted to existing systems, technology providers and sourcing structures.
by Tim Morch, Freelance Writer
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