A coffee exporter in Dak Lak sells to Germany, the UK and Switzerland. The trade team asks counsel: “The EU has EUDR, the UK has its own law, what about Switzerland — how many dossiers do we need?” The answer: one for the EU, one taking shape for the UK, and Switzerland has no domestic law — but your EU customers will still demand EUDR compliance from you. This article maps the three-market roadmap so companies do neither too much nor too little.
The EU: EUDR — the law is settled, countdown to 30/12/2026
Regulation (EU) 2023/1115 (EUDR) covers seven commodity groups: cattle, cocoa, coffee, palm oil, rubber, soya, wood — plus derived products (chocolate, furniture, tyres and more). Three conditions for placing goods on the EU market: (1) produced on land not subject to deforestation or forest degradation since 31/12/2020; (2) compliance with the production country’s laws; (3) a due diligence statement with geolocation coordinates of the plots, filed via the EU Information System. After the second postponement under Regulation (EU) 2025/2650, EUDR applies from 30/12/2026 (medium and large operators) and 30/06/2027 (micro and small undertakings). Good news for Vietnam: under Implementing Regulation (EU) 2025/1093, Vietnam is low-risk — due diligence is simplified, but the statement must still be filed; “low risk” does not mean “exempt”.
The UK: UKFRC — framework exists, substance pending (expected 2027)
The UK is building its own Forest Risk Commodity Regulation (UKFRC) under Schedule 17 of the Environment Act 2021 — but the secondary legislation has still not been laid. The 23/6/2026 update during London Climate Action Week: a formal consultation in late 2026, legislation expected in 2027, scope of seven commodities mirroring EUDR (expanded from the original four: soya, palm oil, cocoa, beef). Meanwhile: wood and wood products in Great Britain remain under the existing UK Timber Regulation; and critically — Northern Ireland applies EUDR from 30/12/2026, so goods into Belfast differ from goods into London. For UK-bound exporters today, preparing to the EUDR standard is the smartest “one arrow, two targets” move, since the UK government has declared an EUDR-compatible direction.
Switzerland: no domestic deforestation law — but do not celebrate yet
Per the Swiss Federal Office for the Environment (BAFU): EUDR does not apply in Switzerland; placing timber on the Swiss market remains governed by the Timber Trade Ordinance (HHV). Switzerland has not enacted a deforestation-linked import ban mirroring EUDR either. However, “no domestic law” does not mean “unaffected”: Swiss companies exporting the seven commodities to the EU must comply with EUDR — and they will cascade the requirements to Vietnamese suppliers (geolocation, deforestation-free evidence, due diligence statements). In practice: if you sell green coffee to a Swiss roaster who sells on to Germany, you still need the full EUDR dossier as if selling directly to Germany.
A practical roadmap for Vietnamese companies
Q4/2026: complete geolocation mapping of sourcing areas (coffee, rubber, wood) — the most time-consuming task, impossible to rush in a month; register on and learn the EUDR Information System. Before 30/12/2026: every shipment of the seven groups into the EU (including via Northern Ireland) needs a due diligence statement. In parallel: track the late-2026 UKFRC consultation to prepare for the UK market from 2027 — EUDR-ready companies will transition smoothly. For Switzerland: write “EUDR data supply” clauses into contracts with Swiss customers now, before they urgently need the dossier and squeeze your price. And remember: Vietnam’s low-risk status is a competitive edge — sell it to EU buyers.
Frequently asked questions
Does coffee exported to Switzerland need EUDR compliance?
Not directly — EUDR does not apply in Switzerland. But if your Swiss customer re-exports to the EU (roasting, packing, then selling to Germany), they must comply with EUDR and will demand geolocation and deforestation-free evidence from you. Having the EUDR dossier ready retains Swiss customers.
Is the UKFRC in force yet?
No. The framework sits in Schedule 17 of the Environment Act 2021 but secondary legislation has not been laid. Per the 23/6/2026 update: formal consultation in late 2026, legislation expected 2027. Wood entering Great Britain remains under the UK Timber Regulation; goods into Northern Ireland face EUDR from 30/12/2026.
Does Vietnam’s low-risk status exempt exporters from EUDR statements?
No. Low-risk status under (EU) 2025/1093 only simplifies due diligence duties (fewer checks), but EU importers must still file a due diligence statement with geolocation for each consignment. “Low risk” is a competitive advantage, not an exemption certificate.
Do small exporters get a deferred EUDR deadline?
Yes. Under (EU) 2025/2650, micro and small undertakings apply from 30/06/2027 — six months after medium/large operators (30/12/2026). But large EU customers may demand your data earlier to prepare themselves — do not wait for the deadline.
Exporting coffee, wood or rubber to Europe?
Three markets, three speeds — but one common dataset: geolocation and deforestation-free evidence. FLAT Law Firm — over 30 years advising international trade — helps build traceability systems, draft EUDR due diligence statements and negotiate data clauses with UK and Swiss customers. Talk to us before 30/12/2026.
This article has been quality-reviewed by the FLAW AI Legal Council