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Chain of Custody for Wooden Furniture Exports to the EU: EUDR Documents at Each Stage

5 min readFLAT LAW FIRM

Carpenter operating a saw in a wood workshop
Photo: Pexels (free to use under the Pexels License)

Short answer: Regulation (EU) 2023/1115 on deforestation (EUDR), as amended by Regulation (EU) 2025/2650, will apply generally from 30 December 2026 (medium and large operators) and 30 June 2027 (micro and small operators). Wooden furniture entering the EU must prove two things: no deforestation after 31 December 2020 and legal production in the country of origin — backed by a due diligence statement containing the geolocation of every harvested plot, filed in the EU Information System before the goods are placed on the market. For Vietnamese wood businesses, that means building an unbroken documentary “chain of custody” from the forest plot to the export container.

1. The EUDR legal framework after the 2025 amendment

Product scope. The EUDR covers seven commodities — cattle, cocoa, coffee, oil palm, rubber, soy and wood — plus derived products listed in Annex I (for wood: including wooden furniture). Printed products (ex 49) were removed from scope by the 2025 amendment.

Two core conditions. Products must be (1) “deforestation-free”: not produced on land subject to deforestation or forest degradation after 31 December 2020; and (2) “legal”: produced in compliance with the laws of the country of production on land use, labor, human rights and tax.

Due diligence statement (Articles 4, 5). The EU importer (as “operator” — the first to place the goods on the EU market) must carry out due diligence and file a due diligence statement in the EU Information System before the goods are placed on the market. Under the 2025 amendment, “downstream operators” in the EU no longer file their own statements — only the first operator in the EU chain bears the duty, and later parties keep the reference number.

Geolocation (Article 9). The most operationally painful requirement: the statement must include the geographic coordinates of every plot where the timber was harvested — polygons for plots over 4 hectares, not a single point or a vague locality name.

Country risk benchmarking. Since May 2025, the European Commission classifies countries/regions as high, standard or low risk; goods from low-risk countries qualify for simplified due diligence.

Penalties. Fines of up to 4% of the offending company’s EU turnover, plus seizure of goods and exclusion from public procurement.

2. Chain-of-custody documents at each stage — from Vietnamese forest plot to EU port

Stage 1 — Harvesting (forest plot). Timber origin dossier: harvesting permits, plantation allocation or purchase contracts, and most critically the geolocation of the harvested plot (polygon if over 4 ha). For Vietnamese plantation timber, exporters must work closely with forest owners and planting households on this.

Stage 2 — Transport and primary processing (sawmilling). Handover records between stages showing volumes, species and plot numbers; at the sawmill, batch-segregation logs — timber with a complete EUDR file and timber without it must not be mixed if the shipment is to keep its “deforestation-free” status.

Stage 3 — Furniture factory. Incoming material records (warehouse receipts tied to harvest plot numbers), material consumption norms per product code, and a traceability system that can trace one export container of finished goods back to the exact harvested plots. This is chain of custody in its narrowest sense — a break here collapses the entire EU-side due diligence statement.

Stage 4 — Export from Vietnam. The normal export dossier (customs declaration, commercial invoice, packing list, origin documents) plus the consolidated EUDR file from the earlier stages, handed to the EU importer. The Vietnamese exporter does not file the due diligence statement in the EU system itself (that duty sits with the EU operator), but without complete data the EU importer cannot file — and will switch suppliers.

Stage 5 — Import into the EU. The importer (operator) runs the three-step due diligence — information gathering, risk assessment, risk mitigation — then files the statement in the EU Information System. An EORI number is needed to register.

3. Notes specific to Vietnamese wood businesses

Vietnam and the EU have a Voluntary Partnership Agreement on forest law enforcement (VPA/FLEGT) with a timber legality assurance system (VNTLAS) — a solid foundation for the EUDR’s “legality” condition. But VNTLAS does not substitute for the EUDR’s “deforestation-free” requirement and geolocation data: companies must still build their own plot-coordinate datasets and traceability chains.

The time until 30 December 2026 should be used to: digitize existing timber origin records, sign coordinate-collection agreements with forest owners/planting households, and pilot the traceability workflow on a few sample shipments before the rules fully bite.

Frequently asked questions

When does the EUDR apply?
Regulation (EU) 2023/1115 as amended by Regulation (EU) 2025/2650 (adopted 19 December 2025): general application from 30 December 2026 for medium and large operators (including small timber operators already under the EUTR), and from 30 June 2027 for remaining micro and small operators.

Must the Vietnamese exporter file the due diligence statement in the EU system?
No. The filing duty belongs to the “operator” — the first to place the goods on the EU market (usually the EU importer). But the Vietnamese exporter must supply complete data (plot coordinates, legality file) so the importer can meet the duty.

How detailed must the geolocation be?
Down to each harvested plot; plots over 4 ha require the surrounding polygon, per Article 9 of the Regulation. A generic locality name or one coordinate for a whole sourcing region does not suffice.

Does FSC certification automatically satisfy the EUDR?
Not automatically. Sustainable forest management certification is good evidence for the “legality” condition and supports risk assessment, but the EUDR still requires full geolocation data and a separate due diligence statement.

What are the penalties for EUDR breaches?
Fines of up to 4% of the company’s total EU turnover, plus measures such as confiscation of goods and exclusion from public procurement.

This article has been quality-reviewed by the FLAW AI Legal Council

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