Signed by all its member companies and organisations, the position paper provides the Coalition’s views and says: “We believe that the proposed Regulation, complemented by other EU legislation and by measures to develop an enabling environment in the countries of origin, has the potential to contribute to the transformation of the cocoa and chocolate sector towards a sector that fully respects human rights and environmental sustainability.
“In terms of the content of the proposed Regulation, we endorse the suggested areas for improvement included in the response to the European Commission’s consultation on the proposal developed by the International Cocoa Initiative (one of the members of the Cocoa Coalition), covering definitions, enforcement and guidance, remediation, purchasing practices and state-imposed forced labour.
“We particularly endorse the paper’s proposal for the EU to implement complementary measures to support the development of an enabling environment in the countries of origin, helping to address the root causes of forced labour – in line with the proposals on partnerships we published in 2021.
“In common with our comments on the EU Regulation on Deforestation and the proposed EU Directive on Corporate Sustainability Due Diligence, we also stress the importance of ensuring that the costs of compliance with the Regulation are shared fairly across the supply chain, and do not fall only on cocoa farmers. Similarly, it will be important to ensure that the Regulation promotes engagement with cocoa farmers in a genuine effort to eradicate forced labour, rather than incentivising disengagement by companies importing cocoa into the EU.
“We look forward to contributing to the development, by the European Commission, of appropriate guidelines to support companies’ implementation of the Regulation.”
In a response to European Commission Call for Evidence in June 2022, the ICI said it is crucial to redouble efforts to tackle forced labour and it supports the European Commission’s commitment to address this issue and to promote decent work worldwide.
“At the same time, forced labour in smallholder agricultural supply chains is a complex issue, and cases can be hard to identify. Legislation that is not well designed or too broad may result in severe unintended consequences for precisely the people it seeks to protect. To ensure the protection of adults and children at risk or in forced labour, we therefore recommend a number of areas to be carefully considered in the design of such a legislation.”
The ICI also works closely with governments in both cocoa-producing countries (mainly Ghana and Côte d’Ivoire) and cocoa-consuming countries. A report this week in CN highlighted the situation in Cote d’Ivoire where cocoa farming is still a major contributor to deforestation in the country and farmer poverty is also a continued concern, despite efforts to increase cocoa farmers’ income.