"UK Cocoa Coalition: Position statement on Environment Act", 24 March 2026

We call on the government to bring the Forest Risk Commodities Regulation into force as soon as possible, and for cocoa to be confirmed as one of the commodities it applies to.

The government should also minimise the differences between the UK Regulation and the EUDR, in order to avoid unnecessary barriers to trade and costs to businesses.

This includes:

• Recognising EUDR Due Diligence Statements as credible evidence of due diligence for the purposes of the UK Regulation without requiring further documentation or action.

• Ensuring transparency is required within UK supply chains after the point of import, to enable companies to exercise due diligence and have the information necessary to export products to the EU.

We also call on the government to withdraw the guidance suggested under the previous government that due diligence should be carried out to an ‘as low as reasonably practicable’ (ALARP) standard. We believe that this would undermine the purpose of the legislation by introducing an element of subjective judgement, allowing companies to balance profitability against the exercise of due diligence...

The Regulation should also be accompanied by additional support through UK development cooperation to tackle the underlying problems and ensure that smallholder farmers do not suffer unduly from its implementation. It should be accompanied by comprehensive guidance

and support for companies, and firm deadlines for implementation. Finally, we call on government to engage with all stakeholders in the cocoa and chocolate supply chains, including businesses, producer-country governments and cocoa farmers, in implementing and reviewing the requirements of the UK Regulation