While the ECA is supportive of increased transparency in the cocoa supply chain, it said that it also believes the legislation should allow for an adequate transition period, leaving sufficient time for companies expected to bear the custodianship of the supply chain to adapt and develop their investment and processes to the requirements of the Regulation.
“This is to ensure the effective and efficient implementation that has positive impact in producing countries and across the supply chain,” it said.
According to the ECA, any obligations flowing from the EU’s Regulation must reach up and down the entire supply chain – from cocoa bean to end product – and all those directly and indirectly involved,
“Thus, all actors who place products on the EU market or export from it, as well as those who make them available for consumption or use inside the EU market, should be included,” the ECA said.
Any new legislation goes hand in hand with existing efforts by ECA member companies to halt deforestation, including through the Cocoa and Forest Initiative (CFI).
“The purpose of this valuable initiative – which is signed by 35 leading cocoa and chocolate companies, the Governments of Ghana, Côte d’Ivoire, and Columbia – is to halt deforestation, restore forests and train farmers in sustainable cocoa farming practices,” it said.
The ECA told the EU: “Given the complexity of the enforcement procedures, the Regulation should envisage adequate support for national government agencies in providing necessary guidance, resources, and expertise to evaluate the design, adequacy, and implementation of company due diligence systems. A high level of preparedness and expertise will help ensure that there is minimal disruption of import flows on the EU market and that both the operators and traders, as defined by this Regulation, can continue their operations swiftly.”
A partnership approach is also essential to the success of any Regulation, the ECA said, and where strict obligations for European companies are introduced, there must be, in accompaniment ambitious and robust cooperation between the European Union and cocoa producing (origin) countries.