Bean-to-Bar Chocolate Maker EUDR: Your Due Diligence Statement in 15 Minutes

The numbers that matter for European bean-to-bar makers

The bean-to-bar movement prides itself on traceability. The EUDR adds a regulatory layer: under Article 4, you must file a structured DDS documenting exact farm geolocation, legal land use rights, and formal risk assessment for every lot.

For standard-risk origins (Ivory Coast, Ghana, Cameroon, Nigeria, Brazil), the full DDS is mandatory. For low-risk origins (Ecuador, Colombia, Peru, DR), the full DDS is still required for most operators.

Operator

You import cocoa beans = you place them on EU market = you file the DDS

60%+

World cocoa from Ivory Coast + Ghana — both standard risk

€199

per lot

What the EUDR requires from you

You source the beans. You make the chocolate. Under the EUDR, you also file the DDS.

Commodity

HS 1801 cocoa beans, 1803-1806 derivatives. Theobroma cacao. Annex II point 2.

Country of production

As declared by supplier. With region/department/district. Annex II point 3.

Geolocation of every cocoa farm

WGS-84, 6 decimals, GeoJSON. Under 4 ha = single point, ≥4 ha = full polygon. Annex II point 4.

Supply chain traceability

From cocoa farmer through cooperative, exporter to you. Annex II point 5.

Legal compliance

Land use, environmental law, forest protection, labour rights (child labour documentation critical for cocoa), FPIC, tax. Art. 2(40) + 3(b).

Risk assessment

14 criteria under Art. 10.2. Certifications (Fairtrade, RA, organic) = complementary under Art. 10.2(m).

EUDRCheck produces the entire package from your supplier's data.

Three most common mistakes

❌

Pattern 1 — Cooperative at origin files the DDS

You are the EU operator — you file

If you import cocoa beans directly, the DDS obligation is yours.

❌

Pattern 2 — Fairtrade / RA cocoa cert = DDS

Certification ≠ DDS

Art. 10.2(m): complementary evidence. Full Annex II DDS in TRACES NT mandatory.

❌

Pattern 3 — One DDS for all origins

Each consignment from each origin = own DDS

Ecuador lot and Ghana lot are separate documents.

What you receive: an 8-document EUDR dossier

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.

Scope Dictum

Identifies your role (operator / trader / downstream), applicable regime, legal timeline. Article 2 + Article 8.

Pre-filled DDS

Signable PDF + TRACES NT-importable JSON. Every Annex II field completed with your data. Article 4 + Annex II.

Validated GeoJSON

File compliant with RFC 7946 + WGS-84. Points for plots under 4 ha, polygons for plots over 4 ha. Visual PDF included. Article 2(28) + Annex II.4.

Formal Risk Assessment

Systematic analysis of the 14 criteria of Article 10.2 (letters a to n). Formal conclusion on risk level. Article 10.

Risk Mitigation Plan

Mitigation measures adopted or recommended when risk is standard or high. Article 11.

Supply Chain Mapping

Upstream and downstream map with full traceability data. Annex II.5.

Country-of-production Legal Checklist

Eight dimensions of Article 2(40). Article 2(40) + 3(b).

Post-DDS Calendar + Compliance Reminders

ICS calendar file with annual review, 5-year retention requirement, 72-hour amend/withdraw window. Article 12 + Article 32.

Generated from your own input, in your own browser. No data leaves your device.

What you pay

🧾 COMPLIANCE CONSULTANCY

€2,000–€5,000 per origin

1-3 weeks.

✓ EUDRCHECK

€199 per lot

28-page dossier. 15 min.

Dossier and origin data: two layers

● LAYER 1

DDS

8 docs. 15 min. €199.

∅ LAYER 2

Farm GPS from your cooperative partner

Many bean-to-bar makers already have direct farm relationships and GPS data. EUDRCheck imports directly or captures via map tool.

We do not sell field data collection.

Enforcement reality

Under Article 25 — the fine applies to you as the EU operator.

🇪🇺

Fines — minimum 4% of EU annual turnover

≥ 4%

Article 25.2(a) requires Member States to impose fines with a maximum of at least 4% of the operator's or trader's total annual EU-wide turnover in the financial year preceding the fine decision. The maximum may be raised to exceed the economic benefit gained.

🇪🇺

Confiscation of the commodity and its revenues

100%

Article 25.2(b) and (c) — the relevant product and the revenues from its transaction may be seized by national customs and competent authorities.

🇪🇺

Exclusion from EU public procurement

12 months max

Article 25.2(d) — temporary exclusion from tendering procedures, grants and concessions for a maximum of 12 months.

🇪🇺

Temporary market ban in serious or repeated cases

Indefinite

Article 25.2(e) — prohibition on placing relevant products on the EU market until full compliance is demonstrated. Applies to the European buyer, who will pass the consequence upstream to the non-compliant supplier.

Article 25.5.

Alternatives

Alternative	Cost	What you get
EU compliance consultancy	€2,000–€5,000 per origin	1-3 weeks
Enterprise (Barry Callebaut, Farmer Connect)	€8,000–€20,000/yr	Yearly
Fairtrade / RA / UTZ cert only	Certification fees	Complementary only
EUDRCheck	€199 per lot	28-page dossier

Sourcing from 5 origins, 30 lots per year? Volume pricing.

Email hello@solidwaretools.com.

Request Volume Pricing

One-business-day response

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 or supplier of the consignment.

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 a market surveillance authority in a specific case, nor by a commercial buyer in a procurement process.

EUDRCheck is not legal advice. For specific situations, consult a lawyer or specialised regulatory consultancy.

Frequently asked questions — European bean-to-bar makers

I'm a chocolate maker, not a trader. Does EUDR apply?

If you import cocoa beans directly and place them on the EU market, you are the operator. The DDS obligation is yours.

My Ecuadorian supplier has Fairtrade. Enough?

No. Certification is complementary under Art. 10.2(m). Full DDS in TRACES NT required.

Ivory Coast and Ghana are standard risk. Can I still source?

Yes. Standard risk means full DDS required and heightened scrutiny, not a ban.

One DDS per bar recipe or per origin lot?

One per consignment from each origin.

Privacy?

Browser-side.

Legal advice?

No.

⚠️ 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.

You Source Cacao Fino from Ecuador, Single-Origin Bars from Madagascar, Criollo from Venezuela. You Make Chocolate in Belgium, France or the Netherlands. Under the EUDR, You File the Due Diligence Statement. Here's How — in 15 Minutes per Lot.