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# Updated: The UKFRC & UKCC: EUDR 2.0 Lite? | #PSC 192
- URL: https://thechocolatelife.com/the-ukfrc-ukcc-eudr-2-0-lite-brexit-fomo-psc-192/
- Published: 2026-03-30T19:53:28.000Z
- Updated: 2026-04-01T17:48:15.000Z
- Description: Episode 192 of #PodSaveChocolate takes a look at the recent formation of the UK Cocoa Coalition, which hopes to influence the implementation of the UK Forest Risk Commodities regime. OR, is it Brexit-induced EUDR FOMO?
- Author: Clay Gordon
- Tags: PodSaveChocolate, Live Stream

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Episode 192 streamed on Tuesday, March 31st, 2026\.   
  
Click a link below to view the archived episode.

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This post was updated on Wednesday, April 1st, to include the link to the UKCC post on LinkedIn with an embedded PDF that (IMO) does not clarify the most important issues I discussed in the episode. I have also included the link to Cocoa Radar coverage on this topic. 

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## **Episode 192 Overview**

This episode of #PodSaveChocolate takes a look at a story that exploded in my feeds on Monday, March 30th (much of the information is behind registration paywalls, but I was able to retrieve it using other means):

[Barry Callebaut, Ferrero, Hershey & Tony’s Chocolonely join Cocoa CoalitionA look at how major chocolate makers (Barry Callebaut, Ferrero, The Hershey Company & Tony’s Chocolonely), NGOs (Rainforest Alliance, Fairtrade Foundation, WWF, International Cocoa Initiative, Sustainable Trade Initiative, and VOICE Network) and retailers (Sainsbury’s, Marks & Spencer, and Waitrose) uniting under the UK Cocoa Coalition marks a pivotal shift toward sustainable cocoa sourcing - and why this collaboration signals positive change for the future of cocoa and chocolate.![](https://thechocolatelife.com/content/images/icon/apple-touch-icon-180x180-34.png)ConfectioneryNews.comDonna Eastlake![](https://thechocolatelife.com/content/images/thumbnail/TPA7HENLKRGDNCELCDL2WSZ5BE.jpg)](https://www.confectionerynews.com/Article/2026/03/26/barry-callebaut-ferrero-hershey-tonys-chocolonely-join-uk-cocoa-coalition/?ref=thechocolatelife.com)

[Exclusive: UK Cocoa Coalition aims to deliver sustainable sourcing goals - Confectionery ProductionBarry Callebaut, Ferrero, Hershey and Tony’s Chocolonely are among a landmark UK Cocoa Coalition alongside leading civil organisations, coinciding with the 2026 International Day of Forests, seeking urgent delivery of key industry legislation![](https://thechocolatelife.com/content/images/icon/favicon-71.ico)Confectionery Production![](https://thechocolatelife.com/content/images/thumbnail/ghanacocoa1-scaled.jpg)](https://www.confectioneryproduction.com/news/57098/exclusive-uk-cocoa-coalition-aims-to-deliver-sustainable-sourcing-goals/?ref=thechocolatelife.com)

[UK Cocoa Coalition Calls for Action - International Confectionery MagazineTo mark International Day of Forests 2026, a new UK Cocoa Coalition has launched today in Parliament.![](https://thechocolatelife.com/content/images/icon/cropped-Square-Social-Logos-NEW5-270x270.jpg)International Confectionery MagazineEditor![](https://thechocolatelife.com/content/images/thumbnail/cocoa-diverse.jpeg)](https://in-confectionery.com/uk-cocoa-coalition-calls-for-action/?ref=thechocolatelife.com)

[Chocolate industry pushes UK Government for ban on deforestation-linked imports - edieMarks & Spencer, Barry Callebaut and Ferrero are among the members of a new cocoa industry coalition urging the UK Government to “urgently” implement a much-delayed ban on deforestation-linked imports.![](https://thechocolatelife.com/content/images/icon/apple-touch-icon-180x180-35.png)edieSarah George![](https://thechocolatelife.com/content/images/thumbnail/RocherChocolates12.gif)](https://www.edie.net/chocolate-industry-pushes-uk-government-for-update-on-deforestation-linked-imports-ban/?ref=thechocolatelife.com)

[Some detail on the UKFRC](https://www.edie.net/uk-fleshes-out-anti-deforestation-laws-for-supply-chains-publishes-domestic-nature-conservation-plans/?ref=thechocolatelife.com) (registration “pay”wall).

[UK Cocoa Coalition publishes position statement on UK Forest Risk Commodities Regulation - Business and Human Rights CentreCheck out this page via the Business and Human Rights Centre![](https://thechocolatelife.com/content/images/icon/logo.42e17ee4b348.svg)Business and Human Rights Centre![](https://thechocolatelife.com/content/images/thumbnail/Production_4.2e16d0ba.fill-1200x630.png)](https://www.business-humanrights.org/en/latest-news/uk-cocoa-coalition-publishes-position-statement-on-uk-forest-risk-commodities-regulation/?ref=thechocolatelife.com)

### **The UKCC “Position Paper”**

[UK Cocoa Coalition position statement on Environment Act | UK Cocoa CoalitionUK Cocoa Coalition calls for action on Environment Act provisions on forest risk commodities Cocoa production is still too often accompanied by deforestation and human rights abuses. The UK government can play a role in combating this and contributing to the development of secure and sustainable cocoa supply chains by bringing into force legislation that places conditions on the ways in which the cocoa imported into the UK is grown and harvested. The UK Forest Risk Commodities Regulation included in the Environment Act 2021 is designed to do just this, but more than four years after the Act was passed, it is still not in force, and the government has failed to confirm that it intends to do so or to set out a timetable. The UK Cocoa Coalition calls on the government to: 1 End the current uncertainty over the entry into force of the UK Forest Risk Commodities Regulation. 2 Publish the necessary statutory instrument as soon as possible. 3 Align the requirements of the Regulation with those of the EU Deforestation Regulation. 4 Engage with all stakeholders in the cocoa and chocolate supply chains in implementing and reviewing the requirements of the UK Regulation. For more detail, see the attached position statement.![](https://thechocolatelife.com/content/images/icon/al2o9zrvru7aqj8e1x2rzsrca-35)LinkedInUK Cocoa Coalition![](https://thechocolatelife.com/content/images/thumbnail/c45fy346jw096z9pbphyyhdz7-25)](https://www.linkedin.com/posts/uk-cocoa-coalition%5Fuk-cocoa-coalition-position-statement-on-activity-7442194424723476481-EaDi?utm%5Fsource=share&utm%5Fmedium=member%5Fdesktop&rcm=ACoAAAABaLUB44l0lzyoZ9nf9Lg8nfstgzLqxbg)

### **Cocoa Radar’s Questions**

[Three Uncomfortable Questions for the UK Cocoa CoalitionCocoaRadar comment: A strong political signal – but can it deliver real-world change?![](https://thechocolatelife.com/content/images/icon/sophie-LOGO-FINAL_WEB-7.png)From The Desk of CocoaRadar™Anthony Myers![](https://thechocolatelife.com/content/images/thumbnail/UK-Cocoa-Coalition-Members.jpeg)](https://cocoaradar.com/three-uncomfortable-questions-for-the-uk-cocoa-coalition/?ref=thechocolatelife.com)

This post appears to be free. There is more detailed coverage (behind a paywall) [here](https://cocoaradar.com/cocoaradar-exclusive-uk-cocoa-coalition-launch-signals-industry-push-for-urgent-deforestation-regulation/?ref=thechocolatelife.com).

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### **Topics**

- What ***are*** the UK Forest Risk Commodities Regulations? Goals? Status?

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The UK Forest Risk Commodities rules are a not-yet-operational UK due‑diligence regime targeting illegally produced forest‑risk commodities.

- What is the UK Cocoa Coalition? Who are its members, and what is its mission?

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The UKCC “launched” around International Day of Forests 2026 (specifically, on March 24th).  
  
Members include major chocolate manufacturers (Barry Callebaut, Ferrero, The Hershey Company, Tony’s Chocolonely), large UK retailers (e.g., Sainsbury’s, Marks & Spencer, Waitrose), and prominent NGOs and trade bodies (Rainforest Alliance, Fairtrade Foundation, WWF, International Cocoa Initiative, IDH, VOICE Network, among others).

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****Note**: Take a close look for webs of **potential* conflicts of interest. For example, Antonie Fountain is a C-Suite employee of VOICE Network and is an advisor to Be Slavery Free’s Chocolate Scorecard; that affiliation is not acknowledged on The Chocolate Scorecard website.

🗒️

The coalition is not neutral; it is explicitly ****calling on the UK government to**: a) bring the UK Forest Risk Commodities Regulation into force swiftly; b) align UKFRC closely with the EUDR, including a strong deforestation‑free standard; c) use the UKFRC as a lever to support ****farmer livelihoods**, address ****human‑rights violations**, and tackle ****illegal deforestation**.   
  
One of the key framings (in the announcement and reporting) is that “sustainability is no longer a competitive differentiator but an industry baseline.” That is a normative statement from industry and civil society that regulations like UKFRC/EUDR are becoming ****table stakes** for market access and brand legitimacy, **particularly for cocoa.*

- How is the UKFRC different from (and the same as) the EUDR?

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****UKFRC – legality-based, “illegal deforestation” focus.** The UKFRC is built around ***local** **legality**, not an absolute deforestation ban: affected UK businesses must not use covered commodities if they were produced on land used or occupied in violation of ****local land‑use or land‑tenure law** in the country of production.

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****EUDR – no‑deforestation + legality**. The EUDR combines an absolute deforestation cut‑off with a legality requirement. Products must be ****deforestation‑free**, meaning they cannot come from land deforested after 31 December 2020, regardless of whether that deforestation was legal locally.

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****Scope: covered (in-scope) commodities**  
****UKFRC:** Cattle products (beef and leather; **dairy excluded*), cocoa, palm oil, soy. **Products derived from these commodities* are also covered (including “waste” and by‑products). Timber is excluded here because it is handled under separate UK timber rules.   
****EUDR:** Wood and wood products, soy, beef, palm oil, cocoa, coffee, rubber; plus a wide range of **derived* products (e.g., chocolate, leather, paper, some furniture).

🗒️

****Scope: who must be in compliance**  
****UKFRC:** Targets ****large, high‑volume UK users.** Size threshold: global annual turnover > £50 million. Volume threshold: use of ****more than 500 tonnes/year** of each in‑scope commodity; those using ≤500 tonnes may apply (not automatically) for an exemption. Covered activities include: producing, manufacturing, processing, distributing, selling, supplying, or purchasing covered commodities and derivatives as part of UK commercial activity (irrespective of the consumers’ location(s)).  
****EUDR:** Applies to ****operators and traders** placing covered commodities and products on, or exporting them from, the EU market. There is no turnover or tonnage de minimis; instead, SMEs get somewhat simplified obligations, but they are still in scope. The obligations cascade across the supply chain (importers, manufacturers, traders), creating a wider net than UKFRC’s current design.

🗒️

****Scope: compliance**  
****UKFRC:** Affected businesses must implement a documented due diligence system and publish an annual report. That system must a) gather information on origin and supply chains; b) assess the risk that local land‑related laws were not complied with; c) take mitigation steps to address identified risks; and d) report annually on the system and its findings.  
****EUDR:** The EUDR’s due diligence model is significantly more data‑heavy: Operators must collect ****geolocation coordinates at the plot level** for all production areas supplying the regulated products. They must conduct risk assessment **and mitigation* that explicitly considers both deforestation risk **and* legal compliance. This makes the EUDR both more intrusive and more technologically intensive than UKFRC, and it pushes supply chains toward granular, plot‑level traceability.

🗒️

****Scope: enforcement**  
****UKFRC:** Because implementing regulations are not in force, enforcement is still a designed but not fully detailed architecture. Legal analyses anticipate: ****Civil sanctions**, including an unlimited monetary civil penalty for serious breaches, plus tools like stop notices and enforcement undertakings, and possible publication of non‑compliance; ****Targeted criminal sanctions** for certain failures (e.g., failure without reasonable excuse to keep/supply required information); and ****Investigatory powers** for the enforcement authority (expected to be the Secretary of State/DEFRA and designated agencies), including entry to premises, inspection of records, and potential seizure of products. But until secondary legislation is laid, these remain intentions, not fully specified rules.  
Under the ****EUDR**, Member States must provide for penalties that are: Effective, proportionate, and dissuasive, including: Fines up to ****4% of EU turnover; c**onfiscation and/or destruction of non‑compliant goods; exclusion from public procurement; potential market‑access restrictions or bans.

[The UK Forest Risk Commodities RegulationsAn overview![](https://thechocolatelife.com/content/images/icon/favicon-72.ico)Hill Dickinson![](https://thechocolatelife.com/content/images/thumbnail/reema-shour-ldn-12-1.jpg)](https://www.hilldickinson.com/our-view/articles/the-uk-forest-risk-commodities-regulations-an-overview/?ref=thechocolatelife.com)

One source.

[EUDR Update: Legislator’s Remorse? | #PodSaveChocolate Ep 137Episode 137 explores some implications of a recent vote by the EU Parliament to amend the EUDR, as well as calls to delay (again) it coming into force. \[Updated to include links to other episodes dedicated to EUDR coverage.\]![](https://thechocolatelife.com/content/images/icon/JR_Pods60x60FavIconCutoutButtons-434.png)The Chocolate LifeClay Gordon![](https://thechocolatelife.com/content/images/thumbnail/Ep-137-EUDR-Desolation---Featured1920x1080-3.jpg)](https://thechocolatelife.com/eudr-update-legislators-remorse-podsavechocolate-ep-137/)

[The EUDR, CSDDD, CSRD, and ESRS | #PodSaveChocolate Ep82Episode 82 of #PodSaveChocolate features an exploration of four related EU regulations that affect the cocoa and chocolate industries – how they relate and who needs to worry about compliance will be addressed.![](https://thechocolatelife.com/content/images/icon/JR_Pods60x60FavIconCutoutButtons-433.png)The Chocolate LifeClay Gordon![](https://thechocolatelife.com/content/images/thumbnail/Ep-082-EUDR-CSDDD-CSRD---Featured1920x1080-2.jpg)](https://thechocolatelife.com/the-eudr-csddd-and-csrd-podsavechocolate-ep82/)

[The EUDR and You – w/ Antonie Fountain | #PodSaveChocolateEpisode 9 of #PodSaveChocolate features Antonie Fountain of the VOICE Network. Starting time: 10 am PST / 1 pm EST / 6 pm GMT on December 19th, 2023.![](https://thechocolatelife.com/content/images/icon/JR_Pods60x60FavIconCutoutButtons-435.png)The Chocolate LifeClay Gordon![](https://thechocolatelife.com/content/images/thumbnail/Ep-009---EUDR-Good-Bad-Ugly---Featured1920x1080-2.jpg)](https://thechocolatelife.com/the-eudr-and-you-w-antonie-fountain-podsavechocolate/)

- What is the overlap with the recently announced **TogetherCocoa** foundation?

🗒️

Apart from having one co-member (The ****Hershey** Company), the focus of the UKCC is broader than ****TogetherCocoa**.   
  
Adapted from above: \[the UKCC plans to lobby UK regulators to\] **use the UKFRC as a lever* to support ****farmer livelihoods**, address ****human‑rights violations**, in the process of tackling ****illegal deforestation**. 

[Mars, Mondelēz, Nestlé, Hershey, and Lindt team up to transform future of cocoaThe world’s leading confectionery companies - Mars, Mondelēz, Nestlé, Hershey, and Lindt & Sprüngli - have launched TogetherCocoa, a new foundation aimed at supporting cocoa‑growing communities in Côte d’Ivoire and Ghana, and strengthening sustainability across the global cocoa supply chain.![](https://thechocolatelife.com/content/images/icon/apple-touch-icon-180x180-36.png)ConfectioneryNews.comDonna Eastlake![](https://thechocolatelife.com/content/images/thumbnail/3TRREMPELJGOXFEGMUVW3QQEFQ-1.jpg)](https://www.confectionerynews.com/Article/2026/02/24/mars-mondelez-nestle-hershey-and-lindt-team-up-to-protect-cocoa-and-support-growers/?ref=thechocolatelife.com)

- Who benefits financially? Who foots the costs of compliance?

🗒️

Financially? Not farmers. In the EUDR, the real winners are the companies supplying the technologies used for satellite surveillance and hardware and software necessary to perform compliance reviews. UKCC members will use their efforts to secure additional financial support (NGOs) and market greenwashing to customers.  
  
Farmers will not benefit unless specific targets that provide living wages are implemented in the regulations. (Which may not be legally enforceable in countries like Ghana.)  
  
Who will foot the bill? Ultimately, consumers, taxpayers, and farmers.

- Can the UKFRC, like the EUDR, be considered a form of economic imperialism?

🗒️

YES! It’s a group of actors – megacorporations, governments, and NGOs – that are not domiciled in producing countries trying to impose regulations on actors in producing countries without including them in the decision-making processes.

- Is it too little, too late?

🗒️

Probably.

- Is it the (or even a) right thing to do?

🗒️

Probably not, based on the history of all such previous attempts, including, most recently, the EUDR. Beware unintended consequences that will arise from the combative process of writing regulations that end in unworkable compromises because the people writing the regulations seem blissfully unaware of what they don’t know they don’t know.

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### **Related Reporting**

[Updated: March News & AMA | #PSC 186OVERVIEW: Episode 186 of #PodSaveChocolate features chocolate and cocoa news fit to eat, as well as the monthly live AMA (Ask Me Anything about chocolate or cocoa) for March 2026.![](https://thechocolatelife.com/content/images/icon/JR_Pods60x60FavIconCutoutButtons-432.png)The Chocolate LifeClay Gordon![](https://thechocolatelife.com/content/images/thumbnail/Ep-186-March-NewsAMA---Featured1920x1080-1.jpg)](https://thechocolatelife.com/march-news-ama-psc-186/)

The formation announcement of the ****TogetherCocoa Foundation** is covered in this episode.

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### **Future Episodes**

🗓️

Friday, April 10th  
****A conversation with Shawn Askinosie** **on the 20th anniversary of our first bean sourcing trip (to Mexico and Venezuela).*

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### **Episode Hashtags and Social Media Links**

#cocoa #cacao #cacau  
#chocolate #chocolat #craftchocolate  
#PodSaveChoc #PSC  
#LaVidaCocoa #TheChocolateLife

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