Ghana supplies roughly a fifth of the world's cocoa and, in the EU's May 2025 benchmarking act, landed in the low-risk tier, unlike Côte d'Ivoire next door. For chocolate companies that source both, the border between the two origins is now a compliance boundary: same beans, same farm sizes, different legal procedure. This page covers what the classification is worth, the state mapping programme you can lean on, and the mixing trap that can cost you the simplification.
What low risk changes for Ghanaian lots
Under Article 13, cocoa produced entirely on Ghanaian plots qualifies for simplified due diligence: no formal risk assessment, no mitigation step, and a 1% inspection target instead of 3%. Everything else stands. You still collect full Article 9 information including plot geolocation, still file a DDS in TRACES, and still keep the five-year evidence file. And the exemption is conditional: you must document that you assessed the risk of mixing with cocoa of unknown or standard-risk origin and found it negligible, and any contrary information snaps the full obligations back. The simplified due diligence guide covers the conditions; Vietnamese coffee and Thai rubber face the same structure.
The cross-border mixing problem
Cocoa is smuggled across the Ghana-Côte d'Ivoire border in both directions, in volumes that move with the two countries' farm-gate prices. That trade is exactly what Article 13 makes your problem: Ivorian beans in a nominally Ghanaian lot are standard-risk material of undeclared origin, and their presence disqualifies the simplified track for the consignment. Your file for Ghanaian lots should therefore show the chain of custody from licensed buying through to export, and your plot data gives you a hard check: every declared coordinate should fall inside Ghana, and volumes per plot should be plausible against declared farm areas. A lot whose paper volume exceeds what its mapped plots can grow is the classic signature of mixing.
COCOBOD's mapping head start
Ghana's cocoa sector is centrally organised: COCOBOD licenses buyers, runs quality control, and markets exports. Over the last several years it has built a cocoa management system that registers farmers and maps farm boundaries, with well over a million farms polygon-mapped, and the sector has been piloting EUDR-shaped traceability from licensed buying company records through to port. For an importer this is the richest state-held plot dataset in West Africa. It reaches you through your exporter or licensed buyer, so the contractual ask is the same as anywhere: the plot file per lot, as GeoJSON, with farmer identifiers, polygons or points as appropriate, and production dates. Ghanaian farms straddle the 4-hectare line, so expect a genuine mix of points and polygons.
Screen anyway
Low risk describes the country, not your plots, and Ghana has active deforestation pressure in its western cocoa frontier, including encroachment into forest reserves. A plot inside a reserve fails the legality limb regardless of tier, and a screening hit is precisely the "information pointing to a risk" that revokes Article 13 for that supply. Screening every plot against the 2020 cutoff plus protected-area boundaries is cheap, and a clean run is the best possible content for your Article 13 basis note. The benchmark list is also dynamic: build your file as if the tier could change, and a revision will cost you a procedure update instead of a re-collection campaign.
Sequence for Ghanaian cocoa
- Contract plot files per lot through your licensed buyer or exporter, drawing on the national mapping where available.
- Verify all coordinates fall inside Ghana; reconcile lot volume against mapped farm areas.
- Screen plots, write the Article 13 basis note, and keep the custody records that support it.
- File the DDS in TRACES and retain the file for five years.
If your book spans both origins, run Ivorian lots on the full standard-risk track and keep the two procedures, and the two plot files, cleanly separated.