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Ecuador’s Cocoa at the EUDR Crossroads: The Real Challenge Is Not Only Deforestation, but Proof

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  • Mosaix

Ecuador’s cocoa sector has the geography, market reputation and increasingly sophisticated supply chains to remain a major supplier to Europe. But a spatial assessment by MosaiX shows that the transition toward EUDR-ready cocoa will depend on something more fundamental: knowing exactly where cocoa comes from, what happened on that land before 2021, and whether the evidence can withstand scrutiny.

Ecuador is one of the world’s important cocoa origins, with production landscapes stretching across the humid lowlands of the Pacific coast and into parts of the country’s interior. A recent geospatial assessment identified roughly 3 million hectares of potential cocoa-planted area, equivalent to about 11.9% of Ecuador’s territory, with major concentrations in Manabí, Esmeraldas, Los Ríos, Morona Santiago, Santo Domingo de los Tsáchilas and Guayas.

That scale tells only part of the story.

As the European Union Deforestation Regulation reshapes expectations around cocoa sourcing, the central question is shifting from where cocoa is grown to whether every shipment can be connected to land whose history, legality and boundaries can be demonstrated.

The assessment suggests Ecuador has considerable potential to make that transition. But it also reveals several gaps that could become far more important than production volume itself.

A land-documentation gap hiding beneath the cocoa map

One of the most striking findings concerns land status.

According to the spatial comparison used in the assessment, around 2.8 million hectares, or approximately 92% of the mapped potential cocoa area, fall outside the registered land layer used in the analysis, while roughly 244,000 hectares, or 8%, appear as registered.

That figure needs to be interpreted carefully.

The report itself notes that the cocoa dataset represents potential planting areas as well as areas identified as cocoa, meaning it can overestimate actual planted hectares. It also warns that cadastral information can be incomplete in rural areas. The 92% figure should therefore not be read as proof that 92% of Ecuadorian cocoa farms are legally invalid or without legitimate tenure. It is better understood as a measure of the documentation and spatial-data gap that would need to be resolved during due diligence.

That distinction matters.

For EUDR implementation, a farm does not become compliant simply because its coordinates are known. Buyers need sufficiently reliable evidence connecting a commodity to its production plot, alongside evidence supporting deforestation-free status and compliance with applicable laws.

In other words, mapping is the beginning of due diligence, not the end of it.

The deforestation signal is relatively small—but it cannot be ignored

When the mapped cocoa plots were overlaid with post-2020 forest-loss information, the analysis identified 185 plots out of 212,572 assessed plots, covering approximately 65.4 hectares, that intersected areas recorded as deforested during 2021–2022.

Viewed against hundreds of thousands of plots, this is not evidence that Ecuadorian cocoa as a whole is driving widespread recent deforestation.

But from a regulatory perspective, percentages can be misleading.

EUDR due diligence operates much closer to the level of individual production plots and consignments. A relatively small number of problematic farms can therefore become significant when cocoa from those farms enters an otherwise compliant supply chain.

The implication is important: national-level deforestation statistics alone cannot determine whether a cocoa shipment is compliant.

The question eventually becomes much more specific:

Was this cocoa produced on this plot, and was that plot forest-free after the EUDR cutoff?

A rapidly changing forest-risk context

The broader forest landscape also deserves attention.

Using the European Commission Joint Research Centre’s Tropical Moist Forest dataset, the assessment found national forest loss increasing from approximately 4,913 hectares in 2021 to 12,232 hectares in 2022, falling slightly to around 11,013 hectares in 2023, then rising sharply to approximately 45,367 hectares in 2024.

The spatial pattern is equally important. Forest loss is not distributed uniformly across Ecuador. The report identifies Esmeraldas as the province with the highest cumulative deforestation among the provinces examined, suggesting that due diligence cannot rely on one uniform monitoring strategy across the country.

A cocoa plot in a stable agricultural landscape and another close to an active forest-conversion frontier may both need geolocation and documentation, but they do not necessarily require the same level of monitoring.

That points toward a more practical approach to EUDR implementation: risk-based verification rather than treating every cocoa farm identically.

Protected forests reveal a second kind of risk

Deforestation is only one part of the picture.

The assessment also compared cocoa plots against Ecuador’s mapped Permanent Forest Reserves. Around 2.19 million hectares are represented in the reserve dataset used by the study, and the overlay identified 184 cocoa plots covering approximately 527 hectares that intersect these reserve areas.

This finding illustrates an often-overlooked aspect of commodity compliance.

A plantation may show no recent forest clearance and still raise a due-diligence concern if it occupies land where agricultural production conflicts with applicable land-use restrictions.

For companies building EUDR systems, satellite deforestation monitoring is therefore not enough. Plot screening increasingly needs to combine several layers: land cover, forest-loss history, cadastral information, protected areas and other relevant legal boundaries.

The challenge becomes less about producing a single map and more about assembling an evidence stack around every production location.

What plot-level evidence looks like in practice

A case study from Agrícola del Litoral in Los Ríos Province offers a useful illustration.

Three parcels covering approximately 243.6 hectares were evaluated using cadastral information, protected-area data and satellite imagery. Planet imagery from September 2019 and May 2025 indicated that the parcels were already in agricultural use before the EUDR cutoff and remained agricultural afterwards. The nearest mapped forest reserve was approximately 27 kilometres away, with no overlap identified in the available dataset.

The significance of the example is not the individual farm.

It is the method.

Instead of asking a supplier simply to declare that its cocoa is deforestation-free, the process builds a reproducible file containing parcel boundaries, historical imagery, land-status information and protected-area screening.

That is much closer to what credible commodity due diligence increasingly requires: evidence that another analyst, buyer or auditor can reproduce.

From cocoa mapping to an evidence system

This is where many traceability programs encounter their real bottleneck.

Companies may already possess farmer lists, GPS points, certification records or sourcing contracts. But those datasets are often stored separately. Plot identifiers change between systems. Polygons may contain errors. Legal documents are held offline. Satellite assessments may not be linked back to specific suppliers or shipments.

The report proposes a workflow starting with a stable plot registry, followed by geolocation quality assurance, deforestation and reserve screening, legality documentation, risk classification, evidence archiving and continuous monitoring.

This represents an important shift in thinking.

Traceability should not simply answer “Who is the farmer?”

It should eventually answer:

Which plot produced the cocoa, what is the land history of that plot, what legal evidence supports production there, what risks were detected, what mitigation was undertaken, and which shipment contains the resulting cocoa?

Digital systems can make that process scalable. The report describes the use of integrated geolocation, automated forest-loss screening, protected-area and cadastral overlays, supply-chain connections and standardized reporting as components of an EUDR-oriented due-diligence architecture.

Technology, however, cannot fix unreliable source data by itself. The report explicitly notes that field mapping, farmer engagement and clear rules over data ownership and editing remain essential foundations.

The opportunity for Ecuador

Perhaps the most important conclusion from the assessment is that Ecuador’s cocoa challenge should not be framed simply as a deforestation problem.

The analysis does identify post-2020 forest-loss overlaps and cocoa plots intersecting protected forest areas. Those cases deserve investigation.

But the larger structural challenge is turning fragmented spatial, cadastral and supply-chain information into verifiable plot-level evidence.

That is also where the opportunity lies.

Ecuador already has national agricultural datasets, environmental information, a strong export-oriented cocoa sector and increasingly sophisticated private traceability initiatives. The next step is connecting these pieces.

For exporters and buyers, this means improving polygon quality, validating supplier locations, screening historical land-use change and building stronger links between farm data and physical cocoa flows.

For government agencies, it means improving interoperability among agricultural, cadastral and environmental datasets.

And for smallholders, it means ensuring that the transition toward stricter documentation does not simply exclude producers whose land tenure is legitimate but poorly represented in formal digital systems.

The report’s broader conclusion captures the moment well: Ecuador combines strong cocoa-market opportunities with remaining gaps around land tenure information and isolated instances of cocoa associated with recently cleared or protected land.

The future of EUDR-ready cocoa may therefore depend less on producing another sustainability declaration and more on something much more concrete:

building a chain of evidence—from the cocoa tree, to the plot, to the supplier, to the shipment.

And in an increasingly regulated commodity market, that evidence may become as valuable as the cocoa itself.

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