What a Lacey Act declaration now requires for Vietnamese wood and furniture.
Since December 2024, many wood furniture imports fall under Lacey Act declaration requirements. A buyer who has imported furniture from Vietnam for years may never have filed a declaration. That has changed, and the paperwork does not assemble itself.
The short answer. Since APHIS Phase VII took effect on 1 December 2024, many wood furniture imports need a Lacey Act declaration. It states the scientific name of the plant, the value and quantity of the importation, and the country where the plant was harvested. Whether your product is covered depends on its HTS code, so check the code against the APHIS schedule. The declaration is filed in the importer's name, so the importer carries the exposure if it is wrong.
What the Lacey Act actually requires
The Lacey Act makes it unlawful to import plant products, including wood and wood furniture, taken, possessed, or sold in violation of the law of the country of harvest. Since 2009, APHIS has phased in a declaration requirement that forces the paperwork this creates to exist at the border rather than only after the fact: an import declaration stating, among other things, the scientific name of the plant, the value of the importation, the quantity, and the name of the country where the plant was harvested.
A Lacey Act declaration is a legal filing about the plant material in your product. It is a different document from an EUDR due diligence statement or a UFLPA supply-chain file, even though the underlying evidence, species, origin, chain of custody, overlaps substantially.
Why furniture buyers cannot ignore this anymore
On 1 December 2024, APHIS implemented Phase VII of the Lacey Act declaration schedule, extending the requirement to the remaining plant-product Harmonized Tariff Schedule (HTS) codes that are not entirely composite materials, including further furniture classifications beyond those already covered in earlier phases. Since 1 January 2026 APHIS accepts declarations only through CBP's Automated Commercial Environment (ACE) or its Lacey Act Web Governance System, not on paper. See APHIS's own announcement of Phase VII for the underlying Federal Register notice and scope. For many wood furniture products imported under covered Chapter 94 HTS classifications, this became a new declaration obligation from December 1, 2024. The exact requirement depends on the product classification and current APHIS coverage: confirm your specific HTS codes against APHIS's implementation schedule rather than assuming coverage either way.
What the declaration needs, and where it comes from
- Scientific name of the species. Common names on a supplier invoice ("pine," "acacia") are not sufficient on their own; the genus and species need to be established and be consistent with what a physical inspection would actually find in the product.
- Country of harvest. Not country of manufacture. For furniture assembled in Vietnam from imported sawn timber, the country of harvest is wherever the tree was cut, which may not be Vietnam at all.
- Quantity and value. Consistent with the commercial invoice and with what the facility can plausibly have produced from the input volume it holds.
A supplier who has only ever shipped to markets that never asked for this may not have it assembled, even where the underlying facts are unproblematic. The gap may be administrative rather than substantive, but the declaration is a legal filing made in the importer's name, and an inaccurate one is the importer's exposure, not the supplier's.
Where this overlaps with EUDR and UFLPA
Buyers selling into the EU as well as the US may treat these as unrelated compliance programmes. They draw on the same underlying evidence: species and origin documentation, chain of custody from harvest to the finished product, and visibility into whether inputs were subcontracted through an undisclosed workshop. A site visit scoped to cover Lacey Act, EUDR Article 9, and UFLPA transshipment risk together costs materially less than three separate exercises, because the physical checks, what is on the yard, what the intake records show, who else touches the product, are largely the same checks. That single visit is the same timber verification scope described elsewhere on this site: one engagement, not three.
What to ask a Vietnamese furniture supplier before your next order
- What is the scientific (not common) name of every wood species in this product?
- For each species, what is the country of harvest: not the country of manufacture?
- If any input is imported into Vietnam before assembly, from where, and can that be shown in intake records rather than summarised?
- Has this supplier filed Lacey Act declarations before, for any customer? If not, do not assume the internal process to assemble one already exists.
Common questions
What does a Lacey Act declaration need to state? The scientific name of the plant, the value of the importation, the quantity, and the name of the country where the plant was harvested.
Is furniture from Vietnam covered by the Lacey Act declaration? It depends on the HTS classification of the product. Phase VII extended the requirement to the remaining plant-product HTS codes that are not entirely composite materials. Confirm your own codes with APHIS or your customs counsel.
Is the country of harvest the same as the country of manufacture? No. For furniture assembled in Vietnam from imported sawn timber, the country of harvest is wherever the tree was cut, which may not be Vietnam.
Can I still file a Lacey Act declaration on paper? No. Since 1 January 2026 APHIS accepts declarations only through CBP's Automated Commercial Environment (ACE) or its Lacey Act Web Governance System.
Related
- One evidence file for EUDR, UFLPA and the Lacey Act: what to collect once from a Vietnamese supplier
- Timber verification in Vietnam
- What EUDR Article 9 requires from a Vietnamese supplier
- UFLPA and transshipment risk in Vietnam
General information on US Lacey Act declaration requirements as they apply to Vietnamese wood and furniture sourcing, not legal advice. Confirm current HTS coverage and declaration mechanics with APHIS or your customs counsel for your specific product.
Field Diligence verifies the species, origin and documentation evidence a Lacey Act declaration depends on, on behalf of the buyer and paid only by the buyer: see current published pricing. Start with a free scoping conversation, or see a sample report first.