By Sogand Shaker-Grambas, Head of Legal and Innovation, Treefera

On December 30, 2025, the European Union Deforestation Regulation (EUDR) comes into force. For companies placing products containing cocoa, coffee, soy, palm oil, wood, cattle or rubber on, or exporting out of, the EU market, the implications are far-reaching. The regulation requires that in-scope products are not associated with deforestation and that they are produced in compliance with all relevant local laws.

This is not just a reporting exercise. It is a trade requirement. Companies must be able to demonstrate – through verifiable data and supporting documentation – that their products were lawfully produced on land that was not deforested after December 31, 2020. Non-compliance carries commercial consequences. These may include blocked shipments, reputational risk and significant penalties across the value chain.

At the heart of the challenge lies a structural issue. The first mile of supply chains – the origin point where commodities are cultivated or extracted – remains poorly documented. While most enterprises have visibility into logistics and processing, few maintain complete records at the plot level. Land tenure, forest status, environmental obligations and third-party rights are often scattered across formats, languages and jurisdictions.

At Treefera, we are building infrastructure to address this. We step into the shoes of a French premium chocolate manufacturer to provide a detailed example of what meaningful, first-mile compliance looks like in practice.

Case Study: French Premium Chocolate Manufacturer | Madagascar

Client

A premium French chocolate brand (both an operator and trader) directly sourcing cocoa from a plantation in Madagascar.

Commodity in Scope

The chocolate manufacturer needs to comply with EUDR as it imports cocoa (in the form of cocoa beans, pastes and other cocoa derived products) from Madagascar into France.

Region and Plot Level Risk

Many of Madagascar’s forests fall within protected areas, which are known to be rapidly declining and under major pressure from agricultural expansion. Whilst Madagascar is rated as a low-risk country by the European Commission (EC) as of June 2025, the chocolate manufacturer is still obliged to collect and submit the full scope of information required under EUDR. If the manufacturer suspects there is deforestation or illegal production taking place at the plot or supplier level, then it needs to undertake further due diligence through a formal risk assessment and mitigation.

The chocolate manufacturer only has the geolocation coordinates of the plantation but not the full plot boundary (a requirement under EUDR) due to poor data availability from its supplier. The plantation also includes mixed land ownership by the French chocolate brand and numerous local partners. However, land title records are not centrally maintained given the historic absence of a formal, regulated land registry in Madagascar.

What Treefera’s Work Achieves

• Processed and verified plantation polygons using platform geolocation features when supplier input is lacking
• Conducted remote sensing analysis to detect deforestation between 2020 and the relevant production period using open source datasets and Treefera’s proprietary models
• Flagged potential risk factors based on proximity to protected areas, historical fires and land use changes.
• Referenced major categories of local laws and requirements to consider for local law compliance and risk mitigation (such as land tenure, environmental laws, free prior and informed consent, labour rights).
• Export EUDR risk ratings and documentation to support due diligence statements Ongoing, near real-time monitoring of location and surrounding plots for any land use change, weather related events and potential deforestation activity

Result

The French Chocolate Manufacturer now has full plot-level traceability and legal defensibility for its cocoa production in Madagascar to support compliance with EUDR. Data from the first mile is downloadable in a standardized format, audit-ready, and scalable via Treefera’s platform.

Built for Compliance, Not Complexity

Treefera was developed with legal, technical, and sourcing teams in mind. The platform adapts to your workflow and scales with your supply base.

Clients use Treefera to:

• Replace spreadsheets and field reports with standardized outputs
• Identify risks early, before enforcement action
• Maintain continuous visibility as new laws or suppliers are added

Find out more about EUDR in our Resource Hub

EUDR Resource Hub