Despite heavy protests from industry and country leaders, including German chancellor Olaf Sholz, in the summer a band FMCG behemoths like Ferrero, Mars and Nestlé wrote the European Commission urging it to press on with the 30 December EUDR go date.
Read more: EUDR delay of 12-months floated by European Commission
“The EUDR represents an important step forward in driving the necessary transformation of the cocoa and chocolate sector, by helping to minimise the risk of deforestation associated with cocoa and chocolate products placed on the EU market,” said the statement.
However, in recent months around 45 countries – including the USA – and agricultural leaders have warned the European Commission to delay the regulation, stressing a state of global unpreparedness.
Will there be an EUDR delay?
Business, environmental and charity leaders have all warned that, while the EUDR is a positive, more time is needed to allow growers and other businesses to get their organisations in order and understand often confusing guidance.
The European Commission has not responded to comment requests about a need for EUDR delays, but said everything was being done to “ensure things are in place on time”.
Experts recently told FoodNavigator a delay was possible and should even be expected at this stage as the lack of preparedness in some parts of the food industry – and outside of it also – was shocking.
Yet, the major players like Mars and Danone appear to be ready for the rule change. So how have they become so confident? How EUDR-friendly are their businesses? And what measures have these big snack and confectionery majors put in place to stay on the side of the law?
Unilever’s EUDR progress
Sourcing at Unilever is 97.5%, independently verified, deforestation-free across its main crops of palm oil, paper & board, tea, soy and cocoa.
“Building the infrastructure we needed to reach 97.5% deforestation-free in these five commodities has been a great challenge, but also a great opportunity,” the business says.
“It has required collaboration with many like-minded partners in forest landscapes. However, we will not compromise on protecting forests […] we will continue to invest in product innovation and reformulation to ensure the ability to manage our growth with diversified and sustainable feedstocks and manage a just transition to net zero.”
But how do the commodities break down?
- 97.5% – total deforestation-free supply chain
- 99.1% – paper & board
- 97.1% – palm oil
- 97.1% – tea
- 95.8% – soy
- 91.1% – cocoa
The business also has a number of initiatives in place to report “transparently” and also support the bigger picture, including people and beyond its supply chain.
Danone’s commitments to EUDR
At the end of 2022, Danone published its Renewed Forest Policy which made pledges to have a fully-traceable, “clean” supply chain by 2025 to coincide with its already deforestation and conversion-free verified direct supply chains.
In the same year Danone pledged it would have a “cascade of deforestation and conversion-free commitments in line with our cut-off dates through our direct supply chains”.
And by the turn of the decade, Danone would support the protection and restoration of vital ecosystems, strengthening farmer livelihoods, through partnerships and coalitions.
By 2020, however, Danone claimed:
- 100% directly purchased soy certified or from low risk regions
- 100% Alpro soybean traceability to farm
- 98% of palm oil certified:
- 100% traceable to mill
- 85% traceable to plantation
- 80% of cocoa certified
- 98% certified paper & board for packaging
- 100% paper & board traceable to country, 90% to mill
In its 2023 Forest Update, Danone said: “Our strategy targets five key materials linked to deforestation and land conversion, based on stakeholder consultation and evidence from the WWF Risky Business report and EU deforestation-free product legislation.
“All raw materials, not just those in our Renewed Forest Policy, fall under our Sustainable Sourcing Policy. Our commitment applies to Danone Group, including operations, third-party manufacturers, and relevant supply chains.”
Mondelēz International targets more sustainable snacking
Like all major food and drink makers, Mondelēz has set out to source ingredients from sustainable, non-deforested sources.
“Our goal is to seek no deforestation across our primary commodities following a phased approach starting with our European business by 30 December 2024 and roll out to our other regions by 31 December 2025,” the business says.
It views cocoa and palm as two "at risk" commodities within its strategy to wipe deforestation from its entire supply chain.
Mondelēz engages with suppliers and encourages them to “take efforts to end deforestation in their supply chains”, it says.
Palm is fully RSPO certified in the business since 2013, and Mondelēz publishes its mill list to provide traceability transparency.
Progress made for deforestation-free commodities is as follows:
- 85% – cocoa volume sourced through Cocoa Life
- 99% – wheat for Europe grown under the Harmony charter
- 99% – palm oil traceable to mill
- 90% – palm oil traceable to plantation
- 97% – palm oil traceable and forest monitored
- 100% – palm oil RSPO certified
- 96% – packaging designed to be recyclable
Nestlé confident about EUDR sourcing
Over 99% of the total volume of Nestlé’s key ingredients – meat, palm oil, pulp & paper, soy and sugar – were deemed to be deforestation-free in 2022.
However, this dropped to 93.4% by the end of 2023 due to the inclusion of coffee and cocoa within the deforestation-free indicator.
By 2025, the business aimed to source 100% of its cocoa and coffee from deforestation-free supply chains.
“Our work on sourcing deforestation-free key ingredients started over a decade ago, and we believe our experience will help us meet the new EU requirements,” says Nestlé.
“We have responsible sourcing core requirements that we ask our suppliers to adhere to when doing business with us, including on forest protection and conservancy.”
Nestlé deforestation-free supply chains broken down through assessment:
- 47.7% – come from non-high-risk origins
- 23.1% – assessed on the ground
- 22.7% – assessed from the sky
But how does it look when Nestlé's commodities are broken down?
Mars sets out Deforestation-free Principles
Deforestation at Mars is defined by a series of principles and the business holds its suppliers accountable and benchmarks against these.
Mars expects suppliers to sell it legal products only, from non-deforested land and with supply chain transparency.
Suppliers are also expected to respect human rights, resolve land disputes through a transparent resolution process and to support land restoration and enhancements.
“There is no time to lose,” says Mars. “Ensuring a deforestation-free supply chain for a discrete corporate ‘buyer’ is a positive step, but we aren’t satisfied if our suppliers continue to contribute to deforestation elsewhere in their businesses.”
When it comes ensuring limited environmental and the deforestation-free sourcing of the five main commodities Mars sources, it says:
- Beef: By the end of 2017, 100% of Mars’s Brazilian beef was to be bought from suppliers compliant with the Brazil Fores Code, who are able to show livestock is not associated with primary forest clearance in the Amazon Biome
- Cocoa: All cocoa sourced by mars is from non-deforested land, it claims
- Palm: In Mars’s Palm Positive Update 2024, the business stated all palm was 100% deforestation-free, with mill traceability at 100% and plantation traceability at 96.3%
- Pulp & paper: Mars continues to work towards 100% traceability of virgin pulp and paper-based packaging to at least the country of harvest. It aims for 100% certified, verified or recycled sources for its fiber sources
- Soy: By 2017, Mars claimed 100% of its soy bought from Brazil would be certified under the Brazil Forest Code, and by 2025 it would aim to stop deforestation and conversion of natural ecosystems for its soy from Latin America
Ferrero “in a good EUDR position”
Italian-headquartered snacking and chocolate giant Ferrero’s sustainability report is claimed to centre around farmers and communities.
Across each of the business’s core commodities, Ferrero outlines how it continues to increase supply chain traceability, as well as the organisations it works with to help strengthen supply chain security and traceability.
“Our approach is built around robust due diligence, supplier management, traceability and transparency certification and standards, partnerships and collaboration,” says head of responsible sourcing Nicola Somenzi.
“We welcome legal frameworks which create a levelled playing field in the industry, such as the EU regulation on deforestation-free supply chains.”
Ferrero’s traceable commodities:
- 90% – hazelnut
- 93% – cocoa
- 98% – palm oil
Since 2019/20, Ferrero has increased its cocoa traceability from 50% to its 93% high, hazelnut traceability has also risen from 2019/20 when it was 51%. Palm oil, however, has dipped since a 100% traceability record in 2019/20 to 99% over the following two years, and 98% last year.
The business has also focused on obtaining high levels of standards and certifications across its supply chain, with cocoa and sugar supplies 100% certified and palm oil at 99.6%.