Big Chocolate’s cocoa supply chains are shedding carbon emissions at a pace that surprises even industry veterans, and a major new analysis credits one regulatory hammer for the shift. The European Union’s deforestation law has not even taken full effect yet. Still, its shadow is already reshaping how the world’s largest chocolate makers source their core ingredient.
Data examined by Global Witness shows emissions tied to cocoa procurement among six dominant producers fell 24.5 percent over three years. That happened while global cocoa output grew roughly eight percent during the 2024 to 2025 season. The average share of cocoa self-reported as “deforestation-free” climbed nearly 17 percentage points across the same period.
The EU Deforestation Regulation, commonly called the EUDR, passed in 2023. Large companies face enforcement deadlines before the year ends. Meanwhile, Nestlé and Hershey both posted major traceability gains in 2025. Nestlé reported a 49 percentage point jump in cocoa it could classify as deforestation-free.
Mondelez stands apart from its peers. The maker of Milka, Toblerone, and Cadbury logged 21.5 million tonnes of CO2 from cocoa sourcing since the law passed. That figure alone exceeds Croatia’s annual emissions. The company also refuses to publicly report traceability progress. As a result, analysts suspect Mondelez carries the highest carbon intensity per kilogram of cocoa among major chocolatiers.
Cocoa-driven forest loss has ravaged West Africa’s Upper Guinean rainforest, which spans Ghana, Côte d’Ivoire, and beyond. Forest clearing for cocoa contributes up to 21 percent of global emissions when land use change across sectors is tallied. European chocolate consumption accounts for roughly 40 percent of the bloc’s entire deforestation footprint.
Not everyone accepts the industry’s self-reported numbers at face value. Global Witness could not independently verify company claims. However, the trend aligns with what some executives have admitted privately. One cocoa sector leader noted that businesses achieved more progress in two years than in the previous twenty, attributing the acceleration directly to the impending regulation.
Mondelez has lobbied heavily against the EUDR since 2025. It even sought support from Washington to weaken the law. Competitors such as Nestlé, Ferrero, and Hershey have publicly backed the regulation. With enforcement just months away, the chocolate industry faces a clear choice: complete the transition to deforestation-free sourcing or risk fines and reputational damage. The coming year will reveal whether corporate pledges translate into measurable protection for West Africa’s dwindling forests.
