What EUDR Article 9 actually requires from a Vietnamese supplier.

The six things Article 9 requires

For each product you place on the EU market, you must collect and retain, for five years:

1. The product description, including trade name, type, and the common name and full scientific name of the species where relevant.
2. The quantity, expressed in net mass, volume, or number of units.
3. The country of production, and where relevant the parts of it.
4. The geolocation of all plots of land where the commodity was produced, with the date or time range of production. For plots over four hectares, this must be a polygon, not a single point.
5. The name, postal address, and email of every business or person who supplied the product to you, and to whom it was supplied.
6. Adequately conclusive and verifiable information that the commodity is deforestation-free, and that it was produced in accordance with the relevant legislation of the country of production.

Why a supplier declaration does not satisfy it

The most common failure we see in practice is a buyer holding a signed supplier declaration and treating the matter as closed. Article 9 does not ask for an assertion; it asks for information that is adequately conclusive and verifiable. Those two words carry the entire burden.

A declaration is verifiable only if you can say what it rests on. If a Vietnamese furniture manufacturer certifies that its timber is deforestation-free, the questions a competent authority may reasonably ask are: on what basis? Which plots? Who harvested? What document establishes legality under Vietnamese forestry law? If those answers do not exist, neither does your due diligence.

This matters because liability sits with the operator — you — not with the supplier who signed. A supplier in Bình Định has no exposure to an EU competent authority. You do.

Where Vietnamese supply chains typically break

Vietnam is a processing country as much as a producing one, and that shapes where the evidence gaps appear. In wood and furniture specifically:

• Imported inputs. A significant share of sawn timber processed in Vietnam is imported — from Laos, Cambodia, and elsewhere — often through a domestic trader. That trader frequently holds country of origin but not plot geolocation, and cannot obtain it retroactively.
• Smallholder acacia and rubberwood. Vietnam's plantation timber comes substantially from small landholdings. Plot data exists, but is fragmented across many households and rarely aggregated in a form a supplier can hand over.
• Undisclosed subcontracting. Finishing, upholstery, and component work is commonly subcontracted to workshops a buyer never sees. Material entering the product at that stage sits outside whatever traceability the primary supplier can evidence.
• Certificates that do not validate. An FSC or PEFC certificate is useful, but is not itself an Article 9 answer — and in our experience a meaningful minority of certificates presented by suppliers do not appear on the issuing body's public register under that entity's name.

What "risk assessment" means under Article 10

Article 9 is collection; Article 10 is assessment. Having the information is not the same as having concluded there is no more than a negligible risk. The assessment must take into account, among other factors, the prevalence of deforestation in the country and region concerned, the presence of forests, the complexity of the supply chain, and any concerns about the reliability of the information supplied.

Where the risk is not negligible, Article 11 requires mitigation — which explicitly includes commissioning independent audits or requesting additional information. This is the clause under which third-party verification becomes not merely useful but the named remedy.

A practical sequence for a Vietnamese supplier

1. Establish the entity. Confirm the supplier is legally constituted and that the entity on the quotation is the entity producing the goods. A trading company presenting itself as a manufacturer breaks the chain at step one.
2. Map the input streams. Determine what proportion of material is domestic plantation, domestic natural forest, or imported — and by what route. Each stream needs its own evidence.
3. Obtain plot data at source, not in summary. Ask for the geolocation data as held, not as summarised by the supplier. Aggregation hides gaps.
4. Validate certificates independently. Check every certificate against the issuing body's register yourself, under the exact entity name and registration number.
5. Identify subcontractors. Ask directly, on site, what work is performed elsewhere. This is rarely volunteered and is almost never in the supplier profile.
6. Document the gaps. What you cannot verify is part of your due diligence record. An honest gap, mitigated, is defensible. An unexamined assumption is not.

The deadline in practical terms

Obligations apply from 30 December 2026 for large and medium operators. Working backwards from that date: collecting plot-level data from a supplier who has never been asked for it takes weeks, not days; obtaining it from an upstream trader who does not hold it may not be possible at all, in which case you need a different supplier or a different input stream. Buyers who begin in the final quarter are frequently discovering, rather than fixing, their problem.

Related

• How to verify a Vietnamese manufacturer before your first order
• UFLPA and transshipment risk in Vietnam
• What a verification report contains, with a sample extract

This guide summarises Regulation (EU) 2023/1115 as it applies to buyers sourcing from Vietnam. It is general information, not legal advice, and does not replace reading the regulation or taking advice on your specific supply chain.