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What requirements should cocoa meet to be allowed on the European market?

Takes about 23 minutes to read

To enter the European cocoa market, you must comply with legal requirements on e.g. food safety, food contaminant levels and consumer labelling. Furthermore, European cocoa buyers increasingly have additional requirements, especially in the field of food safety certification, Corporate Social Responsibility (CSR) and sustainability. Meeting these additional requirements can increase your chances on the market considerably.


1 . Buyer requirements

Buyer requirements can be divided into:

  1. Musts: legal and non-legal requirements you must meet to enter the market.
  2. Additional requirements: those you need to comply with to keep up with the market.
  3. Niche requirements: applying to specific niche markets.

2 . What legal and non-legal requirements must my product comply with?

Here you can find the most important legal and non-legal requirements you must meet when you want to market cocoa products in Europe. These include general requirements for food products (especially food safety) as well as specific legislation for cocoa and chocolate products.

Food safety

Food safety and hygiene are key issues on the European market. If you want to export to Europe, your cocoa products must comply with the European law on food safety and food hygiene that ensure the quality of food products throughout the whole supply chain.

An important aspect to control food safety hazards is defining critical control points (HACCP) by implementing food management principles. Subjecting food products to official controls is another important aspect. Products that are not considered safe will be denied access to Europe.

Tips:

  • Make sure your products comply with the General Food Law (Regulation EC 178/2002) and the general rules on Food Hygiene (Regulation EC 852/2004).
  • Check the Guidance document of the European Commission for information on certain key questions related to import requirements and the European rules on food hygiene and official food controls.
  • Refer to the EU’s Rapid Alert System for Food and Feed (RASFF) database to see examples of withdrawals of cocoa products from the market and the reasons behind these withdrawals. Under ‘Product’, choose the category ‘cocoa and cocoa preparations, coffee and tea’. In addition, you can choose your country under ‘Country’ to see examples of non-compliances. This can be a basis for your own risk management system and to avoid future border rejections.

Food contaminants

Food contamination can occur at different stages of the production process due to environmental contamination, cultivation practices or processing methods. Since many contaminants are naturally occurring, it would be impossible to impose a total ban on them. European Union legislation ensures that contaminants are kept at levels that are as low as possible so that they do not threaten human health. The levels are set on the basis of scientific advice provided by the European Food Safety Authority (EFSA).

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The main contaminants likely to be found in cocoa and derived products are:

A) Heavy metals, in particular cadmium:
The European Union has strengthened its regulation on cadmium in cocoa and derived products. The new regulation became effective as of January 2019. Cadmium is found naturally in the soil, but pesticides and chemical fertilizers containing cadmium are also sources of contamination. The presence of cadmium is a particular problem for cocoa from some Latin American countries due to factors like volcanic activity and forest fires. The maximum permitted levels of cadmium are listed in Table 1. Please note that these levels relate to finished chocolate products, but controls of cocoa beans should also take place.

Table 1 Maximum permitted levels of cadmium in cocoa and derived products

Specific cocoa and chocolate products as listed below

Maximum permitted cadmium levels (ppm)

Milk chocolate with <30% total dry cocoa solids

0.10 as from 1 January 2019

Chocolate with <50% total dry cocoa solids;

milk chocolate with ≥ 30% total dry cocoa solids

0.30 as from 1 January 2019

Chocolate with > 50% total dry cocoa solids

0.80 as from 1 January 2019

Cacao powder sold to the final consumer or as an ingredient in sweetened cocoa powder sold to the final consumer

0.60 as from 1 January 2019

When translating the cadmium levels in chocolate into levels admitted in cocoa beans in practice, European importers consider <0.5 ppm a good level. Up to 0.8 ppm will still be accepted, but acceptance above 0.8 ppm will depend on the content of cocoa in the finished chocolate. If the level rises above 1 ppm, chocolate makers will either reject the product altogether, or will have to blend the cocoa with other cocoa with a lower cadmium content.

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B) Pesticides:
The European Union has set maximum residue levels (MRLs) on the amount of pesticides allowed in food products, including cocoa. The use of pesticides is permitted but should be strictly controlled. This is especially relevant for cocoa farmers using pesticides to fight insect infestation such as mired bugs and the cocoa pod borer.

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C) Mycotoxins:
Mycotoxins such as aflatoxins and ochratoxin A can occur in cocoa as a result of fungal infection of crops. They are a major cause of economic loss in the cocoa sector. The recognition of the health hazards of mycotoxins has led to regulatory limits being set around the world, particularly in the European Union.

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D) Polycyclic-aromatic hydrocarbons (PAHs):
Polycyclic-aromatic hydrocarbons (PAHs) may also contaminate cocoa during post-harvest or primary processing stages. Smoke is one of the main sources of polycyclic-aromatic hydrocarbons in cocoa beans during drying or storage. The limit for benzo(a)pyrene (which is one of the most common polycyclic-aromatic hydrocarbons) is 5.0 μg/kg of fat and 30 μg/kg for the total sum of polycyclic-aromatic hydrocarbons.

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E) Microbiological/Salmonella:
Although cocoa is considered a low-risk commodity, it may occasionally be subject to microbiological contamination as a result of incorrect harvesting and drying techniques. No microbiological criteria for cocoa have been set in the current European legislation. However, food safety authorities can withdraw imported food products from the market or prevent them from entering the European Union when micro-organisms are found.

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F) Foreign matter:
Contamination by foreign matter like plastic and insects are a threat when food safety procedures are not carefully followed. For example, mineral oil residues (MOSH and MOAH) have been recently found in chocolate in Germany. These residues can be derived from materials like recycled paper and treated gunny bags. There is, however, no legislation on this so far in the European Union.

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Extraction solvents

The European Union also sets maximum residue limits on extraction solvents used in the production of foodstuffs and food ingredients. There is for example a limit on the use of Hexane (1 mg/kg), which is used for the production of cocoa butter.

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Consumer labelling

European Union food labelling rules ensure that consumers receive essential information to make an informed choice when purchasing their food. Uniform labelling facilitates consumer choice. All food labels for pre-packaged products (not applicable to labelling of bulk products like cocoa beans) must therefore display the following information:

  • The name under which the product is sold
  • The list of ingredients (including additives)
  • The net quantity of pre-packaged foodstuffs
  • The “best before” date with the day, month and year in that order
  • Any special storage or usage conditions
  • The name or business name and address of the manufacturer or packager, or of a seller established in the European Union
  • Place of origin or provenance, where failure to give such particulars might mislead the consumer
  • Lot marking on pre-packaged foodstuffs with the marking preceded by the letter ‘L’.

These indications must appear on the package or on a label attached to pre-packaged cocoa products sold to consumers (example: chocolate). The label must be visible, legible, indelible and easy to understand, and must be in a language that is easily understood by consumers. This usually means the official language or languages of the European country where the product is marketed. The use of foreign terms or expressions that are easily understood by the purchaser may be allowed.

In the case of cocoa beans, which is not a pre-packaged product, labelling is not guided by specific legislation, but should at least include:

  • product name
  • grade
  • lot or batch code
  • country of origin
  • net weight in kg

In the case your cocoa is organic or fairtrade certified, the labels should contain the name/code of the inspection body and certification number.

Tips:

  • Refer to the legislation regarding the labelling and packaging for more information on general labelling rules for foodstuffs.
  • Also check the specific rules for cocoa and chocolate products (Directive 2000/36/EC) which complement the legislation applicable to foodstuffs.

The Trade Helpdesk by the European commission gives a complete overview of (legal) requirements on the European cocoa market. Here, you can select your country and the European country you want to export to. The Product Code for cocoa products is 18.

Packaging requirements

Cocoa beans are traditionally shipped in jute bags, which can weigh between 60 and 65 kg.

On the mainstream market bulk shipment of cocoa beans has become more popular. This means cocoa beans are loaded directly into the ship’s cargo hold or in shipping containers containing a flexi-bag). This mega bulk method is often adopted by larger cocoa processors, which handle cocoa beans of standard qualities.

In the fine flavour/speciality cocoa segment, jute bags are still commonly used. For very high-quality micro lots vacuum-sealed GrainPro packaging can be used.

Tip:

Quality criteria

If you want to access the European market for cocoa beans, you will have to meet international quality standards. They are particularly high within the speciality segment for fine-flavour cocoa beans.

Cocoa of Excellence mentions the following factors defining the quality of cocoa:

  • Good trees (genetics)
  • Well cared for and grown in a suitable environment
  • Pods correctly harvested
  • Good practices to keep the trees healthy and free of pests and diseases
  • Optimum fermentation and drying protocols specific to the type of beans
  • Know-how for processing cocoa beans and for chocolate making

High-grade (fine flavour) cocoa beans are generally of higher quality than common grade cocoa beans, as their distinctive flavour is popular among manufacturers of high-quality chocolate. Fine flavour beans are usually produced from trees that contain the genetics of Criollo and/or Trinitario cocoa-tree varieties. Common grade (bulk) cocoa beans for mass production are genetically derived from Forastero trees.

Harvesting and processing techniques are also important in harnessing the ‘fine’ qualities of fine-flavour cocoa beans. During harvesting you should make sure you only take the ripe fruits. During processing you should make sure all cocoa beans are fermented and dried homogenously. Cocoa beans should be shipped shortly after harvest because extended storage (> 6 months) may result in losses due to the relatively high humidity in tropical environments.

To moderate the initially bitter cocoa flavour and to develop the typical cocoa flavour, the beans are fermented. Cocoa grading differs across producing and consuming countries. Standard practices have been set by the international cocoa trade associations. The grading of cocoa depends on the fermentation process:

  • Well fermented cocoa beans: less than 5% mould, less than 5% slate and less than 1.5% foreign matter.
  • Fairly fermented cocoa beans: less than 10% mould, less than 10% slate and less than 1.5% foreign matter.

There are currently no standardised procedures, nor is there a specific terminology for assessing cocoa bean quality and flavour and its direct relation to high-quality chocolate for buyers and consumers to understand, as is the case in the Q Coffee System. This has impeded clear communication among suppliers, buyers and consumers. In addition, this has created difficulties for suppliers in understanding how buyers assess and define quality and the diversity of flavour, which affects their ability to tackle issues in their supply chain that could contribute to quality improvement.

To address this issue, an informal working group was set up in September 2015 during the World Cocoa Foundation (WCF) Annual Seminar on Cocoa in the Americas. This working group (established and coordinated by the Cocoa of Excellence Programme) aims to explore the development of international standards for assessing cocoa quality.

The members of the working group represent the range of stakeholders: from cocoa producers’ associations to traders, chocolate manufacturers and research organisations. The first consultations took place in September 2017 in Managua (Nicaragua) and in October 2017 in Paris (France), and looked at best practices worldwide. The working group’s last meeting took place at the Salon du Chocolat 2018 (Paris, France) to review in detail the 20 protocols that will be published in April 2019 and made available for implementation. Future discussions involving relevant stakeholders will continue during industry events in order to improve and finalise the first-draft standards by the end of 2019.

Buyers currently assess the quality and flavour of cocoa beans in different ways and often use a combination of two or more methodologies. The protocols of the Association of Chocolate, Biscuits & Confectionery of Europe (Caobisco), the European Cocoa Association (ECA) and the Federation of Cocoa Commerce (FCC), which were published in 2016, focus on factors affecting the quality of cocoa beans from post-harvest through to the factory gate. The guide Cocoa Beans: Chocolate & Cocoa Industry Quality Requirements provides recommendations on cocoa growing, post-harvest practices and quality evaluation methods that contribute to cocoa quality. Another common cocoa quality assessment methodology among chocolate makers is the Fine Cacao and Chocolate Institute (FCCI) sampling protocol and cocoa grading. The Heirloom Cacao Preservation Initiative of the Fine Chocolate Industry Association (FCIA) combines an in-depth genetic evaluation with a tasting panel that performs further qualitative and quantitative evaluation of the cocoa beans (in the form of chocolate and liquor).

The Cocoa of Excellence Programme also applies its own methodology to assess the quality of cocoa in different stages: 1) physical quality and sensory evaluation of fermented and dried cocoa beans; 2) flavour and sensory evaluation of cocoa liquor; 3) flavour and sensory evaluation of chocolates. Finally, companies such as Equal Exchange/TCHO have developed a quality assessment and tasting guide to assess the quality of their products along the value chain.

All these initiatives have been included and built on in the new International Standards for the Assessment of Cocoa Quality and Flavour and are part of the working group’s efforts to ensure that standards are not created from scratch, but are built on current best practices and are reviewed by representatives of the cocoa value chain.

Tips:

3 . What additional requirements do buyers often have?

Some buyers have requirements that go beyond existing legislation, in particular regarding food safety, environmental impact and social responsibility. Western and North-European countries generally have stricter additional requirements than South and East-European countries.

Food safety certification

As food safety is a top priority in all EU food sectors, you can expect many players to request extra guarantees from you, such as the implementation of product-specific quality standards and Quality Management Systems (QMS) regarding the production and handling processes. A distinction may be made between certifications applying to processers and those for producer organisations and exporters.

Processors

Many European buyers, such as importers, food processors and retailers, require the implementation of an (Hazard Analysis Critical Control Point HACCP-based) food safety management system.

The most important food safety management systems in Europe are:

All these food safety management systems are recognised by the Global Food Safety Initiative (GFSI), which means that any of them should be accepted by major retailers.

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Producer organisations and exporters

It is very important for producers to follow good agricultural practices to ensure food safety. The main standards in this area are provided by GLOBALG.A.P. They are voluntary standards for the certification of agricultural production processes that provide safe and traceable products.

GLOBALG.A.P. has a special standard for fruit and vegetables, and products derived from them (including cocoa) which covers all stages of production from pre-harvest activities such as soil management and plant protection product application to post-harvest produce handling, packaging and storage.

Tip:

  • Ask your buyers or potential buyers exactly what type of certification they require from you. Certain certification schemes such as Rainforest Alliance/UTZ (see ‘Sustainability certification’ below) are aligned with GLOBALG.A.P. If you are certified with these schemes, there is no need for separate GLOBALG.A.P. certification.

Corporate Social Responsibility

European buyers are increasingly addressing social and environmental issues. Sometimes they become involved in local social and environmental projects. Sometimes they develop their own Corporate Social Responsibility (CSR) policies or codes of conduct. Suppliers are required to adhere to their codes of conduct, which generally includes health and safety, business ethics and social responsibility requirements.

European buyers may expect you to comply with their code(s) of conduct regarding Corporate Social Responsibility. This can be their own code of conduct or one based on external initiatives such as the Business Social Compliance Initiative (BSCI) and Sedex Members Ethical Trade Audit (SMETA). The adoption of these standards is most common among large-scale importers and retailers.

Other sustainability aspects which are getting more attention on the European market for cocoa are:

  • carbon neutrality
  • impact on producing communities
  • welfare of farmers & processing facility workers and
  • impact on local biodiversity.

Where these issues are not specifically addressed by legislation, they are covered in codes of conduct from importing companies and/or retailers, and are investigated further during audits. Some examples are:

Retailers

Importers, cocoa processors and chocolate companies

Tips:

  • Investigate the existing sustainability standards established by retailers and other stakeholders on the European market by approaching supermarket category managers (chocolate), cocoa importers and sector specialists. Check whether you can adhere to the guidelines laid down by these standards. They can be a good starting point if you want to supply cocoa beans to these companies.
  • Consider participating or visiting roundtable meetings (via conference call) or seminars to meet industry players and other interesting stakeholders. Check out the website of the World Cocoa Foundation to keep up-to-date on these discussions.
  • Consider developing and implementing your own CSR policy or code of conduct. This is not always required by buyers, but may be a good way to show potential buyers your views on social responsibility. This may furthermore help you to stand out when your buyer has to choose between several suppliers.
  • Ensure that your suppliers also have responsible businesses practices in place. Many social and environmental issues take place at farm level, which may not be a part of direct (handling and processing) activities.

Sustainability certification

Sustainability has social, environmental and economic aspects. Many European companies have formulated minimum sustainability requirements for their suppliers that address key issues such as child labour, healthy and safe working conditions, deforestation and pesticide use. However, European companies, especially those in Northern and Western European countries, increasingly also adhere to sustainability certification schemes. This trend is largely driven by the commitment of major confectioners such as Mars, Ferrero and Hershey’s.

There are several sustainability certification schemes that focus on different aspects of sustainability, and whose popularity may vary from one country or segment to another.

Rainforest Alliance is the most commonly used mainstream certification scheme for cocoa. In 2017, Rainforest Alliance and UTZ announced a merger into a single organisation and certification named Rainforest Alliance. This organisation will utilise the respective strengths of the current Sustainable Agriculture Network (SAN) and UTZ standards, while creating a single auditing process for certificate holders.

Tips:

  • Familiarise yourself with the requirements of sustainability certification. Most certification schemes have trainings, tools or other types of assistance to help you understand the criteria and educate you on how to become certified.
  • Consider applying for certification. Certification can provide participating producers with opportunities such as training, more efficient agricultural practices and becoming independent of outside synthetic chemicals for fertilisation. In addition, certification can lead to access to new markets for exporters and cooperatives.
  • When opting for certification, consider multiple certification schemes. For example, investigate the accessibility of certification programmes in your country or region, the credibility and recognition of the available certification programmes, the costs of certification and the type of certification preferred by buyers in your main European target markets. For more information about considerations on certification and differences between certification schemes check the ‘Study on the costs, advantages and disadvantages of cocoa certification’.
  • Look into the different operators worldwide which handle UTZ/Rainforest Alliance certification. This will provide you with insight into the countries where these certifications are most demanded, and the players which can be your potential buyers.

4 . What are the requirements for niche markets?

Organic certification

Organic-certified products are increasing rapidly in popularity in Europe. Organic cocoa is produced and processed through natural techniques such as crops rotation, biological crop protection, green manure and compost. On the one hand, implementing organic production and becoming certified can be expensive, especially for small holders, and the return on investment may not be high. On the other hand, it could increase yields and improve quality. Demand for fine-flavour cocoa with organic certification is rapidly growing in Europe, making this an interesting niche market.

If you comply with the organic production methods that are laid down in European legislation regarding products from organic production (which are voluntary) and an accredited certifier has approved your growing and processing facilities, you are allowed to place the European Organic Farming logo on your products, as well as the logo of the standard holder (for example, in the United Kingdom the Soil Association and Organic Farmers and Growers and in Germany the BCS Öko-Garantie). Demeter is a biodynamic certification label and regarded as the highest grade of organic farming in the world.

The popularity of organic certification for cocoa in specific countries follows the general market for organic products in Europe. The organic market in Europe underwent a sharp growth of 11% between 2015 and 2016.

The largest national markets for organic food products are Germany (28% of the European market), France (20%) and the United Kingdom (8%). In terms of per-capita consumption, the leading countries are Switzerland, Denmark, Sweden and Luxembourg. The complete figures for organic food products are available in the FiBL and IFOAM report The World of Organic Agriculture 2018.

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Fairtrade certification

Fairtrade certification is the proven way to substantiate your business’ social performance along the supply chain. Certification by an independent third party will enable you to place the Fairtrade logo on your product. In general, prices for fair trade products consist of a minimum price plus a premium.

The Fairtrade Labelling Organisations International (FLO) is the leading standard-setting and certification organisation for Fairtrade. Products which carry the Fairtrade label indicate that producers are paid a Fairtrade Minimum Price. The current minimum prices and premiums for cocoa, whether organic-certified or conventional, can be found in the Fairtrade Minimum Price and Fairtrade Premium Table.

Other fairtrade standards available in the European market are Fair Trade Ecocert and Fair for Life. The Símbolo de Pequeños Productores (SPP) also focuses on social impact, adopting community-based sustainability principles.

Fairtrade certification is most popular in North-Western Europe. For example, market figures for FLO certification indicate that the United Kingdom is by far Europe’s main buyer of FLO-certified cocoa beans from producers, followed by the Netherlands, Ireland and Switzerland.

Tips:

  • Check the ITC Standards Map for an overview of non-legal standards relevant to the European cocoa market regarding sustainability.
  • Before engaging in a Fairtrade or other sustainability certification programme, make sure to check (in consultation with your potential buyer) that this label has sufficient demand in your target market and whether it will be cost beneficial for your product.
  • Next to certification, transparency of the supply chain is an asset in the specialty segment. Communicate a traceable and clear, direct link between producer and consumer.

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