We, the undersigned group of companies and co-signatories to this joint position paper, take note with concern of the delayed proposal for EU measures to minimize the risk of placing products linked to deforestation on the EU market, as well as the delayed proposal for an EU framework on mandatory human rights and environmental due diligence, as part of the European Commission’s broader initiative on sustainable corporate governance.

We remain strongly convinced that an EU-wide legal framework based on international standards would be beneficial for companies in the cocoa supply chain, including our own, mainly by clarifying a common framework through which all companies will be expected to proactively manage their potential and actual adverse impacts on human rights and the environment. Holding all companies to the same standard will help to create a level playing field, eliminate free riders and close loopholes, provided that expert regulatory authorities are equipped with adequate powers and tools to ensure that all covered companies in fact establish and adequately maintain these systems.

A harmonised and predictable EU-wide legal framework is essential to ensure legal certainty for companies and enable them to focus on implementing actions on the ground together with supply chain partners to tackle systemic human rights and environmental challenges, rather than engaging in several compliance exercises in different member states.

We therefore call on the European Commission to prioritize the adoption without further delay of EU measures to minimize the risk of placing products linked to deforestation on the EU market, as well as a proposal for an EU framework on mandatory due diligence. This will help to avoid a further fragmentation of the legal landscape in Europe and proceed in shaping the policy framework needed to secure the long-term sustainability of the cocoa supply chain.