Nigeria: Europe's Anti-Deforestation Regulation Threatens Cocoa Exports -

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By Mike Visser
Africa Contemporary Trade & Agribusiness Magazine – April 2025 Edition

A Bitter Turn in the Chocolate Trade

Deep in the lush green highlands of Cross River State, cocoa is more than just a crop—it’s a lifeline. But for farmers like John Etta in Bendeghe-Afi, that lifeline is under threat. A new regulation from the European Union—the world’s largest cocoa market—is shaking up Nigeria’s cocoa trade, with implications that stretch from remote village farms to global chocolate shelves.

The European Union Deforestation Regulation (EUDR), now slated for enforcement in 2026, mandates that cocoa and other primary goods entering Europe must not originate from deforested land after 2020. Though designed to address climate change and biodiversity loss, this policy presents a major challenge for countries like Nigeria, where cocoa farming has quietly but steadily encroached into protected forest reserves.

A Boom Fueled by Survival

After six years of unsuccessful job-hunting, 29-year-old John Etta followed his uncle’s advice and turned to cocoa farming in 2021. Since then, he’s found more success in agribusiness than he ever imagined possible with a white-collar job. In his community, cocoa is gold.

With rising cocoa prices and scarce employment opportunities, families across Ikom and its surrounding communities have claimed whatever land they can, often stretching into the Afi Forest Reserve—an ecologically critical area vital for climate mitigation.

“Everybody is now in the forest reserve,” says forest ranger Bassey Foster. “The forest is not expanding, but the population is. People need the forest to survive.”

The sentiment is echoed by locals like Benjamin Takim, a “tracker” who transports cocoa from farms to local markets: “Nobody gave them access; they encroached because the government abandoned the land. Now, they consider themselves the owners.”

Forest or Food?

In places like Cross River, where cocoa farming has become widespread—even in people’s backyards—the hunger for land is fierce. A 100kg bag of cocoa now sells for up to ₦1.35 million during the off-season, and that number is expected to rise with the October harvest. With prices climbing and demand strong, encroachment into reserves has accelerated.

Though major cocoa processors like Tulip Cocoa Processing Limited, a subsidiary of Dutch giant Theobroma, claim to operate strict traceability systems, many in the supply chain admit the reality is less clear-cut.

“We don’t buy cocoa from protected areas,” a Tulip official said anonymously. “We register farmers and use GPS to ensure farms aren’t in forest zones.”

But on the ground, cocoa from legal and illegal farms often get mixed long before reaching exporters.

“There’s no way to track every bag,” says Takim. “Some bring out two tonnes in a season. That’s 32 bags. We just carry.”

Even Licensed Buying Agents (LBAs), such as Goddy Ukwu—who also serves as the national secretary of the Cocoa Association of Nigeria (CAN)—acknowledge the challenge. “About 20% of cocoa still comes from untraceable sources,” Ukwu admits.

A Race Against Regulation

For exporters dependent on EU markets, the stakes couldn’t be higher. Companies like Tulip, which expanded its processing capacity to over 30,000 tonnes annually, could face export restrictions if traceability gaps persist.

To mitigate this, some Nigerian stakeholders are pushing for local legislative action. Ukwu suggests de-reserving lands that have already been cultivated for years before the EU regulation was introduced.

“What is the EU saying, should we cut down the stems and replant trees?” he asks. “Cocoa trees absorb carbon too.”

His association is lobbying the Cross River State House of Assembly to formally reclassify parts of the Afi Forest that are already under cocoa cultivation, a move that could legally align these lands with EU standards.

Policy Meets People

Officials at the Cross River Forestry Commission confirm they’re aware of the issue and are taking steps. “As population grows, the demand for land will increase,” says Ibiang Essien, Director of Operations. “We’ll consider de-reservation demands but through proper legal channels.”

Mobile courts are also in the works to prosecute illegal forest encroachers, although such measures may be hard to enforce without offering alternative livelihoods.

A Fragile Future for Nigeria’s Cocoa

Nigeria ranks as Africa’s third-largest cocoa exporter, trailing only Ghana and Côte d’Ivoire. With the EU as its top buyer, any disruption to exports could hit a critical source of foreign exchange, second only to oil.

As the EUDR deadline looms, Nigeria faces a delicate balancing act: align with international climate goals while safeguarding the economic survival of tens of thousands of rural families.

For John Etta and countless others, the path forward is unclear. But one thing is certain: if Europe slams the door on cocoa from encroached lands, Nigeria must quickly find a way to either comply—or diversify its markets.

As Mr. Ukwu pragmatically puts it: “If Europe won’t take it, we’ll find other buyers. But this can’t go on forever.”

Understanding the EUDR

What Is It?
The European Union Deforestation Regulation (EUDR) aims to ensure that commodities like cocoa, coffee, palm oil, and timber imported into the EU are not linked to deforestation.
When Will It Be Enforced?
Initially scheduled for January 2025, it’s been delayed to 2026 due to global supply chain concerns.
What Does It Require?
Exporters must prove—through geolocation, traceability systems, and certification—that their goods are not sourced from land deforested after December 31, 2020.