In cocoa-producing countries - primarily in Latin America and Africa - outdated technologies and fragmented information make supply chain management and data collection particularly challenging. This context is further complicated by the need to comply with the upcoming EU Deforestation Regulation (EUDR).
Thanks to its partnership with Trusty, ICAM has successfully digitalized its cocoa supply chain in the countries where it operates, mapping approximately 26,000 plots. The results are encouraging: only 4.6% of these plots require further investigation.
The European chocolate market was valued at €47.3 billion in 2024, accounting for 43%[1] of the global market. This strong demand makes Europe the world’s largest importer of cocoa beans and cocoa-based products. Market stability is impacted by price volatility, climate change, labor issues, and production dynamics. On top of these challenges, new EU regulations - such as the EUDR[2], which includes cocoa among the regulated commodities - are placing strict constraints on imports.
ICAM, an Italian chocolate manufacturer with nearly 80 years of history, has always prioritized supply chains that respect both communities and the environment. It sources high-quality cocoa from a range of producing countries, including Uganda, Ecuador, Peru, the Dominican Republic, Togo, Cameroon, Nigeria, Congo (Brazzaville), and Colombia. Its constant commitment to sourcing the best raw materials has led to the development of a complex supply chain characterized by diverse origins, numerous suppliers, and a predominance of smallholder farmers. The resulting fragmentation of land ownership makes data collection - crucial for EUDR compliance - especially demanding.
To address this complexity, ICAM partnered with Trusty, a Benefit Corporation and innovative company that leverages blockchain technology to ensure regulatory compliance and traceability in agri-food supply chains, including cocoa and coffee.
The Data Collection Methodology
ICAM’s compliance journey began by organizing historical data collected over the years from various sources and tools - a process that required significant effort in normalization, cleaning, and verification.
A fully integrated digital solution was then introduced. It includes a mobile application for Android and iOS devices, paired with a satellite analysis platform. To ease the process of collecting geolocation data from farming plots, continuous technical support- both phone and online - was provided to individual farmers across multiple countries.
At the same time, the satellite platform integrated due diligence aligned with both local laws and international human rights standards. Starting from country-specific risk assessments, supported by global data sources, each supplier was required to adhere to ICAM’s Ethical Code and Cocoa Supplier Code of Conduct. This ensured clear commitment to shared values such as environmental protection, human rights, and compliance with both local and EU legislation, including the EUDR.
To coordinate the collection, verification, and digitization process, ICAM formed a cross-functional team. Representatives from quality, administration, IT services, and cocoa procurement worked under the guidance of the sustainability team, in close collaboration with Trusty's technical experts. Several processes were reviewed, starting with the collection of GPS data. Cocoa traceability protocols were strengthened to meet EUDR requirements, and the company’s management system was integrated with the EU’s digital platform. ICAM also revised internal policies and implemented mitigation and remediation actions to address deforestation risks and resolve non-compliant cases.
Challenges Faced
Rolling out traceability technologies was not without obstacles. Local stakeholders often lacked digital literacy, communication infrastructure was poor, and data was inconsistent or incomplete. Cocoa-producing countries face systemic issues such as low-resolution satellite images, incomplete land ownership databases, limited farmer registries, and unreliable mobile coverage.
“Our supply chain is highly fragmented and spans over 20 countries where we maintain active collaborations. We mainly work with smallholders - farmers who manage plots of half a hectare or less, smaller than a soccer field, and who often support entire families,” explains Sara Agostoni, Chief Sustainability Officer at ICAM. “During the EUDR compliance process, we found that most growers are not familiar with technology. A GPS device might seem trivial to us, but not to a farmer living in remote tropical areas with limited or inadequate infrastructure,” she continues. “Unlike major cocoa-producing countries like Côte d'Ivoire and Ghana - where governments supported supply chain actors -we’ve had to tackle compliance in our sourcing regions with our own resources, leveraging close collaboration with stakeholders. This approach strengthens the trust-based relationships we’ve built over time with our suppliers. We’ve always aimed to build partnerships that are both long-lasting and sustainable.”
The Results
Data digitalization has significantly improved the understanding of the supply chain, enabling data-driven decision-making and enhancing sustainability, transparency, and the detection of non-compliance. It also creates the opportunity to monitor future environmental and social risks while strengthening relationships with stakeholders.
To date, ICAM has mapped around 26,000 plots from its strategic suppliers. Only 4.6% show deforestation risks, and targeted investigations and mitigation plans are underway.
“Thanks to our close collaboration with Trusty, we have so far confirmed EUDR compliance for 95.4% of the plots belonging to our direct suppliers—well aligned with the regulation’s enforcement timeline,” says Sara Agostoni. “Looking ahead, we aim to continue supporting our suppliers - especially the smallest ones - by helping them implement monitoring and mitigation plans, staying true to our commitment to involve everyone and ‘leave no one behind’.”
A Strategic Choice for the Future
“In a rapidly evolving European chocolate market, and under new regulations like the EUDR, the complexity of ICAM’s long-standing and conscientious supply chains is both a challenge and an opportunity,” says Alessandro Chelli, founder and CEO of Trusty. “The results show that real added value lies in overcoming fragmented supply chains and weak digital infrastructure in origin countries by adapting technology to local contexts. This journey highlights the importance of acting now - complying with EUDR takes time, vision, and tools that go far beyond document management. It requires a sophisticated system for collecting, analyzing, and validating data across the entire supply chain. It’s a decisive choice - one of governance and strategic market positioning.”
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[1] https://www.cbi.eu/market-information/cocoa/what-demand
[2] Il Regolamento UE sulla deforestazione (EUDR)che entrerà in vigore il 30 dicembre 2025 per le aziende grandi e medie e il 30giugno 2026 per le micro e piccole imprese, prevede che materie prime comebovini, cacao, caffè, olio di palma, gomma, soia, legname e i loro derivatisiano a deforestazione zero (cioè non provenienti da aree deforestate dopo il31.12.2020), che siano prodotti nel rispetto delle leggi del Paese diproduzione e che siano accompagnati da una dichiarazione di Due Diligence.
