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Frontiers in Environmental Economics ·

Volume 5 - 2026 | https://doi.org/10.3389/frevc.2026.1783933

Economic vulnerability of the cacao value chain to the cadmium (Cd) regulation in chocolates: a whole-chain analysis in Ecuador, Colombia, and Costa Rica

  • Guillermo Zambrano1*corresponding author
  • Karen Ramírez1
  • José Luis Vázquez1
  • Felipe Montealegre2
  • Luis Sánchez3
  • Daniel Bravo4
  • Byron Moyano1
  • Laura Ramírez3
  • Eduardo Chávez1
  • Adriana Santos1
  1. 1Escuela Superior Politécnica del Litoral, ESPOL, Facultad de Ciencias de la Vida, Campus Gustavo Galindo, Guayaquil, Ecuador
  2. 2Corporación Colombiana de Investigación Agropecuaria (AGROSAVIA), vereda Galápagos, Rionegro—Santander, Colombia
  3. 3Dirección de Investigación y Desarrollo Tecnológico, Instituto Nacional de Innovación y Transferencia en Tecnología Agropecuaria (INTA), edificio Central Ministerio de Agricultura y Ganadería (Sabana Sur) Mata Redonda, San José, Costa Rica
  4. 4Laboratory of Soil Microbiology and Calorimetry, Corporación Colombiana de Investigación Agropecuaria (AGROSAVIA), Bogotá, Colombia
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Abstract

The EU regulation on cadmium (Cd) in chocolates has posed significant trade challenges for cacao-producing countries in Latin America and the Caribbean (LAC). Elevated Cd levels have been reported in various LAC countries, threatening the export potential of cacao beans. This study analyzed the effects of this regulation on cacao commercialization in Ecuador, Colombia, and Costa Rica. The analysis began with the mapping of cacao value chains and the collection of stakeholder perceptions regarding the impacts of the regulation. Following this, the study assessed the volume of cacao exports at risk based on secondary data regarding Cd concentrations and export statistics. Finally, the Business Model Canvas tool was employed with exporting associations and companies in Ecuador to evaluate the impacts on actors involved in specialty cacao commercialization. The findings revealed that the most significant impacts were absorbed by direct trade, i.e., bean to bar. The analysis estimated that without mitigation measures, Ecuador was at risk of losing USD 280 million in annual exports, followed by Colombia with USD 80 million and Costa Rica with USD 2 million. This study identified the most affected actors and countries due to the EU regulation and emphasized the necessity for innovative strategies to overcome this non-tariff barrier for producing countries.

Keywords

1 Introduction

Cacao is a key raw material for chocolate manufacturing, and its production is crucial for the economies of many Latin American and Caribbean (LAC) countries, such as Ecuador, Colombia, and Costa Rica. Originating from the Neotropics of South America (Lanaud et al., 2024), cacao production involves more than 255,000 producers across Ecuador, Colombia, and Costa Rica (Avadí et al., 2021; MADR, 2021; MAG Costa Rica, 2021). Despite recent increases in cacao prices, which have raised the cost of chocolate and related products, global demand has shown only moderate declines, rather than abrupt contractions (ICCO, 2025). International chocolate consumption has been sustained in part by the continued recognition of cacao-based products as sources of health benefits, reinforcing the economic relevance of the cacao sector (Voora et al., 2019; Dimeji et al., 2025). This sustained demand has contributed to the strengthening of food safety regulations, which may act as non-tariff trade measures, especially in high-value consumer markets such as the European Union (EU) and the United States (Grundke and Moser, 2019; Vanderschueren and Pulleman, 2021; Letort et al., 2025).

Countries establish different regulations to protect their products, the environment, and ultimately, consumer health. To this end, the use of non-tariff barriers, such as phytosanitary or food safety requirements, has increased (Krugman and Obstfeld, 2006; Grundke and Moser, 2019). The European Food Safety Authority (EFSA), in 2009, identified Cd exposure as mainly toxic to the human kidney, bones, and liver (Himeno and Aoshima, 2019) and established a tolerable weekly intake of 2.5 mg of Cd per kg of body weight. Later, a group of experts concluded that it was necessary to reduce Cd exposure in the European population. Considering this opinion and the scientific report of the (EFSA 2012), maximum Cd levels were established for chocolate and ready-for-sale cacao. These maximum levels became a non-tariff barrier for cacao products (European Commission, 2014). The impact of these non-tariff barriers, such as the EU Cd regulations, has been a growing area of research, particularly regarding their economic implications and the development of agricultural countermeasures to mitigate their effects on export markets (Elisabeth and Verico, 2022; Hwang and Lim, 2017; Jaimes et al., 2011; Jouanjean et al., 2016; Madiyarova and Terletskiy, 2022; Mendes and Luchine, 2020; Soon and Thompson, 2020; Villacis et al., 2022a).

For many cacao producers in LAC countries, the EU regulation has become a pressing trade concern. Recent studies have shown that more than 50% of cacao beans in some regions exceed EU Cd limits, threatening exports to key markets (Vanderschueren et al., 2021). The European market is particularly important for the export of fine-flavor cacao, which plays a key role in cacao sustainability (ICCO, 2023). Despite the challenges posed by the Cd regulation, exports from these countries to the EU have continued to increase in value over the past decade (ITC, 2023a,b,c). However, internal market disruptions have appeared with producers facing higher operating costs due to Cd analyses, logistics for sourcing lower-Cd beans, and limited access to premium markets in high-Cd areas (Argüello et al., 2019; Ramírez et al., 2022; Charry et al., 2023). Other regulations imposed by the EU, such as the pesticide regulation (EU 396/2005), the so-called due diligence (EU 2024/1760), or deforestation-free products (EU 2023/1115), have generated diverse impacts in Global South countries, including a potential reduction in cacao exports in the coming years (Tijani and Masuku, 2020), increased production costs for business models to adapt to regulations (Akande et al., 2023), and even a potential inability to sell products in this market due to deforestation (Conte et al., 2024). Nevertheless, despite the initial costs, those who successfully comply with the regulations can access high-value markets with quality products (Santeramo and Lamonaca, 2019).

The blending of cacao beans from different regions with varying Cd concentrations has been identified as a temporary strategy to reduce Cd levels in exported cacao products (Vanderschueren et al., 2021). While this practice offers a short-term solution, it does not address the underlying issue faced by producers in regions with consistently high Cd levels. In Ecuador, for example, a transition away from cacao production in high-Cd areas could result in significant economic losses, potentially as high as USD 750 million (Vázquez-deCastro et al., 2023). Moreover, a considerable portion of the cacao exports from Ecuador, Colombia, and Costa Rica is increasingly vulnerable to regulatory pressures, as compliance with the EU Cd limits remains a major challenge. Given these risks, this study aims to quantify the volume of exports threatened by Cd contamination and assess the broader economic consequences for cacao value chains in these countries. By employing value chain mapping, conducting interviews with key stakeholders, and analyzing business models, this research provides a detailed assessment of the economic risks associated with cacao production in high-Cd regions. Additionally, this study is the first to assess the operational costs associated with complying with EU regulations at the exporter level. The findings can be used to inform policies that offset the economic burden of Cd regulations within cacao value chains in the studied countries, particularly to protect the wellbeing of small-scale farmers, who are the most vulnerable actors in these value chains.

2 Study context: cacao production and exports in Ecuador, Colombia, and Costa Rica

2.1 Ecuador

Ecuador has had a strong orientation toward the production and export of raw cacao beans since the 19th century, historically making it one of the country's main economic activities attracting foreign exchange and contributing to national development (Acosta, 2012; Abad et al., 2020; Villacis et al., 2022b). Cacao is the most planted crop in the country with more than 500,000 ha (hectares) representing 41.3% of agricultural land (INEC, 2023). The planted area of this crop has had a growing trend during the last 10 years, from 390,176 ha in 2012 to 509,179 ha in 2022. It is estimated that there are approximately 189,000 cacao production units in Ecuador (Avadí et al., 2021). Similar to the planted area, overall production has raised from 133,323 Mg (megagrams) in 2012 to 337,149 Mg in 2022. Average yields in 2012 were recorded at 0.34 Mg ha−1 and rose to 0.66 Mg ha−1 by 2022 (MAG Ecuador, 2023). Cacao is one of the top 5 agricultural products exported in Ecuador (MAG Ecuador, 2022).

The two most grown cacao varieties in Ecuador are CCN51 and the Nacional group, with a cluster of cultivars. At the international level, Nacional cultivars, with high aroma and flavor characteristics, is widely used for the production of gourmet chocolates (Quingaísa, 2007; ICCO, 2023). In particular, the Cacao Arriba denomination of origin for the country's fine flavor cacao is an opportunity to boost exports. Ecuador is the world's leading producer of fine flavor cacao, with a market share of over 60% (Bianchi, 2020). About 98% of Ecuador's cacao production is exported (Arvelo et al., 2016), mainly as whole or broken, raw or roasted, cacao beans generating around USD 915 million (ITC, 2023f). Over the last 10 years, exports to EU member countries (27 countries) have increased from USD 120 million in 2012 to USD 261 million in 2022, representing 24.63% of total exports of item 18 (Table 1) (ITC, 2023c).

Table 1. Cacao and derivative exports from Ecuador, Colombia, and Costa Rica (2012–2022).

YearsEcuadorColombiaCosta Rica
Exports to the EU (27)Exports to other marketsExports to the EU (27)Exports to other marketsExports to the EU (27)Exports to other markets
2012120,724332,5285,48967,8323508,459
2013151,696379,47311,19280,5576959,205
2014189,207520,94420,328125,5969459,281
2015235,530576,85227,292101,65243210,331
2016204,510545,52030,791105,86457411,318
2017192,889479,53721,11991,1415749,957
2018204,599583,32717,31691,07565010,403
2019215,502548,39515,80089,9188299,642
2020216,893718,13120,20289,7118369,109
2021265,915674,12919,214106,09280211,575
2022261,807801,07011,015120,09697814,495

Values expressed in thousands of USD. Exports to the EU and other destinations. Source: (ITC 2023a,b,c).

2.2 Colombia

The crop has gained strategic importance, given that, since the signing of the peace treaties, the Government established the Comprehensive National Program for the Substitution of Illicitly Used Crops, which has promoted the substitution of illegal crops for oil palm, coffee, or cacao (Zamora and Ochoa, 2020). According to the Ministry of Agriculture and Rural Development (MADR), Colombia has an estimated 65,341 cacao producing families, distributed in 422 municipalities in 27 departments. Likewise, it is estimated that an average producer cultivates 3 ha of cacao in the country (MADR, 2021). The cacao sector generates approximately 167,000 direct and indirect jobs in the country (FEDECACAO, 2021).

In 2010, the growth rate of the planted area was 9%, because domestic prices were very close to international prices, which motivated many farmers to produce cacao (FEDECACAO, 2021). By 2020, production increased by 3,676 Mg, which is a historical level for the country. This increase in production was because favorable climatic conditions throughout the year (FEDECACAO, 2021). The planted area in 2020 was 189,185 ha, with a production of 63,416 Mg of cacao and an average yield of 0.34 Mg ha−1 (MADR, 2021).

The internal market of chocolate is considered strong, given the good prices and high consumption of chocolate and its derivatives (FEDECACAO, 2021). On average, 82%, of the national production is consumed by domestic demand and only 18% is exported (MADR, 2021). The designated locations for both cacao raw-material and other exports have changed between 2009-−2020 (MADR, 2021). In 2022, chocolate and cacao-based products, generated around USD 85 million (64.9% of the total exports), and cacao beans, whole or broken, raw or roasted added USD 15 million (11.9%) (ITC, 2023d). Overall, in 2022 the member countries of the EU imported around 8.40% of cacao and cacao preparations, generating exports of approximately USD 11 million, also it is highlighted in Table 1 (ITC, 2023a).

2.3 Costa Rica

Cacao production in Costa Rica was one of the main economic activities between the 50's and 80's when it was strongly affected by Monilia (Moniliophtora roreri), which devastated most commercial plantations. However, in recent years, cacao has started to positioning as an agricultural activity with great potential for inclusive and sustainable business development (Comisión Interinstitucional de Cacao, 2018). One of the main advantages of the cacao production is the possibility of integrating into agroforestry management, in addition, it represents an opportunity for the incorporation of smallholders and agro-entrepreneurs into high-value chains (Ulloa, 2019).

By 2020, Costa Rica registered 2,409 ha and 1,422 active producers, with 99.2% being small-scale with less than 15 ha (MAG Costa Rica, 2021). These smallholder farmers are located in areas with limited access, with traditional agroforestry systems and significant use of family labor (González, 2017). In addition, 100% of cacao is considered fine flavor according to the International Cocoa Organization (ICCO, 2016).

In 2022, 6.32% of exports were destined for member countries of the EU (ITC, 2023b). The main form of export was chocolate and other food preparations containing cacao, generating around USD 13 million (90.3% of the total exports), followed by cacao beans, whole or broken, raw or roasted (USD 1 million) (6.77%) (ITC, 2023e).

3 Materials and methods

3.1 Assessment of Cd regulation impact on value chains and stakeholders

To determine the perceptions of the impact of Cd regulation on different stakeholders, the value chains in each of the studied countries were first updated and presented in sketches. To this end, the Value Links methodology developed by (Springer-heinze 2017) was used. This methodology provides an overview of a productive system, identifying the stages, functions, and interactions between actors, allowing in-depth analysis and graphical representation of the economic complexity and diversity of the value chains in the three countries. Value chains were explained in three levels: micro, meso, and macro. The micro level shows the different actors that have a direct relationship with production processes, productive transformation, and commercialization with final product markets. These operators may become product owners along the chain. In this process, operators acquire raw materials, carry out the production process, and pass the semi-finished and final products to consumers in the final markets. At the meso level, the actors that provide support services to the direct operators in the chain are described. At the macro level, actors related to government or public units that organize regulatory frameworks and dictate policies are included. The value chains sketches were edited using the virtual software (Miro, 2023).

In this study, exports at risk are defined as the volume of cacao production that, at the territorial unit of analysis, exceeds the threshold commonly used for commercialization and export to the EU, thereby potentially restricting access to that market. To implement this assessment, average Cd concentrations were first estimated for each of the cacao producing countries and regions under study. These estimates were calculated using a combination of cacao-bean content maps and overall cacao production statistics, with slight methodological variations depending on data availability and sources for each country. It was assumed that the entire cacao production of the countries under study is subject to Cd thresholds, as a more detailed analysis could not be performed due to the limited traceability of cacao, which makes it difficult to determine the destination of cacao exports from each province or department. The next step was to estimate the volume of exports at risk for each country. For the countries considered in this study, a threshold of 0.60 mg kg−1 was used to determine whether the average Cd concentration weighted by plantation area could affect trade. This threshold reflects sourcing requirements commonly applied by exporters purchasing Latin American cacao for high percentage dark chocolate (>70%) destined for the EU market. During processing, Cd concentrations approximately double in cocoa powder due to the separation of cocoa butter. Using the CHOCO SAFE tool (Alliance Bioversity CIAT, 2026), a bean concentration of 0.60 mg kg−1 corresponds to a safe level for producing chocolate with approximately 80% cocoa content. In addition, the viability of the physical mixing strategy was evaluated as a potential mitigation measure to reduce the impact on exports. The results are presented in a table, containing production levels and export values at risk for each country.

Finally, the effects of the EU regulation on business models were analyzed at the associations and cacao export levels. This study focused solely on the Ecuadorian value chain due to its larger export volumes to the EU and its greater expected vulnerability relative to the other two countries. For this purpose, some of the variables in the Business Model Canvas were used. This tool describes the dynamics of how an organization creates, organizes and captures value (Osterwalder and Pigneur, 2010). This framework is divided into 4 areas and 9 components, which analyze the value proposition offered by the business, interactions with customers and key partners and the resources to generate production (Lundy et al., 2014).

3.2 Data collection and analysis

Cacao value chains were initially mapped based on a search of secondary sources (literature review) of peer-reviewed (published Q1-Q3 papers) and official (governmental) sources. For Ecuador, the initial analysis was based on the studies of the (Vicepresidency of the Republic of Ecuador 2015), (Guilcapi 2018), (Sánchez et al. 2019), (Moreno et al. 2020), (Avadí et al. 2021), and (MAG 2017), (MAG 2019b), (MAG 2019a), (MAG 2021). For Colombia, the value chain studies taken as an initial reference were developed by (Zamora and Ochoa 2020); (MADR 2017, 2018, 2021); (Jaimes et al. 2021); (Montealegre Bustos et al. 2021). Finally, for Costa Rica, the characterization of cacao value chain was prepared based on the studies of (Nadurille 2010), (IICA 2016), and (Comisión Interinstitucional de Cacao 2018).

For the validation of the value chains and the identification of impact perceptions through primary data, semi-structured interviews were conducted with key informants from the value chains in each country. The questionnaire was prepared based on the guide to value chain mapping (Lundy et al., 2014). The form was developed and adapted to each of the interviewee's profiles which included 1) public policy decision-makers (questionnaire S1) and 2) technicians or experts in the value chain at the national level (questionnaire S2). Participants were drawn from research centers (n = 7), governmental agencies (n = 11), NGOs and international cooperation agencies (n = 6), private companies (n = 16), producer organizations (n = 14), and exporter associations (n = 5) (Supplementary Tables 1–3). The questions oriented to gather the perceived impact were aimed at determining the relevance of the European market for cacao exports and its derivatives, impacts and challenges that have been generated for cacao trade after the onset of the regulation. Due attention was paid to price variation, farmers/exporters income, and mitigation strategies that could reduce the problem.

Given the limited availability of experts and technicians, participants were selected using a non-probabilistic sampling strategy combining snowball and convenience approaches. The number of interviews was determined based on theoretical saturation, reached when additional interviews did not provide substantially new information and the value chain diagrams remained stable across respondents (Flick, 2009). During this process, value chain structures were iteratively validated and refined through comparison of responses among participants. The interviews were carried out during 2021, 2 years after the implementation of the EU regulation. The number of interviewees were 16, 33 and 12, in Ecuador, Colombia and Costa Rica, respectively. The interviews were conducted via online or in person depending on the restrictions during COVID-19 pandemic. Informed consent was obtained prior to the participants' involvement in the interview.

To estimate the volume of cacao exports at risk from regulation, two steps were followed. For the first step, maps showing Cd concentration in cacao beans by country were selected. In the case of Ecuador, data from the national agricultural land use map (SIPA, 2016) were combined with a spatial distribution map of Cd in cacao beans (Argüello et al., 2019). Specifically, all geographic sectors that were identified as cacao plantations from the satellite data were singled out and the Cd distribution map was used to obtain the expected Cd level for each of their centroid coordinates. Assuming that each sector had the same Cd level as its centroid, these values were used to calculate an average for each province weighted by plantation area. In Colombia, a national map of Cd content in cacao beans reported in (Bravo et al. 2024) was used. In Costa Rica, a survey conducted by (Carrillo et al. 2023) was used.

The second step consisted of determining the affected areas by combining the data on average Cd levels in cacao beans, obtained in step 1, with agricultural production statistics from official sources in each country. For Ecuador, the national agricultural production survey was used (INEC, 2020), for Colombia the information on production and area of cacao plantations (MADR, 2021) and for Costa Rica the Census of cacao 2020–2021 (MAG Costa Rica, 2021). Data on cacao exports for 2020 were obtained from the Trade Map tool (ITC, 2023a,b,c).

The identification of the effects of the EU regulation on business models was carried out in 4 associations and 2 cacao export companies in Ecuador through interviews. These organizations were selected based on value chain mapping interviews, in which participants identified the main organizations in both the Coastal and Amazon regions whose commercial operations had been affected by the implementation of the regulation. The data collection was carried out through virtual semi-structured interviews with managers of these organizations. The form was structured in three sections: 1) Characterization of the organization's business model, 2) Impacts caused by the regulation and 3) Mitigation practices implemented (Supplementary Table 3).

To improve consistency across cases, the same interview structure was applied to all organizations and responses were contrasted during the analysis. Due to confidentiality policies, organizations did not disclose absolute cost figures; therefore, the impact of the regulation on operational costs was assessed using relative changes (percentage variations) reported by respondents and qualitatively contrasted with the operational adjustments described during the interviews. For this purpose, respondents first identified the cost components affected by the regulation (e.g., laboratory analysis costs and participation in research projects) and subsequently assigned a percentage value relative to their total operational costs. A limitation of the study is that, in most organizations, it was not possible to obtain information on the unit sale price of cacao or detailed production costs due to the confidentiality of business models and security protocols followed by some actors. This limited the possibility of estimating the total economic impact of the regulation on business models. The consistency of the reported cost increases was further reviewed by members of the research team with expertise in Cd laboratory analysis to assess their technical plausibility. The results are presented in a table that describes the three sections. The names of the associations or companies are not disclosed because of potential commercial barriers.

4 Findings and discussion

4.1 Description of the cacao value chains in Ecuador, Colombia, and Costa Rica and the perceived impact of EU regulation.

Based on interviews with key stakeholders, it was determined that the cacao value chains in Ecuador, Colombia, and Costa Rica share a similar structure across three levels: micro, meso, and macro. This similarity in the value chains has been shaped by the historical interactions between the region and markets in the United States and Europe, reinforcing a tendency toward agro-exporting cacao to these markets (Sánchez et al., 2019; Santiago et al., 2020). As evidenced by export data from the countries in this study (ITC, 2023d,e,f), in Ecuador, exports have primarily focused on cacao beans, while in Colombia and Costa Rica, exports of chocolate and other cacao derivatives have strengthened. This dynamic has influenced the different target markets for the processing and export segments between the countries. All countries share similarities in cacao production, which is primarily carried out on smallholder farms (less than 20 ha).

In Ecuador (Supplementary Figure 1), at the micro level, smallholder farmers represent 85% of the producers. These smallholders primarily cultivate the CCN51 variety, which covers 72% of the planted area. Around 98% of the production follows conventional farming practices. Most smallholders sell their cacao beans to intermediaries who manage 82% of the cacao production, concentrated in urban centers like Guayaquil, Duran, Quito, and Cuenca. At the meso level, the value chain is supported by input suppliers, financial institutions, and research centers that provide technical assistance and resources. At the macro level, The Agency for Quality Control of Agriproducts (AGROCALIDAD) plays a critical role in ensuring traceability and quality control. The Ministry of Agriculture and Livestock (MAG) also oversees the sector, ensuring that it complies with the EU Cd regulation. The regulation has increased costs for exporters due to required testing and mitigation measures, and regions with higher Cd levels face difficulties accessing premium markets.

In Colombia (Supplementary Figure 2), smallholders make up 95% of cacao producers, with an average farm size of 3 ha. While these smallholders sell their cacao to intermediaries and large processors like Casa Luker and Nacional de Chocolate (CNCH), they face limited market influence. The meso level includes input suppliers, transporters, and other service providers, while the National Cocoa Council coordinates the sector at the macro level. Although Colombia exports a much smaller portion of its cacao compared to Ecuador, concerns about the future impact of the EU Cd regulation are growing as production expands.

In Costa Rica (Supplementary Figure 3), the value chain is focused on fine-flavor cacao, with 99.1% of production coming from smallholders with less than 15 ha. 44.3% of these producers use conventional farming practices, but the value chain is dominated by intermediaries and processors who handle post-harvest processes. At the meso level, the value chain is supported by input suppliers and the State Phytosanitary Service, while the macro level involves the Ministry of Agriculture and Livestock, working with international organizations to maintain export standards. Costa Rica primarily exports to the United States, but exporters are aware of the EU Cd regulation and have implemented mitigation strategies, e.g., cacao mixing.

Across all three countries, the impact of the EU Cd regulation has not led to widespread rejections of cacao shipments, but concerns persist, particularly for exporters targeting high-value European markets. The actors most knowledgeable about the regulation include exporters, technical experts, and organizations involved in certification and quality control. These actors have been directly affected by the need for Cd testing and mitigation strategies, as they are responsible for ensuring compliance with international standards.

In Ecuador, the concern has focused on specialty cacao for niche markets, where stricter quality and safety requirements apply. Producers linked to niche markets in high-Cd areas have faced challenges, as companies have redirected their sourcing to lower-Cd regions. This has forced farmers in high-Cd areas to sell their cacao in standard markets, increasing economic pressure. Exporters have also incurred higher costs due to Cd testing and mitigation measures to meet the requirements of European buyers.

In Colombia, approximately 85% of cacao production is consumed locally, which has limited the immediate impact of the regulation. However, as exports to Europe increase, exporters and technical experts are increasingly aware of the potential risks and costs associated with compliance. In Costa Rica, where all cacao is classified as fine-flavor, exporters and processors have adopted cacao mixing strategies to reduce Cd levels, though concerns persist about the potential impact on the premium prices traditionally associated with fine-flavor cacao. Overall, rising costs related to compliance with the Cd regulation have particularly affected producers in high-Cd regions, threatening their market access and profitability.

Non-tariff regulations from the EU have influenced agricultural practices, production costs, and business models in the Global South. In the case of the European pesticide regulation (EU 396/2005), it was shown that countries like Côte d'Ivoire and Ghana were negatively impacted in their cacao exports to the EU, leaving small producers particularly vulnerable, as they have limited access to mitigation technologies and the adoption of good agricultural practices (Tijani and Masuku, 2020). In contrast, in Nigeria, evidence was found that, despite the initial costs of adapting to EU regulations, actors who complied with the regulations by adopting better production practices gained access to a high-value market (Akande et al., 2023; Tijani and Kehinde, 2026).

One of the main risks faced by smallholder producers regarding the Cd regulation is the varying levels of costs associated with mitigation solutions (Meter et al., 2019). Some of the mitigation alternatives currently being researched, such as the use of lime or biochar (Ramtahal et al., 2022; Wiersma et al., 2025), selecting varieties that transfer less Cd to the beans (Engbersen et al., 2019; Villegas et al., 2024), or even switching to different crops in extreme cases of very high Cd concentrations (Vázquez-deCastro et al., 2023), involve high costs and require significant efforts at the farm level. Smallholder farmers may struggle to implement these solutions due to their limited financial resources and lack of access to low-interest and long-term financing schemes. For this reason, the dissemination of mitigation alternatives should include the evaluation of public policies that facilitate access to these technologies. Additional efforts must also be made in all three countries to raise awareness about the scope of the regulation and its impact, particularly at the production level.

4.2 Vulnerability of cacao exports from Ecuador, Colombia, and Costa Rica to EU Cd regulation

The vulnerability of cacao exports to the EU Cd regulation was country dependent and was driven by differences in Cd levels in cacao beans, the size of export volumes, and the capacity for implementing mitigation measures.

In Ecuador, the average Cd concentration weighted by plantation area is 0.58 mg kg−1, just below the EU threshold of 0.6 mg kg−1 (Table 2). However, the feasibility of using cacao mixing strategies to lower Cd levels is limited by geographical constraints. While ten provinces in Ecuador have Cd levels below the threshold, others, such as El Oro, Orellana, and Sucumbíos, exceed 1 mg kg−1, making mixing potentially not feasible in these regions. As a result, other mitigation strategies, including soil mapping and selective sourcing, are necessary to maintain market access. If no measures are implemented, approximately 30% of Ecuador's cacao plantations are at risk of exceeding the Cd limit and could result in significant export losses, estimated at USD 280 million annually (Table 5).

Table 2. Cacao production and average Cd concentration by province in Ecuador.

ProvincesProduction (Mg)Average Cd level in beans (mg kg−1) (Standard deviation)
Los Ríos93,0080.49 (0.18)
Guayas91,3850.58 (0.29)
Manabí45,1950.45 (0.18)
Esmeraldas30,5040.56 (0.23)
Santo Domingo16,6990.46 (0.05)
El Oro*2,9201.41 (0.37)
Santa Elena2620.55 (0.07)
Bolívar*16,0440.70 (0.11)
Pichincha5,8790.30 (0.09)
Cotopaxi3,1940.49 (0.05)
Chimborazo8210.51 (0.05)
Cañar*7420.83 (0.17)
Azuay*6100.65 (0.20)
Imbabura4470.26 (0.12)
Orellana*11,6811.11 (0.31)
Sucumbíos*5,9091.02 (0.45)
Napo*1,4840.80 (0.43)
Morona Santiago*8130.62 (0.07)
Zamora Chinchipe*2850.78 (0.16)
Pastaza*210.73 (0.25)
ThresholdTotal productionWeighted average of Cd
* Cd > 0.6 mg kg−1327,9030.58

* indicates that the corresponding departments have Cd levels greater than 0.6 mg kg−1. Source: (Argüello et al. 2019).

In Colombia, the average Cd level in cacao beans is 2.39 mg kg−1, which is significantly higher than the EU threshold (Table 3). This poses a major challenge for cacao producers, especially in departments such as Antioquia, Arauca, Meta, Nariño, Norte de Santander, Santander and Tolima, where Cd levels exceed 0.6 mg kg−1. Assuming that all cacao exports were destined for the EU, an assumption that introduces a strong bias due to high internal consumption, Table 5 presents a worst-case export scenario for the country. The most commonly used strategy for chocolate manufacturing is blending, as less than 1% of cacao farms in Colombia export directly, which helps mitigate the real impact of Cd regulation on producers.

Table 3. Cacao production and average Cd concentration by department in Colombia.

DepartmentsProduction (Mg)Average Cd level in beans (mg kg−1) (standard deviation)
Antioquia *5,2001.69 (1.4)
Arauca *9,6953.81 (1.6)
Meta*2,3050.84 (1)
Nariño*3,8740.66 (0.3)
Norte de Santander*9751.74 (1.9)
Santander*20,6032.71 (3.5)
Tolima *3,4511.47 (1.7)
ThresholdTotal productionWeighted average of Cd
* Cd > 0.6 mg kg−146,1032.39

* indicates that the corresponding departments have Cd levels greater than 0.6 mg kg−1. Source: (Bravo et al. 2024).

In Costa Rica, Cd contamination in cacao-producing areas is less widespread compared to Ecuador or Colombia. In addition, Costa Rica is a minor cacao producer, which alleviates the impact of Cd on the current value chain. The weighted average Cd level in cacao is 0.50 mg kg−1 (Table 4) just below the selected threshold. However, 24% of cacao-growing areas exceed the limit, putting approximately USD 2 million in exports at risk annually (Table 5). According to interviews with stakeholders, there is optimism regarding the viability of mixing due to the small size and proximity of production areas within the country. Stakeholders believe that this geographical advantage makes the mixing process more feasible compared to other countries. However, they also expressed concerns about maintaining the premium quality of fine-flavor cacao, as implementing the mixing could potentially compromise the distinctive characteristics, which are crucial for accessing high-value markets.

Table 4. Cacao production and average Cd concentration by municipality in Costa Rica.

MunicipalityProduction (Mg)Average Cd level in beans (mg kg−1) (standard deviation)
Buenos Aires6.940.12 (0.10)
Corredores*49.302.13 (3.51)
Coto Brus18.720.07 (0.04)
Golfito*25.521.01 (1.01)
Guácimo10.720.22 (0.03)
Guatuso*135.590.70 (0.66)
Limón*200.180.61 (0.79)
Los Chiles23.430.36 (0.32)
Matina119.720.55 (0.17)
Osa*60.281.12 (0.00)
Pérez Zeledón18.960.05 (0.04)
Pococí108.810.48 (0.53)
San Carlos*98.230.71 (0.69)
Sarapiquí25.790.19 (0.18)
Siquirres*74.380.64 (1.04)
Talamanca357.340.47 (0.45)
Upala486.270.51 (0.34)
ThresholdTotal productionWeighted average of Cd
* Cd > 0.6 mg kg−11,820.180.50

* indicates that the corresponding departments have Cd levels greater than 0.6 mg kg−1. Source: (Carrillo et al. 2023).

Table 5. Potential cacao exports at risk in Ecuador, Colombia, and Costa Rica due to the EU Cd regulation.

CountryCd level (mg kg−1)Cultivation area (ha)%Production of dry cacao beans (Mg)Value of exports (in thousands of USD)
EcuadorTotal590,579100.00327,902.56935,024
Cd > 0.6176,87829.9598,206.82280,040
ColombiaTotal189,185100.0063,048.00109,913
Cd > 0.6137,31472.5845,761.4179,777
Costa RicaTotal2,863100.00652.009,945
Cd > 0.667723.65154.202,352

Since the implementation of the Cd regulation, exports from LAC countries to the EU have not decreased (Charry et al., 2023). Even during the COVID-19 pandemic, which disrupted the value chains of several agricultural products worldwide and halted the growth of many exports from countries like Ecuador, cacao exports remained stable, considering the increasing global demand for chocolate and other cacao derivatives (Zambrano et al., 2024). Evidence suggests that the impact of the regulation has primarily affected business models offering specialty cacao and specific regions with high contamination levels. However, the potential impacts of Cd contamination in cacao are increasing, as other markets, beyond the EU, may implement similar measures to protect consumers from Cd exposure, as seen in California, USA. Despite the limitations of the study, the findings can be used to anticipate the possible effects of future Cd regulations on cacao exports from LAC countries.

4.3 Direct impacts of Cd regulation on business models of farmers' associations and exporters in Ecuador

The EU regulation on Cd has been regarded as a non-tariff barrier limiting access to one of the most attractive markets for cacao. To date, no cacao rejections have been reported. Six business models (labeled as A, B, C, D, E, and F) were analyzed and are summarized in Table 6. Among the most vulnerable models are Model A, located in the coastal region, which exports 75% of its production to Switzerland and Germany, and Model F, based in the Amazon, where 90% of its sales are trade in the EU. Both models face significant risks due to their high dependence on the European market, making them particularly exposed to Cd regulation.

Table 6. Evaluation of potential impacts of Cd regulation on business models in Ecuador.

VariablesModel AModel BModel CModel DModel EModel F
Type of actorFarmers' AssociationFamily businessFarmers' AssociationFarmers' AssociationNon-profit Organization (NGO)Farmers' Association
ProvincesManabí (Coast)Esmeraldas (Coast)Napo, Orellana, Sucumbíos (Amazon)Esmeraldas (Coast)Guayas, Manabí, Esmeraldas, El Oro, Napo, Bolívar (Coast—Andes)Zamora Chinchipe, Morona Santiago (Amazon)
Main marketsSwitzerland (60%), Germany (15%), Ecuador (15%), USA (10%)USA, China, EU (< 5%)Sells to a local company that exports to USA, Malaysia, and EUEU (50%), USA (30%), UK (10%), Ecuador (10%)Cacao beans: EU (< 10%), Semi-processed and elaborated cocoa products: EcuadorCacao beans: EU (90%), North America, Ecuador
Avg. volume (Mg)550100362160350023
Cacao varietyNacionalNacional, CCN51Nacional, Súper ÁrbolNacionalNacional, CCN51Nacional, CCN51, Sacha Gold
Impact of Cd regulation↑ 5% increase in costs (mixing strategy, Cd analysis)↑↑↑ 13% increase in costs (research participation, Cd analysis), Loss of European buyer (USD 300,000-400,000)↑↑ Loss of EU traders, limited premium sales↑ 1% increase in operating costs, Difficulty accessing new EU buyers, cash flow problems↑↑ USD 300 per ton spent on analysis for premium customers, 5–7% decrease in prices paid to producers (seen as negative due to social objectives)↑↑↑ 90% reliance on the EU market, risk of contract termination if Cd levels are high
Actions implementedMapping of Cd-affected zones, redirection of technical staff, mixing strategy, partnerships with research institutionsInput analysis, diversification into non-EU markets, ongoing research projectsParticipation in international cooperation projects seeking mitigation alternativesPhysical mixtures of cacao lots from legal partners and associations with low Cd areas, participation in research projects, farm mapping, and promoting sustainable practices to mitigate CdInvestments in soil mapping, Cd mitigation inputs, and strategic redirection of high Cd batchesDetailed monitoring of Cd levels, mixing strategy, participation in Cd mitigation projects, exploration of non-EU markets, and renegotiation of contracts

Arrows express the impact of Cd regulation on the parameter. Arrow pointing upwards means negative whereas downwards the opposite.

Models A and D, both operated by farmers' associations, have seen modest increases in operating costs due to the need for Cd testing and mitigation strategies. Model A has experienced a 5% increase in costs related to testing and blending cacao from different regions to meet EU standards. In contrast, Model B has been significantly impacted, with a 13% increase in costs due to its participation in Cd mitigation research projects and the need to analyze inputs used on farms. Furthermore, Model B lost a major long-term commercial relationship with a European buyer, expected to generate between 300,000 USD and 400,000 USD in revenue, as high Cd levels were detected in its cacao, forcing the company to redirect its operations to non-European markets. Similarly, Model E has reported a 5% to 7% decrease in prices paid to producers due to elevated Cd concentrations, pushing the company to trade in less profitable markets.

The mixing of cacao from different regions has been used by several models, including Model F, as a strategy to reduce Cd levels and meet EU requirements. However, for Model F, this approach has compromised its unique origin designation, which is crucial to its business model. In response to these challenges, some businesses have engaged in research projects with universities and international agencies to explore more sustainable mitigation solutions. Mixing appears to be the quickest and cost-effective solution thus far; however, the new EU Deforestation Regulation (European Parliament and Council of the European Union, 2023) may limit the applicability of this strategy due to stricter traceability requirements. Previous evidence indicates that cacao mixing has been one of the first mitigation responses adopted by exporting companies and producer associations in the Andean region (Charry et al., 2023); however, further research should evaluate the feasibility of this strategy for smaller producer organizations and independent farmers, for whom implementation may be constrained by smaller production scale and limited infrastructure and technical capacity.

Several researchers consider non-tariff barriers as limitations but also as opportunities for the business models of developing countries. While these barriers may impose high compliance costs with standards, they also facilitate improvements in product quality and access to high-value markets (Santeramo and Lamonaca, 2019; Oberlack et al., 2023). Global regulations and standards on agricultural value chains can promote the adoption of sustainable practices (Wollni et al., 2025; Romano et al., 2026). It is crucial that environmental regulations do not compromise poverty eradication efforts in Global South countries, particularly in rural areas (Giger and Musselli, 2023). Consequently, it is essential to achieve a balance between non-tariff regulations and their potential impacts on the livelihoods of small-scale producers and vulnerable business models, by articulating economic resources from destination markets that can help mitigate these challenges. Likewise, coordination with local governments and their regulatory frameworks is essential to facilitate the implementation of destination market standards (De Oliveira et al., 2024; Ingram et al., 2025; McDermott et al., 2025; Solar et al., 2025).

Worldwide, cacao value chains will likely face an increasing number of non-tariff barriers imposed by the EU, aimed at promoting sustainable production. The regulations on due diligence (EU 2024/1760) and deforestation-free products (EU 2023/1115) will entail additional commitments that may heighten the vulnerability of cacao exports, particularly where compliance with such regulations proves challenging (Conte et al., 2024; Felbermayr et al., 2024). The analysis of the business models developed in this study serves as a baseline for more in-depth evaluations of the impacts of these regulations.

5 Conclusions

This study aimed to assess the vulnerability of cacao value chains in Ecuador, Colombia, and Costa Rica to the EU Cd regulation on chocolate products and derivatives. The findings reveal that this regulation poses significant challenges, particularly for regions with higher Cd contamination levels and for specialty cacao producers dependent on niche markets.

The mapping of cacao value chains in the three countries provided key insights into the structural differences and similarities across their supply chains. In Ecuador and Colombia, smallholder farmers represent the majority at the production level, but the processing and export stages are controlled by larger actors, highlighting the concentration of market power in specific links of the value chain. Costa Rica's value chain is distinct, with its focus on fine-flavor cacao and smaller-scale production, which offers both challenges and opportunities for compliance with Cd regulation. The mapping also revealed that the actors most aware of the regulation are those involved in export activities, technical assistance, and certification. However, producers, the most vulnerable actors, were often unaware of the regulation. This underscores the need for mitigation measures to focus primarily on farmers, who require increased support and training to adapt and minimize the negative impacts on their livelihoods.

A major constraint in our study was the lack of traceability, which makes it difficult to identify cacao destined for export vs. that for the internal market. Because of this limitation, there is potential to overestimate the economic impact of the Cd regulation, particularly in Colombia, where domestic consumption is high. Despite this, our study can serve as a baseline for future cacao expansion, which may be encouraged by the high cacao prices observed over the past year. Any expansion efforts should take into account the potential risks identified in this study to avoid market barriers for new production.

In Ecuador, where a significant share of cacao exports is destined for the EU, the potential impact of the regulation is more severe than in Colombia or Costa Rica. The results indicate that nearly 30% of cacao production could be at risk. Ecuador was selected for a more detailed business model analysis due to its high dependency on the EU market and the significant portion of its production that could be affected. The analysis of various business models revealed that greater exposure to high-value markets in the EU leads to increased costs related to Cd testing, mitigation measures, and sourcing strategy changes. Smaller exporters and family-owned businesses are particularly vulnerable, as they face higher operational costs and potential revenue losses due to reduced access to premium buyers. In contrast, larger exporters have been able to absorb these costs more effectively by diversifying their sourcing regions and implementing mixing strategies.

In Colombia, the impact of the regulation has been less immediate due to higher domestic consumption. However, as the country seeks to expand cacao exports to the EU and other markets, risks associated with Cd levels are becoming increasingly concerning. The expansion of cacao production in areas with high Cd contamination should be avoided, and preliminary Cd assessments should be conducted before establishing new plantations.

In Costa Rica, where the cacao sector focuses on fine-flavor production, different challenges arise. Although overall Cd levels are lower compared to Ecuador and Colombia, around 24% of the cacao produced exceeds EU limits. The main concern is balancing the need to maintain the premium quality of cacao while implementing mitigation strategies. Despite these challenges, Costa Rican stakeholders remain optimistic, citing the country's smaller production scale and proximity of production areas as advantages in meeting EU standards.

Cd regulation has impacted the operational costs of business models and impaired potential business opportunities for the organizations studied. These economic challenges are particularly pronounced for smallholder farmers, who may struggle to absorb the costs of compliance. To address these issues, targeted support from both public and private sectors is essential to enhance the resilience of cacao producers and value chain actors at all levels.

At the micro level, stakeholders must strengthen their connections with local and international research initiatives to identify and implement alternative mitigation strategies. At the meso level, increasing access to credit lines and subsidy schemes is critical to support the most vulnerable actors in adopting mitigation measures. At the macro level, agricultural policy should prioritize the provision of efficient extension services, ensuring smallholder farmers in high-Cd areas have access to information about regulations, detection mechanisms, and best mitigation practices. Strengthening producer associations, improving access to technology, and promoting cost-effective mitigation strategies will also be crucial for minimizing the socioeconomic impacts of EU regulation on the cacao sectors of Ecuador, Colombia, and Costa Rica, while preserving their access to key markets.

Finally, this study presents limitations regarding reproducibility, as the information gathered during the interviews could not be directly linked to specific trade destinations or price data. Over the last few years, cacao prices have fluctuated considerably, which may have influenced interviewees' responses, particularly regarding their willingness to absorb additional costs associated with Cd testing or the mixing of commercial batches. Despite these limitations, the methodological approach remains relevant for evaluating the potential impact of upcoming regulations, such as those related to nickel (Ni), and the value chain analysis and semi-structured interview approach applied in this research can be used to assess the economic implications of this emerging regulation.

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Supplementary material

The Supplementary Material for this article can be found online at: https://www.frontiersin.org/articles/10.3389/frevc.2026.1783933/full#supplementary-material

Supplementary material Supplementary material at the source

Footnotes

Edited by: Gideon Danso-Abbeam, University for Development Studies, Ghana

Reviewed by: Jose Carlos Montes Ninaquispe, Universidad de San Martin de Porres, Peru

Luis Enrique David Tenorio, Institución Universitaria Escuela Nacional del Deporte, Colombia

Statements

Conflict of interest

The author(s) declared that this work was conducted in the absence of any commercial or financial relationships that could be construed as a potential conflict of interest.

Funding

The author(s) declared that financial support was received for this work and/or its publication. This research was funded by FONTAGRO through with grant ATN/RF-17235-RG. The opinions expressed in this publication are exclusively those of the authors and do not necessarily reflect the point of view of FONTAGRO, its Board of Directors, or the countries it represents.

Data availability

The datasets presented in this article are not readily available because, the data used in this study were obtained from publicly available sources, including official international trade websites and published scientific literature. Requests to access the datasets should be directed to guiazamb@espol.edu.

Ethics approval

The studies involving humans were approved by Research Committee of ESPOL University under resolution number 20-08-001. The studies were conducted in accordance with the local legislation and institutional requirements. The participants provided their written informed consent to participate in this study.

Author contributions

GZ: Conceptualization, Data curation, Formal analysis, Investigation, Methodology, Software, Validation, Writing – original draft, Writing – review & editing. KR: Conceptualization, Data curation, Formal analysis, Investigation, Methodology, Software, Validation, Visualization, Writing – original draft, Writing – review & editing. JV: Conceptualization, Data curation, Formal analysis, Investigation, Methodology, Software, Writing – original draft, Writing – review & editing. FM: Data curation, Formal analysis, Investigation, Software, Validation, Writing – original draft, Writing – review & editing. LS: Data curation, Formal analysis, Investigation, Software, Validation, Writing – original draft, Writing – review & editing. DB: Conceptualization, Data curation, Formal analysis, Investigation, Methodology, Software, Validation, Writing – original draft, Writing – review & editing. BM: Conceptualization, Investigation, Project administration, Resources, Writing – original draft, Writing – review & editing. LR: Conceptualization, Investigation, Project administration, Resources, Supervision, Writing – original draft, Writing – review & editing. EC: Conceptualization, Data curation, Funding acquisition, Investigation, Methodology, Project administration, Resources, Supervision, Validation, Visualization, Writing – original draft, Writing – review & editing. AS: Conceptualization, Formal analysis, Investigation, Methodology, Project administration, Resources, Supervision, Visualization, Writing – original draft, Writing – review & editing.

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Citation

Zambrano, G., et al. (2026). Economic vulnerability of the cacao value chain to the cadmium (Cd) regulation in chocolates: a whole-chain analysis in Ecuador, Colombia, and Costa Rica. Frontiers in Environmental Economics, Volume 5. https://doi.org/
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5 - 2026

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Copyright © 2026 Zambrano, Ramírez, Vázquez, Montealegre, Sánchez, Bravo, Moyano, Ramírez, Chávez and Santos.

License: https://creativecommons.org/licenses/by/4.0/

*Correspondence: Guillermo Zambrano

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