What EUDR Article 9 actually requires from a Vietnamese supplier.

The short answer. For each product you place on the EU market, EUDR Article 9 requires you to collect six kinds of information: the product description with the species name, the quantity, the country of production, the geolocation of the plots where the wood grew together with the production date, the details of your suppliers and customers, and conclusive evidence that the product is deforestation-free and legally produced. A signed supplier declaration is not enough. The rules apply from 30 December 2026 to large and medium operators and traders, and from 30 June 2027 to micro and small operators.

Which wood products does EUDR cover?

Annex I lists the covered products by customs code. A delegated regulation published in the Official Journal on 17 September 2026 (Delegated Regulation (EU) 2026/2102) updated the list. Wooden furniture (HS 9403 30, 40, 50, 60 and 91), wooden seats (HS 9401) and prefabricated wooden buildings (HS 9406 10 00) stay in scope. Used and second-hand products, seats for aircraft and motor vehicles, samples, and single-use packing that carries another product are not covered. Products made of bamboo, rattan and other woody materials, such as reeds, rushes, osier, raffia, straw and lime bark, are not covered either. Check your own customs code against the current Annex I before you rely on this. For rattan and bamboo furniture, and for products that mix wood with them, see does EUDR apply to rattan and bamboo furniture.

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.

The cut-off date is 31 December 2020. Land converted from forest after that date renders the commodity non-compliant, regardless of whether the conversion was legal under local law.

Why a supplier declaration does not satisfy it

The mistake to avoid is 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 set the standard.

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 can 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. Vietnam's wood industry depends on imported round and sawn wood, from sources that include Laos, Brazil, Chile and the United States. If a trader or importer sits between the forest and the factory, it may know the country of origin but not the plot location, and may be unable to obtain it retroactively.
• Smallholder acacia and rubberwood. Vietnam's plantation timber comes substantially from small landholdings. Plot data may exist, but be fragmented across many households and not aggregated in a form a supplier can hand over.
• Undisclosed subcontracting. Finishing, upholstery, and component work can be 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 a certificate presented by a supplier has to be checked 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 may not be volunteered, and it may not appear 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 and traders, and from 30 June 2027 for micro and small operators. Working backwards from that date: collecting plot-level data from a supplier who has never been asked for it can take weeks; 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 have little time left to fix whatever they discover.

Common questions

What does EUDR Article 9 require from a supplier? It lists the information you must hold for each product: description and species, quantity, country of production, plot geolocation with the production date, supplier and customer details, and verifiable evidence that the product is deforestation-free and legal in the country of production. Your supplier has to provide most of it.

Is a signed supplier declaration enough for EUDR? No. Article 9 asks for information that is adequately conclusive and verifiable. A declaration is only a statement. You need the records it rests on, such as plot data, harvest documents and certificates checked on the issuing body's register.

When does EUDR apply? From 30 December 2026 for large and medium operators and traders, and from 30 June 2027 for micro and small operators.

Who is liable if a supplier's data is wrong? The operator who places the product on the EU market, not the supplier who signed. A Vietnamese supplier has no exposure to an EU competent authority. You do.

Related

• Does EUDR apply to rattan and bamboo furniture from Vietnam?
• One evidence file for EUDR, UFLPA and the Lacey Act: what to collect once from a Vietnamese supplier
• How to verify a Vietnamese manufacturer before your first order
• UFLPA and transshipment risk in Vietnam
• Timber verification in Vietnam
• What a Lacey Act declaration requires for Vietnamese wood and furniture
• What documents should a Vietnamese timber supplier provide
• 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.

Field Diligence verifies Vietnamese manufacturers against these requirements, on behalf of the buyer and paid only by the buyer. Fixed published price of USD 2,200, agreed before work begins. Start with a free scoping conversation, or see a sample report first.