You Transform Imported Cocoa into Chocolate in Belgium. You Place Derived Products on the EU Market. The EUDR Obligation Is Yours. Here's How to Generate the Dossier in 15 Minutes.
Belgium processes more cocoa than any other European country. Major chocolate manufacturers and hundreds of artisanal chocolatiers in Antwerp, Brussels and Ghent transform imported cocoa into products placed on the EU market. Under Regulation (EU) 2023/1115, when you place a derived product (chocolate, cocoa butter, cocoa powder) on the EU market, you bear the due diligence obligation as operator. The FAVV/AFSCA is the competent authority. EUDRCheck generates the complete Annex II dossier — including the JSON file for TRACES NT — in 15 minutes. €299 per lot.
€299 · One-time · 28-page professional dossier + TRACES NT files · Your data never leaves your browser
The numbers that define Belgium's chocolate manufacturing exposure to the EUDR
Belgium is Europe's largest cocoa processing hub and one of the world's largest chocolate producers. Barry Callebaut, Puratos, Belcolade and hundreds of artisanal chocolatiers operate across the country. As EU-based operators placing derived cocoa products on the market, Belgian chocolate manufacturers bear the full due diligence obligation.
The EUDR applies directly to you as EU-based operator. When you place chocolate on the market, you must file a DDS in TRACES NT for each lot of cocoa used. The DDS must trace the cocoa back to the production plot.
#1
Belgium's position as Europe's largest cocoa processing hub
≥ 4%
Minimum fine — percentage of EU annual turnover (Art. 25.2.a)
€299
per lot for the complete 8-document dossier
What TRACES NT requires from you before placing chocolate on the EU market
Under Article 4 and Annex II, the data fields are defined by law. Your cocoa suppliers provide the raw production data. You structure it into the DDS and file it in TRACES NT.
Commodity and product description
HS codes 1801-1806 (cocoa), 1806 (chocolate). Theobroma cacao. Product type, lot number, cocoa content. Annex II point 2.
Country of production with subdivision
Ivory Coast — Haut-Sassandra, Nawa. Ghana — Western, Ashanti. Cameroon — Centre, South. Per cocoa origin. Annex II point 3.
Plot-level geolocation of every production area
Minimum 6 decimal places, WGS-84, GeoJSON RFC 7946. Points for plots under 4 ha, polygons for 4 ha or more. Article 2(28) + Annex II point 4. EUDRCheck includes a built-in coordinate generator to help your supplier produce compliant files.
Full supply chain traceability
Full chain: cocoa farmers, cooperatives, exporters, Belgian manufacturer, EU distributor. Annex II point 5.
Legal compliance in the country of production
Land use rights, environmental protection, forest legislation, third-party rights, labour rights, human rights, FPIC, tax and anti-corruption. Each country has different source legislation. Article 2(40) + Article 3(b).
Risk assessment against 14 criteria
Systematic evaluation of risk factors including country risk classification, complexity of supply chain, and prevalence of deforestation. Article 10.2 (letters a to n).
EUDRCheck generates the complete dossier — including a JSON file formatted for direct import into TRACES NT — in 15 minutes.
The three mistakes Belgian chocolate manufacturers make most often with EUDR documentation
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Pattern 1 — Assuming only importers need a DDS
As an EU-based manufacturer placing derived products on the market, you are an operator
Under Article 2(15) of Regulation (EU) 2023/1115, the operator includes any entity that places relevant products on the EU market. When you manufacture chocolate from imported cocoa and place it on the EU market, you bear the DDS obligation for the cocoa content. Your cocoa supplier's DDS covers the raw beans. Your DDS covers the derived product.
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Pattern 2 — Treating Rainforest Alliance or UTZ as the DDS
No voluntary certification replaces Article 4 and Annex II
Article 10.2(m) of Regulation (EU) 2023/1115 classifies voluntary certifications as complementary evidence for the risk assessment. They are not a substitute for the Due Diligence Statement. A DDS must be filed in TRACES NT for every lot regardless of certification status.
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Pattern 3 — Cocoa trader coordinates instead of plot-level GPS
Article 2(28) requires geolocation of the production plot, not the aggregation point
Cocoa passes through multiple aggregation stages before reaching your Belgian factory. Only the coordinates of the production plot satisfy the regulation. EUDRCheck's built-in coordinate generator and GeoJSON validator ensure the data meets the 6-decimal, WGS-84, RFC 7946 standard.
What you receive: an 8-document EUDR dossier generated in your browser
EUDRCheck does not generate a single PDF. It generates a complete dossier of eight structured documents, delivered as a ZIP file you download and keep. Every document cites the specific EUDR article it complies with.
1
Scope Determination
Identifies your role as EU-based operator, applicable regime, legal calendar. Article 2 + Article 8.
2
Pre-filled DDS + TRACES NT JSON
Signable PDF + machine-readable JSON for direct import into TRACES NT. Every Annex II field completed. Article 4 + Annex II.
3
Validated GeoJSON
Production plot coordinates validated against RFC 7946 + WGS-84. Points for plots under 4 ha, polygons for 4 ha or more. Visual map in PDF. Article 2(28) + Annex II.4.
4
Formal Risk Assessment
Systematic analysis of 14 criteria of Article 10.2 (letters a to n). Formal conclusion on risk level. Article 10.
5
Risk Mitigation Plan
Mitigation measures when risk is standard or high. Article 11.
6
Supply Chain Mapping
Full chain: cocoa farmers, cooperatives, exporters, Belgian manufacturer, EU distributor with full traceability. Annex II.5.
7
Country-of-Production Legal Checklist
Eight dimensions of legal compliance in the origin country. Adapted per country. Article 2(40) + 3(b).
8
Post-DDS Calendar + ICS Reminders
Annual review dates, 5-year retention period, automatic calendar reminders. Article 12 + Article 32.
See before you buy — Download sample dossier (PDF, fictional company) — Real structure, real articles, real format. Fictional data.
Generated from your own input, in your own browser. No supplier data leaves your device.
What you pay to get a valid EUDR dossier per lot
🧾 REGULATORY CONSULTANCY IN ZURICH OR GENEVA
€3,000–€8,000
Typical fee per origin. Lead time: 2-4 weeks.
✓ EUDRCHECK
€299
One-time per lot. 28-page professional dossier. 15 minutes. Browser-side.
The EUDR dossier and the plantation data: two separate layers
● LAYER 1 — THE DOSSIER (EUDRCHECK DOES THIS)
The structured Due Diligence Statement
Eight documents. 15 minutes. €299. Yours permanently. Including the JSON formatted for TRACES NT import.
∅ LAYER 2 — PLANTATION DATA (YOUR SUPPLIER PROVIDES THIS)
Plot-level GPS from the origin country
Your cocoa suppliers provide the GPS coordinates of production plots. EUDRCheck includes a built-in coordinate generator that converts their GPS data, Google Maps pins, or KML files into validated GeoJSON. If they have mapping data from Rainforest Alliance, Cocoa Life, Cocoa Horizons or similar programmes, EUDRCheck imports it.
We do not sell field data collection services. We structure the data your supplier provides into the format the regulation requires.
Enforcement reality: what happens when you place chocolate without a valid DDS
Under Article 25, consequences apply to the operator placing non-compliant products on the EU market. Under Article 25, consequences apply directly to you as the operator placing the derived product on the EU market. In Belgium, the FAVV/AFSCA (Federal Agency for the Safety of the Food Chain) is the competent authority.
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Fines — minimum 4% of EU annual turnover
≥ 4%
Article 25.2(a). For a Belgian manufacturer with €10M EU turnover, the minimum fine starts at €400,000. The maximum may exceed the economic benefit gained from the infringement.
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Confiscation of the commodity and its revenues
100%
Article 25.2(b) and (c). The chocolate products and all revenues may be seized by Belgian authorities.
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Exclusion from EU public procurement
12 months max
Article 25.2(d). Temporary exclusion from tendering procedures, grants and concessions.
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Temporary ban on placing chocolate on the EU market
Until compliance
Article 25.2(e). In serious or repeated cases, prohibition on placing relevant products on the EU market until full compliance is demonstrated.
Under Article 25.5, every final infringement decision is published by the Commission.
Alternatives Belgian chocolate manufacturers usually consider
| Alternative | Cost | What you get |
|---|
| Regulatory consultancy (Brussels, Antwerp) | €3,000–€8,000 | Same Annex II, 2-4 weeks per origin |
| Enterprise compliance platform | €12,000–€30,000/year | Yearly subscription, multi-origin |
| Rainforest Alliance / Fairtrade / Organic | Certification fees | Complementary evidence only (Art. 10.2.m) |
| EUDRCheck | €299 | 28-page dossier + TRACES NT JSON, 15 min, browser-side |
Processing cocoa from multiple West African origins? Volume pricing available.
Belgian chocolate manufacturers handling cocoa from Ivory Coast, Ghana and other origins need volume DDS capacity. EUDRCheck offers pack pricing from 10 dossiers. One dossier per cocoa lot. Email hello@solidwaretools.com with your estimated annual volume.
Request Volume PricingOne-business-day response · No sales call
What EUDRCheck guarantees and what it doesn't
EUDRCheck generates a document structured under Article 4 and Annex II of Regulation (EU) 2023/1115 (as amended by Regulation (EU) 2025/2650) based on the information you enter. The truthfulness, accuracy and completeness of that information is your responsibility as operator under Article 4.2.
We guarantee that the document structure follows Article 4 and Annex II of Regulation (EU) 2023/1115 and that the legal references cited are correct as of the latest verification date. We do not guarantee that a specific document will be accepted by any competent authority in a specific case.
EUDRCheck is not legal advice. For specific situations, consult a lawyer or specialised regulatory consultancy.
Frequently asked questions — Belgian chocolate manufacturers
I source cocoa from multiple origins. Do I need a separate DDS for each?
Yes. Article 4 of Regulation (EU) 2023/1115 requires a separate Due Diligence Statement for each consignment. Each cocoa origin requires its own DDS filing in TRACES NT. EUDRCheck generates each dossier independently for €299 per lot. Volume pricing is available from 10 dossiers.
My supplier has Rainforest Alliance or Fairtrade certification. Does that replace the DDS?
No. Article 10.2(m) of Regulation (EU) 2023/1115 explicitly classifies voluntary certifications — including Rainforest Alliance, Fairtrade, UTZ and organic — as complementary evidence for the risk assessment, not as a substitute for the Due Diligence Statement. The full DDS under Article 4 and Annex II is always required regardless of certifications held by the supplier.
As a Belgian manufacturer, do I need to file a DDS for derived products?
Yes. Under Article 2(15) of Regulation (EU) 2023/1115, the operator is the natural or legal person who places the product on the EU market for the first time. As an EU-based manufacturer placing chocolate on the market, you are an operator. You must file a DDS for the cocoa content of your products. Your cocoa supplier provides the origin data. You structure and file it.
My cocoa supplier cannot provide GPS coordinates of production plots. What do I do?
Article 2(28) and Annex II point 4 require plot-level geolocation in WGS-84 with minimum 6 decimal places. Without this data, you cannot file a valid DDS. EUDRCheck includes a built-in coordinate generator that helps your supplier produce compliant GeoJSON from GPS data, Google Maps pins, or KML files. Points for plots under 4 hectares, polygons for 4 hectares or more.
Does EUDRCheck handle my data securely?
All processing happens 100% in your browser. No supplier data, no GPS coordinates, no trade volumes, no company details are transmitted to any server. The dossier is generated on your device and the ZIP file you download stays on your computer. This is GDPR-native by design, not by declaration.
Is EUDRCheck legal advice?
No. EUDRCheck is a documentation structuring tool that organises your data into the format required by Article 4 and Annex II of Regulation (EU) 2023/1115. It is not a law firm, not a consultancy, and not a third-party audit. For specific legal situations, consult a lawyer or specialised regulatory consultancy.
Is there a subscription?
No. EUDRCheck is a one-time payment of €299 per dossier. No monthly fees, no auto-renewals, no commitment. You generate the dossier, download the ZIP, and the documents are yours permanently.
What if the regulation changes after I generate my dossier?
EUDRCheck is maintained and updated whenever the regulation or its implementing acts are amended. Our regulatory monitoring team verifies the tool weekly against EUR-Lex. The dossier you generated remains valid as of its generation date. If a material change occurs, we publish an advisory and update the tool.
⚠️ Important notice: EUDRCheck is a self-assessment documentation tool, not legal advice and not a third-party audit. The document under Article 4 and Annex II of Regulation (EU) 2023/1115 is generated from your input data. You are responsible for the accuracy of the data you provide. EUDRCheck does not replace a qualified professional assessment and does not provide the EU Responsible Person service.
The obligation is yours. The dossier takes 15 minutes. Generate it now.
Eight documents. Annex II fully structured. Regulation (EU) 2023/1115 in its current wording including Regulation (EU) 2025/2650 amendment of 23 December 2025. TRACES NT JSON included. Your data stays on your device. The ZIP you download is yours forever.
€299 one-time
28-page professional dossier · 15 minutes · No subscription · Browser-side
Generate the DDS — €299