One evidence file for EUDR, UFLPA and the Lacey Act: what to collect once from a Vietnamese supplier
If you sell wood or furniture into both the EU and the US, you have three laws and one supplier. Most of the evidence is the same.
The short answer. You do not need three separate checks. The EU Deforestation Regulation (EUDR), the US Uyghur Forced Labor Prevention Act (UFLPA) and the US Lacey Act ask for overlapping evidence: who the supplier is, what species the wood is, where it grew, who handled it on the way, and whether it is legal. Collect it once, check it once on site, and map it to each law.
Key facts, as of 13 October 2026
- EUDR applies from 30 December 2026 to large and medium operators and traders, and from 30 June 2027 to micro and small operators. The Commission's May 2026 review left these dates unchanged.
- The UFLPA Entity List has 187 entities since 3 August 2026, after 43 were added at once.
- The Lacey Act declaration covers most plant products, including wood furniture, since 1 December 2024 (Phase VII).
Official sources: EUR-Lex, Regulation (EU) 2023/1115 · US Department of Homeland Security, UFLPA Entity List · USDA APHIS, Lacey Act implementation schedule.
The three laws have different regulators. Each one puts the legal duty on the importer or operator, not on the factory. The supplier sees it differently: the same factory gets asked three times, by three buyers or three departments, for documents that overlap. The answers can even contradict each other.
A single evidence file ends that. This page lists what goes in it and where the laws differ.
What does each law ask for?
EUDR. Anyone placing wood or wood products on the EU market, or exporting them, must do due diligence and file a due diligence statement. Article 9 lists what to collect: a description of the product, its quantity, the species with its scientific name, the country of production, the geolocation of the plots where the wood grew, and the date or period of production. It applies from 30 December 2026 for large and medium operators and traders, and from 30 June 2027 for micro and small operators. Wooden furniture is covered. Products made of bamboo or rattan, and used or second-hand goods, are not. Read what Article 9 requires from a Vietnamese supplier.
UFLPA. US Customs and Border Protection presumes that goods made wholly or partly in Xinjiang, or by a company on the UFLPA Entity List, were made with forced labour, and it keeps them out of the United States. The importer can rebut this, but only with clear and convincing evidence that the goods are free of forced labour. With 187 entities on the list since 3 August 2026, a name that was clean last year may not be clean now. Read about UFLPA transshipment risk in Vietnam.
Lacey Act. It is illegal to import plant products, including wood and wood furniture, that were taken or traded against the law of the country of harvest. APHIS requires an import declaration for covered products. It states, among other things, the scientific name of the plant, the value and quantity, and the country of harvest. Phase VII, from 1 December 2024, extended it to the remaining plant-product tariff codes that are not entirely composite materials. The importer is held to a standard of due care. Read about the Lacey Act and Vietnamese wood furniture.
What goes into the evidence file?
The table shows what to collect from the supplier and what each law does with it. "Required" means the law names the item. "Supports" means the item is not a listed field, but you need it to defend your filing or your claim.
| Evidence | EUDR | UFLPA | Lacey Act |
|---|---|---|---|
| Legal identity: name, enterprise code, address, legal representative, owners, parent and affiliates | Required: supplier name and address | Needed to screen the company and its parents against the Entity List | Supports: links the declaration to whoever holds the records |
| Product description and tariff code | Required | Supports: shows which inputs you must trace | Required: the tariff code decides whether a declaration is due |
| Species, common and scientific name | Required for timber | Not listed | Required: genus and species |
| Country of harvest | Required | Supports: shows whether inputs came from a sensitive region | Required |
| Plot geolocation | Required | Not listed | Supports: shows where the wood was cut |
| Quantity and value | Required: quantity | Supports: volumes that do not reconcile can point to swapped inputs | Required: quantity and value |
| Date or period of harvest and production | Required | Supports: dates input purchases | Supports: legality is judged against the law at the time of harvest |
| Chain of custody: every step from forest to factory, with each trader named | Supports the risk assessment | Required in practice: it is the evidence used to rebut the presumption | Supports due care |
| Legality papers: harvest, transport, export and tax records | Required: compliance with the law of the country of production | Not listed | Required in practice: legality under the harvest country's law is the whole question |
| Subcontracting: which steps are done where, by whom | Supports the risk assessment | Supports: a hidden workshop is a company nobody screened | Supports |
| Screening record: list, date, version, result | Supports | Required in practice | Not listed |
| On-site confirmation: factory, equipment, stock, records held | Supports | Supports | Supports |
Check the current regulation text and the current APHIS form for your product before relying on one row. This page is general information, not legal advice.
Where do the three laws differ?
When it applies. EUDR needs the due diligence done, and the statement filed, before the product goes on the EU market. UFLPA applies at the US border, where customs can detain a shipment. The Lacey Act applies when you file the declaration, and again later if anyone questions what you declared.
What kind of proof. EUDR is built around geolocated plots and a risk assessment you write down. UFLPA is built around the supply chain: who made what from which inputs, and whether any link leads to Xinjiang or a listed company. The Lacey Act is built around whether the wood was cut legally.
Who carries the risk. In all three it is the importer. A supplier who cannot produce the evidence leaves you with the problem.
In what order should you work?
- Identity first. Confirm the legal entity and screen it and its owners. Every other document refers to a name.
- Product and species. Settle the tariff code, the scientific names and the quantities.
- Map the chain. Name each step between forest and factory, including any trader.
- Collect origin and legality records, including plot data, from whoever holds them.
- Verify on site. Confirm that the company, the people and the records are real and match what you were sent.
- Date the file and keep it current. Update it when the supplier, the species or the source changes.
Four mistakes to avoid
- Treating a signed supplier declaration as proof. It is a statement. The evidence is what stands behind it.
- Screening only the supplier. Listed entities can sit further up the chain, or behind an owner or a joint venture partner.
- Accepting certificates as files. Look each one up with the body that issued it, under the supplier's exact name and scope.
- Starting late. A supplier who has never been asked for plot-level data may need weeks. A trader further up the chain may not hold the data and may be unable to get it. Beginning well before 30 December 2026 leaves room to change supplier.
How Field Diligence builds the file
We visit the supplier in Vietnam on your behalf, collect this evidence, check it on site, and write the report. It maps what we found to the requirements of EUDR, UFLPA and the Lacey Act, so one engagement serves a buyer who sells into both markets. The fee is fixed and published, and it is agreed before work starts. You pay it. The supplier does not.
We are not a certification body, we do not give legal opinions, and we do not make the filing for you. We deliver verified evidence that your compliance team or your lawyer can file on.
Common questions
Do I need three separate checks? No. The evidence overlaps heavily. Collection and on-site verification happen once. Only the mapping to each law differs.
Does an FSC certificate replace the evidence file? No. A certificate is one document in the file. Look it up on the issuer's register under the supplier's exact name and scope.
What if the supplier cannot give plot geolocation? Then your EUDR evidence for that supplier is incomplete. Decide whether the gap can be closed upstream in time, or whether the order should move to a supplier who can document it.
Does the Lacey Act apply to furniture from Vietnam? A declaration is required for covered tariff codes, and the requirement depends on your product's classification. Confirm your tariff code with APHIS or your customs broker.
Related
- How to screen a Vietnamese supplier against the UFLPA Entity List
- Does EUDR apply to rattan and bamboo furniture from Vietnam?
- What EUDR Article 9 requires from a Vietnamese supplier
- UFLPA and transshipment risk in Vietnam
- What a Lacey Act declaration requires for Vietnamese wood and furniture
- Vietnam supplier due diligence checklist
We build this file on site in Vietnam, on behalf of the buyer and paid only by the buyer. See current pricing or book a free scoping call.