Supporting Farmers and Chocolate Companies on the Implementation of the EU Cadmium Regulation

Implementation of the EU Regulation

Each EU member state is responsible for the implementation of the regulation in its own country, with the EU as general auditing body. Controls are carried out at EU borders or in supermarkets. The company that brings the chocolate to the market is responsible for complying with the European rules. Actions that the EU has undertaken since the early 2000s include: informing recipients, rejecting lots at the border, recalling and destroying products. The Rapid Alert System for Food and Feed (RASFF) informs consumers about food recalls and sends food safety warnings. So far, there have been no fines imposed on chocolate makers when a product has been removed from the market.

What Causes Variation in Cadmium Levels in Beans?

Soil naturally differs in total cadmium levels depending on geological origin, soil formation, and erosion. Sediments can be transported over large distances by river. Contamination of soils and water through mining or certain industrial activities can also play a role. Frequent use of fertilizers with high cadmium content (phosphate) may contribute as well, although smallholder producers generally use few fertilizers because they are expensive. The amount of cadmium that can be taken up by cacao trees is more important than the total level of cadmium in the soil, because not all cadmium is bioavailable, i.e. present in a form that plants can take it up. The amount of available cadmium in the soil depends on several soil properties, such as the soil acidity and the amount of organic matter (decomposed plant materials) in the soil, but also on the type of cacao (in other words: the variety). Cacao trees in general can have a high cadmium uptake capacity, although a study by the Cacao Research Center in Trinidad has shown that different cacao varieties grown in the same location under similar soil and climate conditions accumulate cadmium in beans to a different extent.

Average cadmium levels in cacao beans from a large part of South America are higher than elsewhere, but strong variation exists between different locations. As of now, it is not possible to make reliable predictions based on the total soil cadmium content alone, although progress is being made by scientists to predict risks of high cadmium accumulation in beans based on a wider characterization of soil and plant properties. High concentrations in the leaves may indicate high bean concentrations at an early stage, but are an estimation at best. Finally, cadmium contents in beans can vary to some extent from year to year due to changing weather and soil conditions, with the genetic characteristics of the cacao tree, and with age of the plantation.

Analysis of cadmium in beans is therefore recommended after each harvest, and ideally at the plot level, until a farmer has a better understanding of the variation in bean cadmium levels between different harvests and plots. This presents farmers with additional costs, which is a huge challenge for smallholder farmers. A related issue that requires further attention is the need to invest in the capacity of laboratories in the region to reliably assess cadmium levels in beans, soil and fertilizers.

Research, both on soil management as well as on cacao varieties, has potential to create multiple improvements in bean safety, productivity, and production sustainability. So far, little information exists about technologies that remove cadmium from the beans after harvest, during fermentation, drying or further processing, although research is being developed in this field as well. An exhaustive review of the status of research on cadmium in cacao  was recently published by Bioversity International. Another issue that requires further research is good sampling protocols for the assessment of cadmium levels in exported beans, as there are indications that current sampling protocols are not adequate to make reliable estimations of cadmium concentrations in cacao batches.

Impacts

Although the EU regulation came into force in 2019, several larger South American exporters who sell directly to Europe have felt the impact on their sales much earlier. Maria del Pilar Gómez of Mariana Cocoa, exporter from Colombia, said: “sales have fallen since 2017 and we had to make large investments in order to do cadmium analysis in all the regions we buy from.” According to Gómez, there is a clear shift in the market as “higher prices are paid for cacao from areas without cadmium problems, which often also have lower quality of beans. Prices in high-cadmium areas have dropped, but buyers are asking us not to mix cacao from different areas of the country”.

Peru, leading exporter of organic cocoa and cocoa powder in South America, mainly sells to the Netherlands and Belgium. According to a source at Promperú, an promotion agency related to the Peruvian government, sales dropped in 2018 around 21% compared to the previous year. On the other hand, export to other Latin American countries and to Asia has increased. In Peru and Colombia, the uncertainty of future sales and prices also put a risk to programs that promote cacao as an alternative to the production of illicit crops such as coca, as part of a strategy to combat rural violence and drug-related conflict.

What Can Buyers and Chocolate Makers do?

To support smallholder farmers in affected regions we make the following recommendations to buyers and chocolate makers:

1. Avoid exclusion of countries or regions. There is a lot of variation of cadmium levels between different locations.
2. Understand how the beans will be used in the final product (powder or chocolate). Although the regulation does not apply to the beans but to the final product to be sold to consumers, it is important to estimate realistic safe cadmium levels in raw products. These levels may well be higher than that is currently applied as a general rule. In many cases, it is perfectly safe to use nibs with a cadmium content above 1.2 mg/kg, for example when being used in a 50-60% dark milk chocolate. CIAT developed a calculation tool that can be used to estimate the safe limit for cadmium in nibs and beans according to the type of chocolate product and the corresponding EU norm.
3. Chocolate makers can also consider changing the recipe altogether, for example by making a dark chocolate milk bar, instead of a dark chocolate (without milk). Or, when possible, mixing beans from different locations within the same country.
4. Ensure that farmers are well informed and are receiving support. Farmers need to receive support to make the required investments for lab testing and for taking adequate mitigation measures that can reduce cadmium levels in the short term.
5. Conduct or support research and cost-benefit analyses. On-farm piloting and evaluations that involve the farmers are important to develop realistic solutions for specific contexts.

To support farmers, and to safeguard the future supply of unique varieties and exquisite cacao flavors, it is important that a sector-wide approach is mapped out to reduce the impacts through strong communication and actions based on a shared responsibility. A four-year project led by the International Center for Tropical Agriculture (CIAT) in Colombia, Peru, and Ecuador will address major knowledge gaps and build capacity. The project has started in December 2019 with support from the EU and provides a platform to involve partners and relevant stakeholders in research, dissemination, and co-development of mitigation actions.

This article was modified in December 2019 to include more detail on the relationship between cadmium levels in raw beans and various transformed products such as cocoa powder.