Current as of 9 October 2026
Growing at the date this was checked. A record marked this way is describing something that has not yet reached whatever it is going to reach. Checked twice a year. First observed: Both adopted in 2024; neither applies yet.
The EU forced labour ban and due diligence directive, and cocoa
Two European Union laws besides the deforestation regulation will reach cocoa. One bans products made with forced labour from 14 December 2027. The other puts a human-rights and environmental due diligence duty on the very largest companies, with national laws due by 26 July 2028 and applying from 26 July 2029. Neither names cocoa, and neither has been applied to anything yet.
The deforestation regulation is about land. Two further instruments are about people and about company conduct, and they are written for every product, not for cocoa. Regulation (EU) 2024/3015 prohibits placing on the Union market, making available there, or exporting any product made with forced labour, and it applies from 14 December 2027. Directive (EU) 2024/1760 obliges large companies to identify and address adverse human-rights and environmental impacts in their own operations, their subsidiaries and their business partners' chains of activities, with liability for failing to. It has been amended twice before applying. A 2025 directive moved its dates, and Directive (EU) 2026/470 of 24 February 2026 moved them again and narrowed its reach: member states now have until 26 July 2028 to write it into national law, the measures apply from 26 July 2029 for every company in scope, and the threshold rose from 1,000 employees and 450 million euros of turnover to more than 5,000 employees and 1.5 billion euros.
What would make this page wrong
Written before the page went up rather than added afterwards. If one of these has happened since the date above, treat what follows as history.
- A third amendment of the due diligence directive. It has been changed in 2025 and in 2026 before applying to anyone, and this record states what the consolidated text of 18 March 2026 says. A Commission proposal on public procurement, dated 9 September 2026, would amend it again; what that would change was not read for this record.
- An amendment of the forced labour regulation. None was on the Publications Office's record when this was checked.
- The Commission's database of forced labour risks by area and product group, which the regulation requires. Whether it names cocoa, and for which areas, will decide how much attention the sector gets from enforcement.
- The first investigations after 14 December 2027, which will show what evidence is treated as enough to open one.
- National laws writing the directive in, which can differ in how liability works.
What stays true when this is over
Whatever happens to the dates, the three instruments divide the subject in a way worth keeping. The deforestation regulation asks where the cocoa grew. The forced labour regulation asks how the product was made, and attaches to the product, whoever sells it. The due diligence directive asks what a company did about the risks it could foresee, and attaches to the company, above a size threshold. A bar can satisfy one and fail another. Forced labour in the regulation is defined by reference to International Labour Organization Convention No 29 and includes forced child labour, which is a narrower category than child labour as the cocoa surveys measure it.
What the forced labour regulation does
IT ATTACHES TO THE PRODUCT. The prohibition is on placing or making available on the Union market, or exporting, a product made with forced labour. It names no sector and no country.
IT COMES WITH A RISK DATABASE. The Commission is to establish a database of forced labour risks in specific geographic areas or for specific products or product groups, which the text describes as indicative, non-exhaustive, evidence-based, verifiable and regularly updated.
IT APPLIES FROM 14 DECEMBER 2027.
What the due diligence directive does
IT ATTACHES TO THE COMPANY. It sets obligations regarding actual and potential adverse impacts on human rights and the environment, in a company's own operations, those of its subsidiaries, and those of its business partners in its chains of activities.
IT IS A DIRECTIVE, so it binds through national law. Member states must adopt that law by 26 July 2028 under the 2026 amendment, and apply it from 26 July 2029.
IT COVERS ONLY THE LARGEST. A company established in the Union is in scope with more than 5,000 employees on average and a net worldwide turnover above 1.5 billion euros. The 2024 text had set 1,000 employees and 450 million euros, with a staged start; the staging has gone.
What a reader should take from this
Three European laws now bear on a bar of chocolate, with three different questions and three different calendars: land from the end of 2026, forced labour from the end of 2027, company conduct from mid-2029. None of them is a label, and none will appear on a wrapper.
None of them is a livelihoods instrument either. The texts and what each one says are on the page about tariffs and supply-chain law in the data section, quoted from the official journal.
Widely said, not established
These are claims in circulation about this subject that the evidence available to this catalogue does not carry. They are listed rather than ignored, because a reader who has met them elsewhere is entitled to know where they stand.
- That either law applies to cocoa today. Neither applies to anything yet.
- That the forced labour regulation is a ban on cocoa touched by child labour. Its definition covers forced child labour. Child labour in cocoa and forced labour in cocoa are different findings, measured differently, and are set out separately on the sustainability pages.
- That most chocolate companies fall under the directive. Since the 2026 amendment it covers companies with more than 5,000 employees and 1.5 billion euros of turnover. A small or medium maker is outside it, though a large customer may pass requirements down a contract.
- That either law will raise what a farmer is paid. Neither sets a price or an income.
Related
The data and the studies
- Cocoa tariffs and supply-chain lawDuties by stage of processing, and the EU's forced labour and due diligence laws.
- Cocoa sustainability: promise and outcomeWhat was promised set against what was measured, with the quality of the evidence.
What is happening now
- The EU deforestation rules and cocoaThe first of the three instruments and the only one written with cocoa in its list of commodities. It asks about land; these two ask about labour and conduct.
- Forced labour and child labour are not the same thingWhat is and is not known about forced labour on cocoa farms, which is the evidence any investigation under the regulation would have to start from.
- The child labour commitmentsWhy child labour and forced labour are measured separately, and what two decades of commitments on the first have and have not achieved.
- Traceability, and where it stopsWhere knowing a product's history stops being possible in a chain built for blending, which limits what any of the three laws can establish.
Sources
- Regulation (EU) 2024/3015 on prohibiting products made with forced labour on the Union market — European Parliament and Council of the European Union, 2024
- Directive (EU) 2024/1760 on corporate sustainability due diligence — European Parliament and Council of the European Union, 2024
- Directive (EU) 2026/470 amending Directives 2006/43/EC, 2013/34/EU, (EU) 2022/2464 and (EU) 2024/1760 as regards certain corporate sustainability reporting and due diligence requirements — European Parliament and Council of the European Union, 2026
How this page is kept current
Dates on this site are advanced by a person who has re-read the record, never by a build step. If the date at the top of this page is old, that is the honest state of it rather than a bug — and the list of what would make it wrong is there so you can check for yourself. See the editorial policy.