New analysis reveals the true climate impact of Big Chocolate for the first time – and how the EUDR is already driving down deforestation-linked emissions
Key points
- Analysis of public reporting from world’s largest chocolate companies shows emissions related to cocoa sourcing falling by a quarter in the last three years, even as global cocoa production increased globally
- Percentage of cocoa sourced by chocolate giants self-reported as “deforestation-free” has risen by nearly 17 percentage points on average across companies in same period, with Nestlé and Hershey reporting major improvements in 2025
- Anti-EUDR lobbyist and Toblerone-maker Mondelez reports highest cocoa-sourcing related emissions, equivalent to annual output of Croatia since passing of law
- Mondelez is also the only manufacturer in our analysis not to publicly report on traceability progress – and likely has the highest “carbon intensity” cocoa sourcing of any chocolate company
The EU’s new deforestation law appears to be driving major change in the global chocolate industry before it has even entered into force, a new Global Witness analysis suggests.
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The European Union Deforestation Regulation (EUDR) was agreed at European level in 2023, initially giving companies 18 months to comply. Chocolate companies have been working to ensure compliance with the law. Legal obligations for large companies are expected to come into force at the end of this year.
We found that emissions related to cocoa sourcing – mainly driven by deforestation – have collectively dropped by 24.5%, even as global cocoa production increased by an estimated 8% in 2025.
The analysis shows the connection between a higher percentage of deforestation-free sourcing and reduced emissions. The average percentage of companies’ sourcing that was self-reported as “deforestation-free” increased by 17 percentage points among major producers.
Global Witness found that each company analysed – with the exception of Mars – listed the EUDR prominently on its website or named the regulation as a potential compliance risk to shareholders, suggesting that the law is informing internal strategy.
The EU’s deforestation law hasn’t even entered into force, and it is already transforming the global chocolate industry
Marie Toussaint MEP
We showed the evidence to Marie Toussaint, a Green Member of the European Parliament.
She responded: “The EU’s deforestation law hasn’t even entered into force, and it is already transforming the global chocolate industry: cocoa-related emissions are falling, traceability is improving, and production keeps growing.”
“This is proof that companies can adapt when the rules are clear. There is no excuse for delay or dilution: implement EUDR now, lock in these gains for the long term, and extend them to all commodities.”
The law will end years of reliance on business-led voluntary commitments to stop deforestation, requiring importers of cocoa to submit geolocation data to prove deforestation-free sourcing.
We were unable to independently verify the claims of the companies included in this analysis, which focused on the world’s largest chocolatiers – Nestlé, Ferrero, Mondelez, Mars, Lindt and Hershey.
However, this analysis suggests that the EUDR is driving laggards in the industry to finally address deforestation in their supply chains.
This is crucial as most of the world’s cocoa comes from Ghana and Côte d’Ivoire, where rampant deforestation for the commodity has led to the near disappearance of the Upper Guinean Rainforest, which stretches across both countries.
Heavy lobbying has delayed the law by two years, including by chocolate giant Mondelez, the manufacturer of Milka, Toblerone and Cadbury.
Civil society and chocolate giants such as Nestlé, Mars and Hershey have repeatedly called on the EU to implement the law with no more delays.
The links between chocolate, deforestation and climate change
Deforestation has many well documented negative consequences for planet and people – including driving biodiversity loss, droughts, ecosystem collapse and violations of Indigenous Peoples’ rights.
It also drives climate breakdown, which exacerbates phenomena such as the record heatwaves seen all over Europe this summer.
Deforestation causes emissions by releasing stored carbon from trees and soil back into the atmosphere, which occurs when farmers clear forests to plant cocoa. Forest loss is estimated to contribute between 13-21% of global emissions – more than sectors such as aviation and shipping.
EU consumers eat more chocolate than anywhere else in the world. This consumption drives more deforestation abroad than any other commodity sold in the bloc – around 40% of its entire “deforestation footprint.”
With no regulation to stop companies doing so, chocolatiers and their suppliers have sourced huge quantities of cocoa without knowing its origin. This has been a particular problem in West Africa’s Upper Guinean rainforest, which stretches from Ghana to Guinea, where untraceable cocoa has caused enormous deforestation.
Ivorian cocoa campaigner Bakary Traoré and his organisation Initiatives for Community Development and Forest Conservation (IDEF) have seen first-hand the effects that Mondelez’s purchasing strategy has had on his country’s forests.
“Major companies have driven small-scale farmers to maintain large cocoa plantations just to earn a living wage,” he tells us.
Cocoa has been a major driver of deforestation in Côte d’Ivoire
Cocoa’s carbon emissions drop as EUDR takes hold
We decided to analyse how much cocoa sourcing has contributed to the emissions of major chocolate companies. To do so, we carried out a deep analysis of sustainability reports produced by Nestlé, Mondelez, Hershey, Mars, Lindt and Ferrero.
We found that in the years since the EUDR was introduced (2023-2025), cocoa sourcing by the chocolate giants generated emissions of 63.5 million tonnes of CO2 – greater than the annual output of Austria.
Mondelez’s cocoa sourcing caused the most emissions of any company, exceeding the annual emissions of Croatia on its own with 21.5 million tonnes of CO2 emissions during the same period.
Deforestation is by far the most significant contributor of emissions related to cocoa sourcing. A recent study by the Accountability Framework Initiative showed that nearly 88% of cocoa’s emission footprint in Ghana comes from deforestation, which could be vastly reduced if companies only sourced EUDR-compliant cocoa.
They have made more progress in the past two years than in the past 20 due to the upcoming law
Co-founder of the VOICE Network Antonie Fountain
The environmental impact of Europe’s consumption is exactly what the EUDR was designed to address – and our analysis shows that according to company reporting, it appears to be “cleaning up” the chocolate sector.
The carbon emissions linked to cocoa sourcing that we calculated above may be high, but a closer look reveals that, in that same period, those emissions have already seen a year-on-year drop.
We discovered that the emissions from cocoa sourcing of the six companies analysed have collectively fallen by almost a quarter since the year the EUDR was passed, even as global cocoa production increased by almost 8% from 2024-2025.
The available data does not show what is driving companies’ reductions in emissions from cocoa sourcing, such as whether they result from reduced deforestation and land use change. But over this period, we see a noticeable trend where emissions from cocoa sourcing have fallen as the share of deforestation-free cocoa has increased.
Within the last three years, the average percentage of companies’ cocoa sourcing classed as deforestation-free rose by nearly 17 percentage points.
Behind this figure lies companies reporting remarkable improvements in traceability by individual businesses.
For example, in 2025 Nestlé reported a 49-percentage point improvement in the percentage of cocoa it purchased that could be classed as “deforestation-free.” If this figure is correct, it would act as an important corrective to anti-EUDR lobbyists that have said traceability is not feasible.
“I have heard several very senior private sector executives state that they have made more progress in the past two years than in the past 20 due to the upcoming law,” cocoa expert and co-founder of the VOICE Network Antonie Fountain told us last year.
We also calculated an estimation of the “carbon intensity” of each company’s cocoa sourcing – how many CO2 equivalent emissions are released per kilogramme of cocoa sourcing. This allows us to control for a large difference in volumes that companies purchase.
Different cocoa companies report emissions differently, making direct comparisons difficult. However, the data does suggest that Ferrero (the only company to declare its carbon intensity) reports 98% deforestation-free sourcing, with half the emissions intensity of Nestlé in 2024 – when the KitKat producer could not trace over 60% of its supply.
Mondelez’s estimated emissions intensity is particularly high. The company doesn’t declare how much of its supply is deforestation-free. These two factors – along with its anti-EUDR lobbying – suggest the company hasn’t yet tackled its deforestation problem.
Note on emissions & emissions intensity estimates
Mars, Hershey and Nestlé noted concerns in correspondence with Global Witness about comparing or ranking companies that operate in different regions and use different GHG methodologies to calculate emissions intensity. Ferrero welcomed the research, stating that it welcomed recognition of its work on traceability. Lindt did not respond to our invitation to comment, and Mondelez did not specifically address our emissions research in its response.
As Ferrero is the only company that publicly discloses the emissions intensity of its sourcing, Global Witness had to estimate emissions intensity of all other companies based on company reporting, which may use different methodologies. Quality of cocoa-specific reporting varied by year and inferences were made when data was not available.
A further caveat is that Mars and Mondelez do not declare sourcing volumes publicly, and so we used estimations from Cocoa Barometer. This graphic is only indicative and should not be seen as a definitive ranking of company sustainability performance.
2024 was the year for which sourcing volume data was most recently available, and most companies report improvements in 2025.
A full methodology document can be found at the bottom of this page.
A turning point for forests
The findings come with three months to go before the groundbreaking law is scheduled to enter into force – despite repeated pressure by US business interests and the Trump administration to dismantle it.
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Mondelez are an outlier among major chocolate producers. Last month, we revealed that the Toblerone manufacturer has led a pan-European campaign against the law since 2025, including by recruiting the Trump administration into its fight. Peers Nestlé, Ferrero and Hershey publicly back the law.
The company denied it was lobbying to weaken the EUDR, stating it was committed to “making sure the Regulation works effectively in practice, and we continue to invest significant resources to be ready for implementation.”
It’s full response can be read in our investigation into lobbying on the EUDR.
Despite Mondelez’s efforts to weaken the law, our analysis is the latest addition to a growing body of evidence that suggests EUDR is creating a positive cascade for forests across the globe.
New traceability schemes are emerging at national and state level to show compliance in Africa, Asia and South America. Crucially for cocoa, new national systems are being developed in Côte d’Ivoire and Ghana, which together produce between 50 – 60% of the world’s cocoa.
The EUDR has also led to the UK government announcing plans to finally bring in dormant deforestation legislation after a five-year delay, with the stated aim of aligning its laws with the EUDR in the medium term.
Mondelez’s failure to report notwithstanding, the data does appear to show the significant impact that the EUDR has had in the sector, both in reducing deforestation and reducing the carbon intensity of most companies’ cocoa.
But the data also shows that there is still work to do for Big Chocolate to close the gap to full deforestation-free sourcing.
With just three months to go before companies could be fined for non-compliance, the EUDR may have sparked a revolution in the chocolate industry – but to ensure progress is maintained, the law must see no further delays.
Time will tell whether the improvements that Big Chocolate details on paper translate to a future of deforestation-free chocolate in Europe and an end to West Africa’s deforestation crisis.
Methodology: Calculating emissions figures for cocoa sourcing
Authors
Charlie Hammans, Investigator – Forests
Christopher Lambin, Senior Data Investigator