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18063200
COCOA AND COCOA PREPARATIONSChocolate and other food preparations containing cocoa

Not filled

Unfilled chocolate in international trade

CN code 18 06 32 covers chocolate and other food preparations containing cocoa in tablets, bars, or sticks weighing not more than 2 kg, not filled. This category includes chocolate bars, solid chocolate tablets, dark, milk, and white chocolate in solid form. Import of unfilled chocolate into the EU in 2026 is subject to EUDR regulations requiring due diligence in cocoa traceability. These products represent one of the most important import categories in the confectionery sector. Correct classification under this code requires meeting two conditions: unit weight does not exceed 2 kg, and the product contains no filling. Chocolate with inclusions such as nuts, raisins, or fruit pieces distributed evenly throughout the chocolate mass is classified as unfilled since it does not have a distinct filling layer.

Regulatory requirements and quality controls

Unfilled chocolate imported into the EU must meet the requirements of Chocolate Directive 2000/36/EC, which sets minimum cocoa ingredient content for different chocolate categories. Food safety controls include testing for cadmium, mycotoxins, and pesticide residues. Cadmium limits are differentiated by cocoa dry matter content: chocolate with higher cocoa content is subject to stricter limits. Labeling must comply with Regulation (EU) No 1169/2011, containing a complete ingredient list, allergen information, and nutritional values. The Chocolate Directive requires stating the percentage of cocoa dry matter. Importers must also ensure compliance with regulations on the use of cocoa butter equivalent fats in chocolate, which are permitted up to a specified level. Products failing to meet Chocolate Directive requirements cannot be sold under the name chocolate in the EU market.

Customs aspects and documentation

Customs clearance of unfilled chocolate under CN code 18 06 32 requires complete commercial and regulatory documentation. The commercial invoice must contain an accurate product description, unit weight, cocoa content, and composition. The certificate of origin determines the duty rate and eligibility for trade preferences. The EUDR statement confirms due diligence in the cocoa supply chain. The customs value includes the product price under delivery terms to the EU border. Importers should note the correct distinction between unfilled and filled chocolate, as incorrect classification may result in different duty amounts. Customs authorities may conduct physical inspections, including cutting the product to check for filling. When importing large batches of chocolate, it is also important to ensure appropriate transport and storage conditions, as chocolate requires temperature control.

Unfilled chocolate CN 1806 32 - EU import rules

Unfilled chocolate under CN 1806 32 covers bars, tablets and other chocolate products without filling, weighing up to 2 kg. Compound duties apply. Products must meet Directive 2000/36/EC minimum cocoa content requirements. Dark chocolate requires 35% cocoa solids minimum. EUDR due diligence applies.

Frequently asked questions

How to distinguish filled from unfilled chocolate in customs classification?
Filled chocolate (CN 18 06 31) has a distinct layer of another food material inside a chocolate shell. Unfilled chocolate (CN 18 06 32) is homogeneous or contains inclusions like nuts or raisins distributed evenly throughout the mass. Customs authorities may physically inspect the product by cutting it to verify classification.
What Chocolate Directive requirements apply to imports?
Directive 2000/36/EC sets minimum cocoa ingredient content for different chocolate categories. Chocolate must contain specified minimums of cocoa dry matter and cocoa butter. It also permits limited use of cocoa butter equivalent vegetable fats. Products not meeting these requirements cannot be sold under the name chocolate in the EU.
Is chocolate with nuts classified as filled?
No, chocolate with nuts, raisins, or other inclusions distributed evenly throughout the chocolate mass is classified as unfilled under CN code 18 06 32. A filling in tariff terms means a distinct layer of another material inside a chocolate shell. Products like pralines with a distinct filling are filled chocolate.
What cocoa content requirements apply to unfilled chocolate CN 1806 32?
Unfilled chocolate CN 1806 32 must comply with Directive 2000/36/EC: dark chocolate minimum 35% cocoa solids, milk chocolate minimum 25%, white chocolate minimum 20% cocoa butter. Labelling must reflect actual type.