Mondelez International, the Chicago-listed confectionery group behind Toblerone, Milka and Cadbury, has stepped up its lobbying in Brussels to delay the European Union's flagship anti-deforestation law, having previously supported the same legislation. The shift is documented in research published on Tuesday by the transparency campaign group Global Witness.

The EU Deforestation Regulation (EUDR), adopted by the European Parliament and Council in 2023, requires importers of cocoa, coffee, palm oil, soy, beef, rubber and timber to prove that the land these products were grown on was not deforested after December 2020. Traders must collect geolocation data on plots of origin and submit due diligence statements via an EU information system before goods can be placed on the EU market.

In a 2020 submission to the European Commission's public consultation, Mondelez was unequivocal. "When it comes to EU policy action to tackle deforestation Mondelez International supports the adoption of harmonised due diligence legislation in the European Union," the company wrote. It also joined a "Cocoa Coalition" with Ferrero, Mars, Nestlé and Tony's Chocolonely, which in 2024 urged EU policymakers not to postpone the regulation when a first 12-month delay was being negotiated.

A chocolate maker's about-face

By July 2025, that consensus had fractured. Mondelez publicly broke ranks and called for a second 12-month postponement, on the grounds that cocoa farmers, particularly in West Africa, are "far from being ready" to supply the traceability data the regulation demands. The argument is not invented. Industry surveys and NGO field reports have repeatedly flagged gaps in mapping smallholder plots, digitising boundaries and integrating them with the EU's information system.

What changed in Mondelez's calculation is harder to pin down. Cocoa prices hit record levels in 2024 and have remained historically high, depressing chocolate volumes and squeezing manufacturers' margins. Compliance with the EUDR imposes costs on buyers: tracking beans from millions of smallholders, verifying land use and reconfiguring supply chains. Some of those costs will land on Mondelez and its processors, even if they are partly passed on to consumers.

Global Witness argues that Mondelez has moved from public endorsement to quiet pressure. The campaign group tracked the company's filings on the EU's Transparency Register and reviewed position papers sent to the European Commission and member states' permanent representations in Brussels. It describes a more sustained, technical engagement than the brief calls for "more time" that characterised the 2024 lobbying round.

Why Mondelez broke with its peers

The other members of the Cocoa Coalition have not followed Mondelez's pivot. Ferrero, Mars, Nestlé and Tony's Chocolonely have continued to back implementation on schedule, though all have flagged operational difficulties. Their divergence matters because the EUDR is unusual in being designed to apply competitive pressure: by obliging every importer to meet the same due diligence standards, it removes the first-mover disadvantage that had deterred individual companies from cleaning up their supply chains.

That design is also why a single company's lobbying campaign carries weight. If one major buyer secures an exemption or a delay, others argue they cannot be held to standards their competitors are not meeting. The Commission, for its part, has framed the regulation as a level playing field rather than a concession to any one industry.

A regulation already pushed back once

The regulation's application has already been postponed once. The original entry date of 30 December 2024 was moved by 12 months, to 30 December 2025 for large operators and 30 June 2026 for smaller traders. A further postponement, the one Mondelez is now pressing for, would push the large-operator deadline into late 2027.

The European Commission has not publicly signalled it will grant a second delay. Officials have focused instead on the technical readiness of the EU information system and on guidance for operators. Member states are split. West African producing countries have pressed for more time, while the Netherlands, Germany and several Nordic governments want the regulation to apply as drafted.

Why the timing is awkward for cocoa

For the cocoa sector, the timing is uncomfortable. Cocoa-driven deforestation in Ivory Coast and Ghana, which between them produce the majority of the world's cocoa, has been a particular concern: satellite data suggests protected and classified forests in both countries have continued to shrink over the past decade. That backdrop is precisely what the EUDR was drafted to address, and what critics say companies prefer to delay rather than act on.

Mondelez has framed a delay as essential to give farmers time to comply without being cut out of EU supply chains. Environmental groups see it differently. They argue that the EUDR was designed precisely for an industry that would, in the absence of legal compulsion, keep postponing traceability. Whether one reads the situation as a genuine capacity problem or a reluctance to absorb compliance costs shapes whether a further postponement looks reasonable or self-serving.

Where the lobbying is heading

The next test of Mondelez's position will come as the European Commission prepares its next progress report on the regulation's implementation, expected later this autumn. If the company and its allies secure another postponement, the law's credibility as a tool against imported deforestation will be visibly weakened. If they do not, Mondelez will need to show that the intervening time has been spent bringing its supply chain into compliance rather than lobbying against the rules.

Organisations

Mondelez International · Global Witness · European Commission · European Parliament · Ferrero · Mars