EUDR Verification: A Complete Compliance Guide for Vietnamese Exporters

EUDR verification is the independent check that each shipment placed on the EU market meets the three conditions of Regulation (EU) 2023/1115: it is deforestation-free after 31 December 2020, legally produced under the laws of the country of production and covered by a Due Diligence Statement (DDS). Under amending Regulation (EU) 2025/2650, the obligations apply from 30 December 2026 for large and medium-sized operators and from 30 June 2027 for micro and small operators.

For Vietnamese coffee, timber and rubber exporters, the focus is on plot-level geolocation data, legal origin documentation and a traceability system reliable enough to support EUDR verification by EU customers.

💡 KEY TAKEAWAYS FOR BUSINESS LEADERS (EXECUTIVE SUMMARY)

• Core requirement: Every shipment must be traceable to the coordinates of each production plot (at least six decimal places, with polygons for plots over 4 hectares) and proven deforestation-free after 31 December 2020.
• Current application dates: 30 December 2026 for large and medium-sized operators and 30 June 2027 for micro and small operators, based on the size of the company placing the goods on the EU market.
• Vietnam’s advantage: Vietnam is classified as “low risk” (Implementing Regulation (EU) 2025/1093), which allows simplified due diligence, but full geolocation data is still required.
• Risk of non-compliance: EU customers cannot file a DDS, shipments cannot clear customs, and importers face maximum fines of at least 4% of annual EU turnover.
• Control Union solution: EUDR verification of shipments and supporting DDS data, combined with FSC and PEFC forest management and chain of custody certification.

Why Vietnamese exporters need EUDR compliance and verification

The EUDR is Regulation (EU) 2023/1115 on deforestation-free products, which requires every in-scope commodity to prove “deforestation-free” origin before entering the EU market. Vietnamese companies are not directly bound by the regulation, yet they hold the most important data and evidence that EU importers need to comply.

The EU is a major market for Vietnam’s three key commodities: coffee, timber and rubber. According to the World Resources Institute (WRI), the EU accounts for only about 7% of the world’s population but is linked to as much as 16% of deforestation through its imports, which is why the EU places the burden of proof on the entire supply chain rather than checking only at the border.

What are the core elements of the EU Deforestation Regulation

Regulation (EU) 2023/1115 entered into force on 29 June 2023, progressively replacing the EU Timber Regulation (EUTR) No 995/2010, and covers three activities: placing products on the EU market, making them available on the EU market and exporting them from the EU. In other words, the same standard applies to imports and to goods produced within the EU.

The EUDR is built around five closely linked components.

Which seven commodities fall under the EUDR

The EUDR covers seven commodities, namely cattle, cocoa, coffee, oil palm, rubber, soya and wood, together with the derived products listed by HS code in Annex I. The first step in EUDR compliance is scoping: a product is only in scope if its HS code is on this list, not simply because it contains one of the seven commodities.

EUDR deadlines 2026–2027: when should exporters start preparing

As of October 2026, fewer than three months remain before the 30 December 2026 deadline, and major EU importers usually complete supplier due diligence before signing contracts for the new crop season. In practice, this means the real EUDR deadline for Vietnamese exporters arrives earlier than the legal one.

Companies that prepared their data early already hold a clear negotiating advantage. Vietnam’s Agriculture and Environment Newspaper (August 2026) reported that foreign customers are actively seeking Vietnamese coffee sources able to meet the EUDR, showing that EUDR readiness has become a supplier selection criterion rather than a formality.

How do deadlines differ for large, medium and small companies

Under Regulation (EU) 2025/2650, published on 23 December 2025 and in force since 26 December 2025, the current EUDR timeline is divided according to the size of the company placing goods on the EU market.

The key point about EUDR deadlines is that company size is assessed for the company in the EU, as defined by Directive 2013/34/EU, not for the Vietnamese exporter. Even a micro-sized Vietnamese supplier must therefore have its data ready if it sells to an EU customer that falls within the scope of the EUDR.

The 2025 amendment also simplified downstream obligations: downstream operators and traders no longer need to submit their own DDS, and only the first downstream company keeps the reference number of the original DDS. Micro and small primary operators established in low-risk countries that grow or harvest the products themselves submit a one-off simplified declaration. According to the European Commission, the simplification measures cut compliance costs by about 75% compared with the original text, but data requirements at the sourcing area remain unchanged.

EUDR geolocation: what data must be collected from sourcing areas

EUDR geolocation means the latitude and longitude coordinates that identify each plot of land where the commodities in a shipment were produced. It is mandatory under Article 9, is the first data set checked in any EUDR verification, and is the part Vietnamese companies must prepare themselves, as EU importers cannot collect it on their behalf.

The requirement covers every plot that contributed raw material to a shipment, even when the shipment is blended from hundreds of sources. For smallholder-based supply chains such as Vietnamese coffee and rubber, the volume of data an exporter must manage can run to tens of thousands of coordinate points.

What is the difference between point coordinates and plot polygons

The EUDR distinguishes two ways of describing a plot based on its area, applicable to all commodities except cattle.

The regulation allows point coordinates for small plots but does not prohibit polygons. For plots near forest edges or on hilly terrain, proactively collecting polygons even for plots under 4 hectares is an effective way to remove doubts when customers cross-check forest cover maps. For cattle, geolocation refers to the establishments where the cattle were kept rather than plots of land.

What standards must geographic data meet

The EUDR Information System accepts coordinates in GeoJSON format, using the WGS84 reference system (EPSG:4326), with at least six decimal places. The table below shows the approximate precision for each number of decimal places.

The most time-consuming error when preparing EUDR files in Vietnam is confusing coordinate systems. Coordinates on land use right certificates and cadastral maps are usually expressed in the VN-2000 system as projected coordinates in metres, so they must be converted to WGS84 longitude and latitude before use. Converting with the wrong parameters can shift a plot away from its true location, even into a forest area when checked against maps.

Before handing data to customers or submitting it for EUDR verification, the dataset should be checked against four criteria: correct WGS84 reference system, six decimal places, closed and non-self-intersecting polygons, and no overlapping plots between suppliers. Open-source GIS tools such as QGIS can carry out most of these checks.

What is a DDS and how is a Due Diligence Statement prepared

A DDS (Due Diligence Statement) is the statement that the company placing goods on the EU market submits through the EUDR Information System, confirming that due diligence has been carried out and that the risk of non-compliance is none or negligible. On submission, the company receives a reference number and a verification number to include with the customs declaration.

A DDS is not a certificate issued by a third party but a legally binding statement by the submitting company. The EU importer’s EUDR compliance therefore depends entirely on the quality of the data supplied by its supply chain, including Vietnamese exporters, which is where independent EUDR verification of that data adds value.

What must a DDS contain

Under Annex II of Regulation (EU) 2023/1115, a DDS must include the following information.

In addition to the DDS, Article 9 requires information on the date or time range of production, supplier names and addresses, and verifiable evidence of deforestation-free and legal production. This information does not appear in the DDS but must be kept for five years and presented to competent authorities on request.

Who prepares and submits the DDS in the EUDR Information System

The party that submits the DDS is the operator, meaning the company that first places the product on the EU market or exports it from the EU. In normal export trade, this is the importer or manufacturer in the EU, not the Vietnamese exporter.

Since the 2025 amendment, the obligation to submit a DDS is concentrated at the first point in the EU supply chain, as follows.

• First operator: submits the full DDS and bears legal responsibility for its content.
• Downstream operators and traders: do not submit a separate DDS; the first downstream company collects and keeps the reference number of the original DDS.
• Micro and small primary operators: if established in a low-risk country and growing or harvesting the products themselves, they submit a one-off simplified declaration instead of a DDS for each shipment.
• Authorised representative: under Article 6, an operator may mandate another party to submit the DDS but retains full legal responsibility.

Where a Vietnamese company has a subsidiary or legal entity in the EU that imports goods directly, that entity becomes the operator and must submit the DDS itself. This role should be clarified from the outset when building an EUDR compliance system.

How are responsibilities shared between EU operators and Vietnamese exporters

Legal responsibility for EUDR compliance lies with the EU operator, but responsibility for providing the data rests mainly on the Vietnamese side. This division should be written into commercial contracts rather than left to assumption.

Under Article 25, penalties for non-compliant operators include maximum fines of at least 4% of total annual EU turnover, confiscation of the goods and related revenues, and exclusion from public procurement for up to 12 months. This level of risk explains why EU customers increasingly add data-sharing, audit-right and indemnity clauses to purchase contracts. Exporters who proactively propose a clear data-sharing agreement, backed by independent EUDR verification, are in a stronger negotiating position.

How Vietnamese coffee, timber and rubber companies implement the EUDR

The three key commodities have different supply chain structures, so their EUDR bottlenecks also differ. Coffee struggles with smallholder scale, timber with imported raw material, and rubber faces pressure on both fronts.

Applying one generic process to every commodity often leads to collecting unnecessary data while missing critical data. The sections below analyse the specific requirements for each sector so companies can focus their resources where they matter.

What documents does the coffee supply chain need for the EUDR

Green and roasted coffee (HS 0901) falls within the EUDR, with supply coming mainly from smallholders in the Central Highlands. The biggest bottleneck lies with collection agents, where coffee from many households is mixed before reaching the processing plant.

EUDR files for the coffee chain should be organised at the following levels.

• Farm level: point or polygon coordinates for each plot, land use right certificate and harvest season.
• Collection agent level: list of supplying households for each delivery, weighing slips and a commitment not to accept goods from outside the identified list.
• Processing plant and exporter level: inventory records that keep compliant lots separate, linking each export shipment to its list of plots.

Sustainability certifications such as Rainforest Alliance or 4C provide baseline data and existing internal control systems. However, certification only supports, and does not replace, the geolocation requirement and EUDR verification for each specific shipment.

What traceability challenges do the timber and furniture sectors face

The timber sector has a foundation advantage thanks to the Vietnam Timber Legality Assurance System (VNTLAS) under Decree 102/2020/ND-CP and the VPA/FLEGT agreement with the EU. However, the EUDR additionally requires geolocation and proof of no forest degradation, going beyond the legality evidence provided by existing systems.

Three timber-specific EUDR challenges need to be handled separately.

• Domestic plantation timber: acacia and eucalyptus plantations are still “forest” under the EUDR, so it must be shown that they were not converted from natural forest to plantation after 2020.
• Imported timber: the country of production is the harvesting country, and exporters must collect geolocation from foreign suppliers over whom they have little direct control.
• Multi-material products: a set of furniture may use rubberwood, acacia and imported plywood, each requiring its own data.

Companies should also note the transition mechanism: timber and timber products produced before 29 June 2023 remain subject to the EUTR rather than the EUDR until 31 December 2029. Classifying inventory by production date helps avoid applying the wrong legal framework and simplifies EUDR verification of mixed stock.

What should rubber and processed rubber products pay attention to

Natural rubber (HS 4001) and certain Chapter 40 products such as tyres and gloves fall within the EUDR. Under the regulation’s definitions, rubber plantations are agricultural plantations rather than forests, but clearing forest to plant new rubber after 31 December 2020 still counts as deforestation.

Two features of Vietnam’s rubber sector add complexity to EUDR compliance. First, smallholders account for a large share of output, requiring thousands of households to be identified, as in coffee. Second, part of the raw material is imported from neighbouring countries for processing, so the country of production in the DDS may not be Vietnam.

A key point to note is that the mass balance method, common in some certification systems, is not compatible with the EUDR when compliant material is mixed with material of unknown origin. Latex processors should prioritise segregating raw material flows for orders destined for the EU, which also makes EUDR verification of each lot far more straightforward.

Can FSC and PEFC certification replace the DDS obligation

The short answer is no. In EUDR compliance and EUDR verification, FSC, PEFC and other sustainability certifications are supporting sources of information for risk assessment, but they do not replace the EU operator’s obligation to collect geolocation and submit a DDS.

Materials presented at the 15 July 2026 meeting of the EUDR Community of Practice (EUDR CoP), published by the European Forest Institute (EFI), summarised results from EUDR dry runs and showed that certification serves as an input to the due diligence system, assessed by how well it covers EUDR requirements, rather than as automatic proof of compliance. The differences are clear in the comparison below.

The real value of certification lies in the chain of custody controls, supplier management and legal documentation that have already been independently assessed. Companies already holding FSC or PEFC certification only need to add geolocation and lot-level data linkage, rather than building a system from scratch, and can combine both in a single EUDR verification audit. The European Commission has also indicated that it will set up a repository of EUDR-relevant certification schemes to help operators assess how far each scheme supports compliance.

How to choose an EUDR verification provider in Vietnam

No private organisation has the authority to “approve a DDS” on behalf of the competent authorities of EU member states. A genuine EUDR verification provider helps companies build data and systems robust enough for EU operators to submit their DDS with confidence and pass inspections.

According to EUDR Community of Practice (EUDR CoP) materials from June 2026, operators are increasingly outsourcing individual due diligence components to external service providers, while transparency about the scope of services remains the biggest issue. When choosing an EUDR verification provider, companies should therefore assess five criteria.

• Independence: the provider acts as a third party and is not also selling raw material or providing consultancy and then assessing its own advice.
• Transparent scope: it states clearly whether the service is a readiness assessment, data verification or certification, and does not promise to replace legal obligations.
• Geospatial capability: it can check polygons, cross-check satellite imagery and carry out field verification.
• Multi-commodity experience: it understands the coffee, timber and rubber supply chains and related certification schemes such as FSC and PEFC.
• International presence: its reports are known and accepted by EU customers, and it has a team in Vietnam for field work.

Common mistakes that cause EUDR files to be rejected

Most EUDR files returned by EU customers are rejected not because the company breached the deforestation-free condition, but because the data fails technical standards or lacks linkage, issues that EUDR verification is designed to catch early.

The seven most frequent mistakes are:

1. Using the VN-2000 coordinate system instead of WGS84, which shifts plots when checked against maps.
2. Coordinates with fewer than six decimal places, which the EUDR Information System rejects.
3. Using point coordinates for plots over 4 hectares, failing the mandatory polygon requirement.
4. Mixing in material of unknown origin through mass balance, leaving the whole shipment unable to prove compliance.
5. Declaring the wrong country of production for imported timber or rubber, entering Vietnam instead of the harvesting country.
6. Treating certification as sufficient proof, without adding geolocation and shipment linkage.
7. Assuming “low risk” means exemption, skipping the information collection step that remains mandatory.

Each of these mistakes can be detected in advance through a gap assessment or EUDR verification, at a far lower cost than losing a contract close to the 30 December 2026 deadline.

How Control Union supports EUDR verification

Control Union is an independent certification and inspection body founded in 1920 in the Netherlands, now operating in more than 80 countries and accredited for sustainability schemes such as FSC, PEFC, Rainforest Alliance and RSPO. The group has developed the EUDR Verification Protocol, a modular verification framework for producers, processors, traders and exporters.

As an independent third party, Control Union Vietnam supports EUDR compliance in the following areas.

• EUDR verification of shipments and DDS data: checking geolocation data, legal documentation and traceability from sourcing area to individual shipment.
• FSC and PEFC certification: forest management certification (FSC FM, PEFC FM/VFCS) and chain of custody certification (FSC CoC, PEFC CoC), which can be combined with EUDR verification to optimise audit time.
• Awareness training: training on the requirements of international certification standards for procurement and supply chain teams.

Control Union’s EUDR verification reports do not replace the DDS or the EU operator’s legal obligations, but provide independent evidence that increases the credibility of the data companies pass on to their customers.

For an EUDR readiness assessment or advice on integrating EUDR verification with FSC/PEFC certification, please contact our team of experts directly.

Control Union Vietnam

Head office: 61–63 Dang Nhu Mai, Thanh My Loi Ward, Thu Duc City, Ho Chi Minh City

Hotline: +84 28 6281 3362 / +84 917 040 033

Email: vietnam@controlunion.com

Website: vietnam.controlunion.com

Frequently asked questions about EUDR verification

Do exporters of raw commodities need to prepare a DDS

Vietnamese exporters do not submit a DDS themselves, as this obligation lies with the EU importer, even for raw commodities such as green coffee. However, exporters must still provide complete geolocation and legal documentation so their customers can prepare the DDS and complete EUDR compliance.

How is geolocation handled when a shipment blends material from many areas

The shipment must include the coordinates of every plot that contributed material and must not be mixed with material of unidentified origin. Companies should segregate EU-bound flows from the purchasing stage to limit the number of plots to be declared.

How is Vietnam classified under the EUDR country benchmarking

Under Implementing Regulation (EU) 2025/1093 of 22 May 2025, Vietnam is classified as “low risk”, which allows simplified due diligence and a 1% inspection rate. The European Commission reviews this classification periodically, so companies should monitor updates.