Challenges for implementing human rights due diligence: empirical evidence from the cocoa value chain in Brazil

Abstract

As mandatory HRDD legislation expands globally, including the CS3D and the German Supply Chain Act, understanding the barriers to its operationalisation in agricultural value chains becomes increasingly pressing. This article examines these challenges, drawing on empirical evidence from the cocoa sector in Brazil. Building on the UN Guiding Principles on Business and Human Rights and the growing convergence between international standards, legislation and ESG expectations, it analyses how structural conditions hinder effective HRDD implementation. Based on research conducted by the Business and Human Rights Centre of FGV, the findings demonstrate that human rights impacts are not isolated but interconnected and mutually reinforcing, emerging from territorial vulnerabilities, labour informality, and intermediation dynamics. These factors limit traceability, challenge corporate leverage, and tiered audit-based approaches. The article argues that effective HRDD requires context-sensitive and systemic responses to effectively identify and address human rights impacts, thus, supporting better corporate and investment decision-making.