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  "description": "As the industry gathers in the Dutch capital next week, much of the regulatory spotlight remains fixed on the Corporate Sustainability Due Diligence Directive (CSDDD) and the EU Deforestation Regulation (EUDR), but, as Cocoaradar reveals, the FLR, should not be dismissed",
  "path": "/forced-labour-regulation-a-turning-point-for-the-cocoa-sector-ahead-of-amsterdam-cocoa-week/",
  "publishedAt": "2026-02-13T13:28:02.000Z",
  "site": "https://cocoaradar.com",
  "tags": [
    "COOKO WORKSHOP: Reality Cheque: Redesigning the West African Cocoa Value Chain  Who is cashing the sustainability cheque? The high cost of traceability has made it clear: we are paying for process, not progress. GET YOUR TICKET HEREI",
    "**_agenda_**",
    "**Chocoa**",
    "**Sign-up here**"
  ],
  "textContent": "In an exclusive interview, Sarah Dekkiche, Director of Policy and Partnerships at International Cocoa Initiative (ICI), tells Cocoaradar of another regulation that may ultimately shape the sector profoundly has advanced almost quietly: the EU Forced Labour Regulation (FLR).\n\nAdvertisement\n\n \n\n“The Forced Labour Regulation came a bit out of the blue. It did not receive the same level of political scrutiny as CSDDD or EUDR. And yet, it may prove to be one of the most consequential,” Dekkiche explains. “Everyone’s eyes were on something else. Now it’s here — and we need to be ready for it.”\n\n### Obligation of Means vs. Obligation of Results\n\nAt the heart of the issue lies a structural regulatory tension.\n\nUnder the Corporate Sustainability Due Diligence Directive (CSDDD), companies are subject to an _obligation of means_. They must establish and implement a robust human rights due diligence (HRDD) process and are assessed on the quality and credibility of that process.\n\nThe Forced Labour Regulation, by contrast — EU Forced Labour Regulation — establishes an obligation of results. If a product is found to be linked to forced labour, it can be banned from the EU market.\n\n> As Dekkiche clarifies: “In contrast to the CSDDD, which places an obligation of means on companies, the Forced Labour Regulation defines an obligation of results, linked to a potential product ban. That creates a fundamental tension.”\n\n## Sign up for From The Desk of CocoaRadar™\n\n'From our desk to yours'. Join our growing community of subscribers and receive our daily newsletter on what matters in cocoa.\n\nSubscribe\n\nEmail sent! Check your inbox to complete your signup.\n\nNo spam. Unsubscribe anytime.\n\nThis misalignment is amplified by three critical differences:\n\n  * **Scope** : The Forced Labour Regulation applies to _all companies_ , regardless of size or sector. CSDDD directly concerns only very large companies.\n  * **Definition of due diligence** : CSDDD outlines relatively specific HRDD expectations. The Forced Labour Regulation frames due diligence more broadly — leaving significant room for interpretation.\n  * **Focus** : CSDDD evaluates the company’s overall HRDD process. The Forced Labour Regulation links due diligence expectations to a specific product outcome.\n\n\n\n“The due diligence requirements under the Forced Labour Regulation are framed more generally, yet tied to a potential product harm. That is, in itself, a contradiction,” Dekkiche notes.\n\nWithout alignment, companies may find themselves compliant in process — yet vulnerable in product.\n\n### Cocoa’s Specific Realities\n\nAvailable data indicate that forced labour in cocoa exists but is significantly less prevalent than child labour. Reported risks include:\n\n  * Withholding of wages\n  * Hazardous working conditions\n  * Absence of formalised employment agreements\n  * Trafficking in specific contexts\n\n\n\nAn important nuance, Dekkiche emphasises, is that forced labour is defined by two core elements (in line with the ILO definition):\n\n  * **Absence of free and informed consent**\n  * **Presence of coercion or threat**\n\n\n\nIn cocoa-growing communities, many cases are linked to structural vulnerabilities — including informal labour arrangements.\n\n> “Formalising employer–employee relations is fundamental. Written agreements matter. Awareness-raising matters. Many people may not even recognise when they are in a forced labour situation.”\n\n### **What Works: Prevention, Mediation, and Collaboration**\n\nICI’s externally verified pilot grievance mechanisms in Ghana offer practical insight into what works.\n\nDekkiche outlines a four-pillar approach:\n\n  1. **Prevention**\n\n\n  * Awareness raising\n  * Training\n  * Formalizing worker relations (including written or documented agreements)\n\n\n  1. **Mediation**\n\n\n  * Many situations can be resolved through structured mediation before escalation.\n\n\n  1. **Identification & Remediation**\n\n\n  * Grievance mechanisms operating throughout supply chains and/or at the community level\n  * Individual case resolution and referral where needed\n\n\n\n“A lot of forced labour issues can be addressed through prevention and mediation. Our pilot has led to very positive results.”\n\n  1. **Collaborative Approaches**\n\n\n  * Cross-industry grievance mechanisms\n  * Landscape-level interventions\n  * Pre-competitive pooled funding\n\n\n\nCollective action becomes particularly relevant when structural risk factors, rather than isolated actors, drive vulnerability.\n\n COOKO WORKSHOP: Reality Cheque: Redesigning the West African Cocoa Value Chain  Who is cashing the sustainability cheque? The high cost of traceability has made it clear: we are paying for process, not progress. GET YOUR TICKET HEREI \n\n### **The Traceability Challenge**\n\nA further complexity lies in the feasibility of enforcement.\n\nCocoa supply chains frequently rely on mass balance systems, meaning beans are mixed along the chain. Linking a specific forced labour case to a specific end product may be technically unrealistic — even when companies have implemented preventive systems.\n\nThis raises difficult enforcement questions under a product-ban model.\n\n### **The Decisive Role of EU Guidelines**\n\nThe European Commission is expected to issue guidelines by mid-year, seen as a pivotal moment for NGOs like the ICI, which has long campaigned for ending child labour in the cocoa supply chain.\n\nDekkiche tells CocoaRadar that the ICI is currently working with partners to develop recommendations to ensure the guidance:\n\n  * Clearly defines what due diligence means in forced labour contexts\n  * Recognises sector and geographic realities\n  * Clarifies the relationship between company-level HRDD and product-level enforcement\n  * Enables lawful collaboration (including clarity on competition concerns)\n  * Ideally includes sector-specific supporting materials\n\n\n\n> “Guidelines that are practical and clear in defining what it means to do due diligence in relation to forced labour will be key — ideally, sector-specific,” she says.\n\n### **A Sector Under Pressure**\n\nAmsterdam Cocoa Week offers more than networking and panel discussions. It presents a strategic inflection point.\n\n“We are at a turning point. There are areas that cannot be addressed without stronger public–private alignment. The question is how — and who provides the resources to make that alignment effective,” says Dekkiche.\n\nWhether it becomes a compliance shock or a catalyst for smarter alignment between regulatory and sustainability systems will depend on clarity, coordination, and collective leadership in the months ahead.\n\nFor a sector already navigating the implementation of CSDDD and EUDR, the message is clear: forced labour is no longer a peripheral issue.\n\nIt is the next defining test.\n\n  * **Matthias Lange, Executive Director, ICI, is part of a panel discussion: Connected for Change: Public & Private Synergy to End Child Labour at the World Cocoa Foundation Partnership Meeting in Amsterdam on 17 February 2026. 11:45.\nSee ****_agenda_****for more details.**\n\n\n\n* * *\n\n**cocoaradar.com is:**\n\n  * **Official Media Partner - Amsterdam Sustainable Cocoa Conference,****Chocoa****, 2026.**\n  * **'From Our Desk. To Yours. Daily'**\n  * **Sign-up here****for free and choose your plan.**\n\n",
  "title": "Forced Labour Regulation: A Turning Point for the Cocoa Sector Ahead of Amsterdam Cocoa Week",
  "updatedAt": "2026-02-13T13:28:02.000Z"
}