Please see this excellent primer on child labor in cocoa policy from Tu Rinsche, who has approached child labor policy from numerous perspectives—including federal agency, corporate, and NGO. Read it here on Substack or below.

Human Rights Deep Dive: Cocoa

Why Business Must Lead on Ending Child Labor and Forced Labor in the Cocoa Supply Chain

That personal indulgence, though delightful, has a guilty taste each time I take a bite. As someone who has professionally focused on human rights and supply chain issues, I know a lot more than the average person about where commodities come from and how they are produced. And like many of us, I still indulge.

For example, I know that much of the world’s cocoa production is tainted by child labor and forced labor. Despite decades of awareness and effort, these abuses remain alarmingly widespread—especially in West Africa, home to the majority of the world’s cocoa supply.

In January 2007, I traveled to Ghana and Côte d’Ivoire to gain a deeper understanding of the complexities surrounding cocoa production. My goal was twofold: meet with government officials to explore opportunities for partnership, and visit cocoa-producing communities, farmers, traders, and civil society organizations to hear directly from those on the ground about what could be done to address the worst forms of child labor in the sector.

Tu Rinsche

A few months after that trip, I helped organize a key multistakeholder dialogue, reflecting on the insights I had gained. The meeting brought together the governments of Ghana and Côte d’Ivoire, creating a structured space to discuss gaps, share perspectives, and identify actionable steps to address child labor in the cocoa supply chain. The atmosphere was formal, like walking into a high-stakes board meeting for the first time, but by the end of the session there was a clear, shared acknowledgment of the challenge, an important milestone in building consensus among stakeholders. For anyone who has worked in public policy, achieving that kind of consensus is no small feat. This initial dialogue laid the groundwork for a follow-up event a year later, co-hosted with the Belgian government and expanding engagement to include the German and Brazilian governments, as well as representatives from other cocoa-producing nations.

I could not have undertaken this work without the relentless efforts of those who came before me and continue to fight for change today. Over the years, I have read countless reports, watched numerous documentaries, followed new initiatives, attended regular Child Labor Coalition meetings in D.C., and spoken with scores of people—all of which have shaped my understanding of what it truly takes to tackle child labor and forced labor in cocoa.

After decades of global attention, one question remains pressing: why hasn’t more progress been made? What is holding us back? Certification schemes, voluntary standards, and awareness campaigns have raised visibility, but persistent abuses show that visibility alone is not enough.

Chocolate should bring joy, not the weight of exploitation. I believe wholeheartedly that companies can make an incredible difference to eliminate child labor in the cocoa supply chain and that the business world has the influence, resources, and innovation to turn this vision into reality. The opportunity is clear. Leadership in responsible cocoa sourcing is not just good ethics, it is good business.

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What Child Labor and Forced Labor Look Like in Cocoa

According to the U.S. Department of Labor’s International Labor Affairs Bureau (ILAB) 2024 List of Goods Made with Child Labor and Forced Labor, cocoa remains deeply entangled with exploitative human rights practices. The report identifies cocoa as being:

• Produced with child labor in six countries (Cameroon, Cote d’Ivoire, Ghana, Guinea, Nigeria, and Sierra Leone)
• Produced with forced labor in two countries (Cote d’Ivoire and Nigeria)
• Produced with forced child labor in two countries (Cote d’Ivoire and Nigeria)

Beyond raw cocoa beans, the report also points to downstream products—such as chocolate, cocoa butter, cocoa paste, and cocoa powder—originating from countries where labor risks are documented. This means that businesses across the value chain, from manufacturers to retailers, face exposure to child and forced labor risks in the products they source and sell.

ILAB’s research specifically highlights that cocoa and chocolate products from Côte d’Ivoire, Ghana, and the Netherlands may contain cocoa beans produced under exploitative conditions. For companies, this underscores not only the reputational risk but also the urgent need for robust human rights due diligence to ensure their supply chains are free from labor abuses.

In 2023, the Corporate Accountability Lab reported in There Will Be No More Cocoa Here that hazardous child labor remains highly visible: young children, some as young as eleven or twelve, can be seen walking on roads in the mornings while swinging machetes. These children stand out because they are not wearing school uniforms, which is common in both countries, even as school attendance has impressively increased over the past decade.

The International Cocoa Initiative (ICI) offers a clear picture of what child labor looks like in cocoa production in a Youtube video, aligned with the International Labour Organization’s (ILO) child labor definition. Children in cocoa supply chains may be involved in hazardous tasks such as:

• Using sharp or dangerous tools like machetes and chainsaws
• Carrying heavy loads beyond safe limits for children
• Handling pesticides and unsafe agrochemicals
• Working long hours that interfere with education

While child labor is visible and measurable, forced labor is often harder to detect. It can take the form of exploitative recruitment practices, restrictions on movement, or coercion through debt bondage, withheld wages, or deception. In some cases, migrants are trapped in abusive work arrangements, with no realistic way to exit. ILAB has documented instances of both forced labor and forced child labor in cocoa production in Côte d’Ivoire and Nigeria.

For businesses, the message is clear: the cocoa supply chain remains a high-risk sector where child labor and forced labor abuses persist despite decades of attention. Addressing these risks requires moving beyond compliance checklists toward meaningful, community-centered due diligence that proactively identifies, prevents, and remediates harm.

Progress Since the Harkin-Engel Protocol

In 2001, the Harkin-Engel Protocol set an ambitious vision: eliminate the worst forms of child labor in cocoa by 2020 through a voluntary, multi-stakeholder framework. It reinforced operational tools like the International Labor Organization’s Child Labour Monitoring and Remediation Systems (CLMRS) and fostered public–private collaboration via the International Cocoa Initiative and similar multi-stakeholder efforts.

Yet more than 20 years later, the results remain sobering:

• According to the 2020 U.S. Congressional event on the impact of the Harkin-Engel Protocol, the Protocol’s 70% reduction target was never met. In some regions, hazardous child labor has remained stable—or even increased.
• A 2020 ILAB-funded University of Chicago National Opinion Research Center (NORC) study estimated that 1.56 million children were still engaged in cocoa production, a majority exposed to hazardous or dangerous tasks such as using machetes, carrying heavy loads, or working with pesticides.
• Successive industry pledges, including the World Cocoa Foundation’s 2019 Children First initiative, set ambitious elimination targets, but progress consistently fell short—prompting a shift toward a broader approach and new framework in 2024.

Since the NORC study, which remains the largest examination of child labor in the cocoa sector in Côte d’Ivoire and Ghana, the evidence continues to be clear. From NGO investigations to academic research to documentaries and global reporting, child labor and forced labor remain deeply entrenched in cocoa supply chains, globally. Recent research, reports and exposés—including The Chocolate War (2022), Corporate Accountability Lab’s There Will Be No More Cocoa Here (2023), University of Chicago Law School Cocoa Crisis (2024), and the Business & Human Rights Resource Centre’s Bitter Truth (2025)—show not only the persistence of child labor but also systemic worker exploitation, unsustainable farming models, and power imbalances across the value chain.

Still, progress has not been absent. In 2024, the governments of Ghana and Côte d’Ivoire, together with the World Cocoa Foundation and the U.S. Department of Labor, signed a new 2024–2029 Framework of Action aimed at scaling solutions. This renewed commitment provides an important opportunity to strengthen accountability and accelerate impact.

The obvious truth is that voluntary frameworks and good intentions will never be enough. What is still missing is scalable, business-driven action that addresses the root causes: low farmer incomes, opaque supply chains, weak enforcement, and insufficient worker protections. Through genuine partnership and pooling of resources, business has the leverage and innovation capacity to close these gaps. Companies that approach child labor elimination as a compliance exercise will continue to fall short, while those that embed it into business strategy, procurement models, and long-term investment in farming communities can shift the trajectory.

If we are serious about ending child labor in cocoa, business must move beyond commitments and toward genuine collective partnership with measurable outcomes. This requires shifting from annual KPIs to long-term evaluation of human rights programs, transparent reporting, adoption of living income benchmarks, strong grievance and remediation systems, and community-centered investments that tackle root causes and drive sustainability. It also calls for active investment in and support for the newly launched 2024–2029 Framework of Action, which offers a critical opportunity to align efforts and accelerate progress.

Eliminating child labor and forced labor in cocoa is not impossible.

Responsible Cocoa Sourcing: What Companies Can Do

For business leaders, the persistence of child labor in cocoa is no longer just a reputational issue but a material risk with serious regulatory, legal, and operational consequences. The EU Corporate Sustainability Due Diligence Directive (CSDDD) and the EU Forced Labor Regulation signal a new era of mandatory accountability, where companies that cannot demonstrate robust due diligence and effective remediation face legal liability, import bans, and market exclusion. The UN Guiding Principles on Business and Human Rights (UNGPs) provide the roadmap, but what is now required is disciplined execution that delivers measurable impact. Business leaders have an opportunity to align compliance obligations with value creation by embedding child labor and forced labor prevention into the core of procurement, sourcing, and risk management strategies.

Here are seven recommendations with concrete steps that companies can take:

1. Strengthen Human Rights Due Diligence (HRDD):
   • Design and implement a comprehensive human rights program that integrates all steps of due diligence across the full supply chain as outlined by the UN Guiding Principles on Business and Human Rights (UNGPs) and the OECD standards.
   • Conduct continuous, risk-based due diligence across entire supply chains, beyond tier one suppliers.
   • Integrate findings into enterprise risk management and sustainability reporting, ensuring alignment with the CSDDD and other regulatory requirements.
2. Scale Child Labor Monitoring and Remediation Systems (CLMRS):
   • Invest in child labor monitoring and remediation systems that identify at-risk children, ensure school reintegration, and provide family support.
   • Prioritize remediation over disengagement and publish transparent data to build accountability with governments, investors, and civil society.
   • Support community-led child protection committees and worker-led monitoring systems to ensure risks are identified and addressed locally.
3. Support Living Incomes and Sustainable Farming:
   • Ensure farmers can earn a living income by adopting procurement models that reward sustainable practices, guarantee fair pricing, and promote livelihood diversification beyond cocoa.
   • Develop sourcing models that directly incentivize climate-smart and ethical farming practices, while investing in tools, training, and inputs that improve productivity for smallholder farmers.
4. Embed Grievance and Remedy Mechanisms:
   • Establish trusted, confidential grievance channels for farmers, workers, and communities.
   • Ensure remediation is victim-centered, effective, and aligned with ILO standards, while integrating worker feedback loops into purchasing practices.
5. Advance Transparency and Traceability:
   • Map supply chains to the farm level and beyond tier one, using appropriate digital and verification tools.
   • Disclose sourcing practices, due diligence outcomes, and remediation progress in line with EU reporting requirements and international best practices.
6. Collaborate with Governments and Civil Society:
   • Support and align with national frameworks such as the Ghana–Côte d’Ivoire 2024–2029 Action Plan.
   • Partner with NGOs, trade unions, and civil society to design culturally appropriate interventions rooted in community priorities and are community-led.
   • Share lessons learned and support pre-competitive collaboration, recognizing that systemic issues like child labor and forced labor require joint action.
7. Implement Long-Term Monitoring, Evaluation, and Learning (MEL):
   • Develop clear indicators to measure program effectiveness, not just activity.
   • Conduct regular evaluations to assess outcomes not just inputs, close gaps, and adapt strategies based on learnings.
   • Publish better data and track progress over time through public or annual reporting to demonstrate accountability and tangible results.

The bottom line: Meeting the letter of EU laws and ILO standards is no longer optional. But those who treat compliance as the ceiling, rather than the floor, risk missing the opportunity to lead. Businesses that integrate child labor or forced labor prevention into strategy will not only stay ahead of regulation, they will build more resilient supply chains, protect brand value, and contribute to an industry where growth is not built on the backs of children.

Tools and Resources to Support Compliance and Responsible Sourcing

Preventing child and forced labor in cocoa is complex, but companies don’t have to go it alone. A range of credible global initiatives offer practical tools and guidance to help identify risks, conduct robust human rights due diligence, and implement responsible sourcing strategies. The resources below provide actionable insights that businesses can use to strengthen supply chain integrity and drive meaningful impact.

• U.S. Department of Labor (DoL) – List of Goods Produced by Child Labor or Forced Labor – Annual list identifying high-risk products and regions.
• OECD Guidelines for Multinational Enterprise and Responsible Business Conduct – The updated 2023 edition covers all key areas of business responsibility, including human rights, labour rights, environment, bribery, consumer interests, disclosure, science and technology, competition, and taxation.
• International Labour Organization: Child Labor Monitoring Resource Kit – The official ILO resource kit providing information on how to design, develop and operate child labor monitoring (CLM).
• World Cocoa Foundation (WCF): Founded in 2000, WCF is an international membership organization across six continents, representing the global cocoa and chocolate sector. The membership includes farmer cooperatives, cocoa processors, cocoa traders, chocolate manufacturers, supply chain companies and other companies worldwide.
• The International Cocoa Initiative (ICI): Founded in 2002, ICI is a multi-stakeholder initiative emerging from the Harkin-Engel Protocol that was established to work with the cocoa sector and cocoa-growing communities to address child labour and increase child protection. ICI began operating in Côte d’Ivoire and Ghana in 2007, implementing a community development approach in cocoa-growing communities.

Closing Thoughts: Collaboration is the Future of Ethical Chocolate

I don’t plan to give up my love of dark chocolate anytime soon. But I firmly believe that we, as companies, governments, and consumers, must demand better. True sweetness comes only from chocolate made free from exploitation. Some companies, like Tony’s Chocolonely, are already taking steps in that direction, but they remain the exception rather than the norm.

The Harkin-Engel era showed that public commitment and awareness alone cannot drive real change. Thanks to public funding, public-private initiatives, and the tireless work of advocates like Terry Collingsworth and many others, we now have a clearer understanding of both the scale of the problem and the pathways to meaningful progress.

My 2007 visit to cocoa farms in Ghana and Côte d’Ivoire, where I met farmers, traders, and civil society organizations, gave me a firsthand view of what I had previously only read about in reports and the media. Those experiences helped me carry the work forward, advancing multistakeholder dialogues and bringing together the governments of Ghana, Côte d’Ivoire, and other cocoa-producing countries to discuss these challenges openly and identify actionable steps. These moments demonstrated that collaboration across business, government, and civil society is not only possible but essential.

Ghana and Côte d’Ivoire now have a new plan of action, and they need our collective support. By partnering together and embedding remediation, transparency, community-led solutions, and rigorous monitoring into operations, companies can transform West African cocoa supply chains from sources of risk into engines of impact and innovation. When business steps up, we can envision a world where enjoying a Sprüngli truffle or any chocolate product brings nothing but joy, pride, and the assurance that no child paid the price for our indulgence.