As sustainability regulations reshape global commodity supply chains, cocoa companies are under increasing pressure to strengthen traceability, transparency, and accountability. In a discussion with Robert Jan van Beekhoff, Operations & Supply Chain Advisor at ECOM Cocoa Theobroma, key insights emerged into the technical and operational changes required to build an end-to-end traceability system capable of linking geo-location data directly to finished cocoa products. 

Robert explained that Theobroma has developed a comprehensive traceability system that tracks cocoa products from import into the European Union through to final customer delivery. The system links incoming cocoa products and Bills of Lading (BLs) to their corresponding Due Diligence Statements (DDSs), enabling full supply chain traceability. 

Products are monitored throughout production using enterprise resource planning (ERP) systems integrated with factory automation systems based on programmable logic controllers (PLCs). Batch and trace numbers are assigned to all materials, allowing sourcing and geo-location data to remain connected to finished products throughout processing. As a result, we can identify which cocoa batches were used in specific final products, retrieve the relevant DDSs, and provide customers with traceability information as products leave the factory. The system has been implemented primarily at factories in Germany and the Netherlands. 

Factory automation systems play a critical role in supporting traceability and operational control. PLC-based systems monitor key production stages, including roasting, storage, pressing, butter and powder production, and intermediate storage. These systems track how materials move and blend throughout the factory, including residual material in tanks and processing lines, enabling accurate traceability calculations even for blended products. Connecting geo-location data to physical products through this integrated system represented a major technical achievement for the company. 

Robert also noted that cocoa stock imported before implementation of the EUDR is currently classified as “transition stock” and may continue to be processed. Looking ahead, we plan to phase out imports of non-compliant cocoa once EUDR requirements are fully enforced. 

Although implementation challenges remain, substantial progress has been achieved. Traceability processes are now significantly faster and more accurate, enabling compliance information to be generated almost immediately when products leave production facilities. Further system integration and fine-tuning are ongoing, with full operational readiness expected by the end of the year.