EUDR Compliance for EU Importers Buying From Vietnam: The Duty Sits on Your Side

Under the regulation, the obligation runs to the operator placing the relevant product on the EU market. A coffee cooperative in Dak Lak or a wood processor in Dong Nai is not the one answering to an EU competent authority — you are. Their incentive to hand over plot-level data is entirely commercial, which means the data arrives if and only if your purchase contract, and your payment terms, ask for it in a form you can actually file.

Article 9(1)(d) is where the shape of that data gets fixed: you must collect the geolocation of all plots of land where the commodity was produced, together with the date or time range of production. If a lot came from several plots, all of them go in the record — not a representative sample, not the biggest one. And if deforestation or forest degradation is found on any single plot, everything from that plot loses its eligibility, which is what makes the mixing of lots at a collection point such an expensive habit.

In practice this rewrites the document request you send before the first order rather than after a problem. If you are building that request from scratch, the list of documents worth asking a Vietnamese supplier for is a longer conversation than plot coordinates alone.

The regulation covers seven relevant commodities, listed in Annex I as cattle, cocoa, coffee, oil palm, rubber, soya and wood, plus the products derived from them. For a buyer sourcing out of Vietnam, three of those do most of the work: coffee, rubber and wood, and the derived products around them — which is why furniture, plywood and tyre-adjacent goods keep pulling companies into scope who never thought of themselves as agricultural importers.

Scope is set at the product level in Annex I, and that list moves even when the commodity list does not. The 2025 amending regulation deleted the printed-matter line, the one covering printed books, newspapers and pictures, from Annex I; the seven commodities themselves were untouched. According to the European Commission's environment directorate-general, a further delegated act adopted on July 13, 2026 would remove items such as bovine hides and leather, retreaded tyres, soya beans for sowing, vulcanised rubber articles, conveyor belts, and aircraft and vehicle seats, while adding instant coffee, certain palm oil derivatives and frozen bovine tongues, with newly covered products applying from December 30, 2027. That act was still in the scrutiny period and had not been folded into the consolidated text, so the working list for any decision you make today is the consolidated Annex I, not the press release.

Every postponement so far has moved when the rules apply to you, never the line the land has to be on the right side of. The commodity must come from land that was not subject to deforestation after December 31, 2020, and wood carries an extra condition: it must have been harvested without the forest being degraded after that same date. A plantation cleared in 2019 and one cleared in 2021 are two different answers, and no amount of paperwork changes which one you bought.

This is why the deadline that matters internally is not the application date but the harvest you are buying next. Plot data for a crop already in a warehouse is archaeology; plot data captured while someone is standing on the plot is evidence. If that capture happens in provinces where connectivity comes and goes, it is worth confirming in advance whether the tool your field team uses really works offline, because a coordinate that failed to sync is indistinguishable from a coordinate nobody collected.

The regulation is specific about precision: geolocation means latitude and longitude coordinates describing the plot, with at least one latitude point and one longitude point, expressed to at least six decimal places. That level of precision rules out a village name, a district, or a pin dropped on a map by someone in an office.

The step change in cost comes with area. For plots larger than four hectares used to produce anything other than cattle, a single point is not enough — you need polygon points sufficient to describe the perimeter of the plot. Smallholder coffee in the Central Highlands often falls under that threshold, while rubber and wood concessions routinely do not, so the same purchasing team can face two completely different data collection problems in the same quarter.

The 2025 amendments added one simplification worth knowing precisely, because it is easy to over-read: for a micro or small primary operator, the geolocation required by Article 9(1)(d) may be replaced by the postal addresses of all plots, or of the premises where animals are kept. That status attaches to the primary operator, not to you as the buyer, so it is something to confirm about a specific supplier rather than assume for a category of them.

Whatever form the data takes, it has to survive: information, documents and data must be kept for five years from the date the product was placed on the market or exported. A due diligence file that lives in one buyer's mailbox does not meet that in any meaningful sense.

The failure mode is predictable: the goods are bought on normal commercial terms, the compliance question is raised at shipment, and by then the only source of plot data is a supplier who has already been paid. What changes the outcome is unglamorous — plot list and production dates as a delivery condition, a documented rule about which lots may be mixed, a right to verify, and a named person on the supplier side who owns the file.

It is also worth being blunt internally about what this is not. This regime asks where the material grew and whether that land was cleared after a fixed date; it does not ask whether the factory did enough work to change the goods, which is a separate question with separate law behind it. Companies that fold both into one supplier scorecard end up with a file that answers neither. If the sourcing side is what you are building out, a due diligence checklist for Vietnamese suppliers is the piece that sits next to this one, not inside it.